Ethical Mailbox

This Code of Ethics is mandatory for all members of the Lucta Group, regardless of their role and geographic location. In view of the current regulatory environment, the Board of Directors of Lucta Spain has decided to draw up this Code of Ethics in order to maintain and uphold the highest ethical standards in the carrying out of the company’s business activity.

The complete document is intended to serve as a guide for the actions of all employees, regulating daily decision-making and the day-to-day activity of the Lucta Group.

The Lucta Ethics Mailbox and its function is regulated in the Resolution Protocol.

The Lucta Ethics Committee is in charge of managing the Ethics Mailbox and the communications received through the following:

Lucta is committed to compliance with the law and its ethical principles and values in all areas of its business and commercial activity, a commitment reflected briefly in the Code of Ethics that serves as a guide for the actions of all employees, directors, advisors, and third parties with whom the Lucta Group maintains business relations, regardless of their function and geographical location.

Within the framework of the Corporate Compliance system implemented by Lucta, one of the fundamental tools to ensure regulatory compliance is its Ethical Mailbox, through which any person may (i) bring to its attention any regulatory non-compliance of which they are aware or has reason to suspect, or (ii) communicate any doubts they may have regarding regulatory compliance. Such communication can be made either identified or anonymously and will always be treated confidentially. 

Lucta’s Ethical Mailbox includes the following ways of communication: 

  1. Through a link to the Whistleblower Software platform published on the company’s website and through the QR code included on the signs at its facilities.
  2. By directly informing any of the members of the Ethics Committee, either verbally or in writing. In this case, the Ethics Committee member must send a notification through the Whistleblower Software platform. At the request of the reporting party, an in-person meeting can be held with a member of the Ethics Committee to explain and detail the facts of the complaint. A breach can also be reported by phone. The contact number is +34 93 845 89 32.
  3. Through the appropriate physical mailboxes provided at Lucta’s facilities for employees who do not have access to a computer assigned by Lucta.

The Ethics Committee of Lucta has been designated as Responsible for the internal information system (Ethics Mailbox). In turn, this committee has appointed one of its members, Lucta’s Director of Human Resources, to manage the channel and process investigation files.To regulate the use of the Reporting Channel and the procedure for investigating and resolving notifications, Lucta has approved and implemented not only the Protocol for the management, investigation, and resolution of notifications received through the ethics mailbox but also the Whistleblowing Policy.Lucta has adopted the necessary measures for preventing all possible forms of retaliation against reporting persons, including threats of retaliation and attempted retaliation, and it will ensure that all reporting persons have access, as applicable, to the necessary support measures for ensuring that they are effectively protected.

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