The Law 2/2023 regulates the protection of the people who report regulatory infringements and the fight against corruption, published in the Official State Gazette of February 21, requires, in its art. 4, that all companies with more than fifty employees to have an internal communication system, which guarantees the confidentiality of the informant, which is independent and has a management procedure.

The Board of Directors of PAPEL ARALAR S.A. approved on March 22, 2023 a Crime Prevention Model and a Code of Ethics regulating its social commitments with its Stakeholders (shareholders, managers, workers, customers, suppliers, competitors, institutions and society in general).

As part of mentioned Crime Prevention Model (CPM) and Code of Ethics a Whistleblower Channel was implemented on the aforementioned date at the e-mail address canal@papelaralar.com; independent from the company’s computer server and to which only the Compliance Officer of the aforementioned CPM has access, which guarantees the confidentiality of the informant and the management of any complaint, by means the established procedure.

Amézketa, 15th October 2023