To ensure strict compliance at all times with all rules, laws, and principles that regulate its corporate life, Testa Homes, S.L. («Testa Homes«) has a Code of Conduct that sets out the ethical principles and standards that should govern the behaviour of all our employees. The purpose of the Code is to guarantee ethics and integrity in our daily activities across all areas of the organisation. Our responsibility includes prevention, detection, and response to ensure strict compliance with ethics regulations and standards wherever we operate.

For this reason, we provide all our stakeholders with a Whistleblowing Channel that allows them to effectively report any improper, unlawful or criminal behaviour that is occurring, has occurred or is about to occur at Testa Homes. Improper, unlawful or criminal behaviour means any type of legal infringement, violation of the Code of Conduct or inappropriate conduct contrary to market best practices.

Where to Report

If you are aware or have evidence or indications of corrupt, unlawful or improper conducts by anyone associated with Testa Homes, the following reporting channels are available to you:

Online Platform

https://testahome.i2-ethics.com/

Through this platform, you can submit information about any conduct or situation that may be considered unlawful or improper. The report can be entirely anonymous, but if you prefer to identify yourself, please check the boxes indicating “Share this information with Testa Homes” next to the fields for your personal details. In this case, the whistleblower’s identity will be confidential and known only to the investigating body.

In-Person

Through a face-to-face meeting at our offices located at Calle Santiago de Compostela 94, 3rd floor, 28035 Madrid. You must arrange an appointment for these meetings.

How to Submit a Report

In order for us to analyse the facts you report, we need you to provide as much information as possible:

• Describe the events clearly and in detail.
• Identify the individuals or companies involved, as well as the area of the company to which they belong, if known.
• Tell us when the events occurred.
• If you have documents supporting the report or that facilitate its resolution, submit them as well.
• Provide any other information you consider relevant.
• Give us your contact information, unless you are making an anonymous report.

Handling of the Report

Upon its receipt, the report will be analysed by the Code of Conduct Committee. If there are signs of misconduct, the investigation phase will begin; otherwise, the case will be closed. You can track the status of your report in the follow-up section.

Use of Information

Testa Homes guarantees the confidentiality of all information provided, as well as the identity of the whistleblower. Testa Homes likewise safeguards that there are not reprisals against those who have made good-faith reports or reports based on a reasonable belief.

In compliance with personal data protection regulations, Testa Homes expressly places on record that personal information included in the report and the file processed as a result will be treated under Testa Homes’s control. Use of said information will be limited to processing and investigating the reported incident. The processing is justified by the compliance with a legal obligation, pursuit of a public interest mission and a legitimate interest.

The legally stipulated limitations serve to guarantee the rights of access, rectification, objection, deletion, portability, processing limitation and all other applicable rights, which may be exercised by writing to the Data Protection Officer: Calle Santiago de Compostela 94, planta 3º, 28035 Madrid, or by sending an email lopd@testahomes.com. Personal data will be processed while the case is under investigation and, afterwards, retained for the time necessary to demonstrate compliance with the Whistleblowing System for a maximum period of 10 years.

Any claims or requests relating to the protection of personal data can be addressed to the Spanish Data Protection Agency (Agencia Española de Protección de Datos).