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COMPLAINT POLICY

1. Objective

The purpose of this document is to present our Internal Information System Web Policy in order to demonstrate compliance with art. 25 of Law 2/2023, of the 20th of February, which regulates the protection of persons who report normative infringements and the fight against corruption, as well compliance with the other national regulations that transpose the aforementioned directive in those countries in which the MIRAI GROUP operates.

The aforementioned article establishes that “The entities within the scope of application of this law shall provide adequate information in a clear and easily accessible form relating to the use of any internal information channel they have implemented as well as to the essential principles of management procedure. In the event these entities possess a website, such information shall be provided on the homepage in a separate, easily identifiable section”.

As a result, the websites https://es.mirai.com/es/, https://fr.mirai.com/, https://es.mirai.com/ca/, https://pt.mirai.com/, https://www.mirai.com/home/, http://www.nexiasolutions.es/, https://heraton.es/ will contain the present document as well as access to a complaint form.

2. Internal Information System Web Policy

Internal information system policy

In compliance with Law 2/2023 of the 20th of February regulating the protection of persons who report normative infringements and the fight against corruption, and which transposes minto the Spanish legal system Directive (EU) 2019/1937 of the European Parliament and of the Council of the 23rd of October 2019, commonly known as the Whistleblowing Directive, as well as in compliance with the other national regulations that transpose the aforementioned directive in those countries in which we operate, MIRAI GROUP has implemented a single Internal Reporting System common to the entities that constitute the group with the aim of creating an information channel in which people can report information on irregularities as well as cases of workplace harassment.

GRUPO MIRAI comprises the following entities:

  • MIRAI ESPAÑA, S.L
  • MIRAI USA LLC
  • MIRAIFUTURE PORTUGAL, LDA
  • MIRAI FRANCE, SARL
  • MEXICO MIRAI HOTELIER S DE RL DE CV
  • HERATON SYSTEMS, S.L.
  • NEXIA SOLUTIONS S.L

The Governing Body of MIRAI ESPAÑA S.L. has appointed an Internal Information System Manager who will be the person in charge of receiving and processing all communications received through our communications channel.

How can I submit a communication?

In the event you should become aware of the commission of any infringement by MIRAI GROUP personnel, or have reasonable grounds to believe that this is happening, you should report this circumstance in writing via the web portal https://demo-4c19318e0bf80d55f2de.factorialhr.es/complaints. Additionally, should you wish to report this circumstance in person to the Head of the MIRAI GROUP’s Internal Information System, you should indicate this in the description section of the aforementioned communication form.

Please note that you have the right to submit anonymous communications should you consider it appropriate.

In the case of communications received by MIRAI ESPAÑA S.L. relating to workplace harassment it will be necessary for the informant to identify himself/herself in order to be able to offer him/her protection as the person being harassed.

Which persons are protected against retaliation for submitting a communication?

GRUPO MIRAI is fully committed to compliance with the applicable legal framework and takes a zero tolerance position regarding the commission of irregularities. Any person may submit a communication to MIRAI GROUP if they have knowledge of the commission of any infringement by MIRAI GROUP personnel or reasonable grounds to believe that such an infringement is being committed.

The MIRAI GROUP formally undertakes to prohibit any form of retaliation against bona fide informants.

The informant’s personal data will in no case be communicated to the reported person.

In relation to what subjects may communications be submitted?

The informant will enjoy all protection mechanisms for bona fide communications relating to the following matters:

  • Public procurement;
  • Financial services, products and markets;
  • Prevention of money laundering and financing of terrorism;
  • Product safety and compliance;
  • Transport safety;
  • Environmental protection;
  • Radiation protection and nuclear safety;
  • Food and feed safety, animal health and animal welfare;
  • Public health;
  • Consumer protection;
  • Protection of privacy and personal data;
  • Security of networks and information systems;
  • Infringements affecting the EU’s financial interests; and
  • Infringements relating to the internal market, including infringements relating to competition and aid granted by EU member states as well as infringements relating to corporate taxation or to practices aimed at obtaining a tax advantage that would undermine the object or purpose of the applicable corporate tax law.

In addition to the specific matters indicated above, informants shall also be protected against any action or omission that may constitute a serious or very serious criminal or administrative offence, in particular offences relating to financial losses for the Public Treasury and Social Security, as established in current Spanish legislation and in compliance with other national regulations that transpose the aforementioned directive in those countries in which the MIRAI GROUP operates.

In the event the complaint relates to potential sexual or gender-based harassment at MIRAI ESPAÑA S.L., the facts will be brought to the attention of the Harassment Protocol Advisory Committee with the aim of processing the complaint in accordance with the “Protocol for the prevention of and action against sexual harassment and gender-based harassment”, due to the approval of it. In the remaining entities that constitute the MIRAI GROUP, the facts relating to potential workplace harassment, sexual harassment or harassment for reasons of sex shall be governed by the provisions of this procedure in the event no specific protocol for the same exists.

How will MIRAI handle the communications it receives?

In general, the MIRAI GROUP will remit acknowledgement of receipt of the communication submitted within a maximum period of seven days from receipt of the same, and process the communication in accordance with MIRAI GROUP’s internal communications management procedure. The maximum period for processing communications shall be CONFIDENTIAL Page 6 of 6 EDITION 2 three months, with the exception of cases of particular complexity, in which case the maximum period may be extended for an additional three months.

The communications management procedure is governed by the following principles:

  • Zero tolerance regarding the commission of irregularities
  • Effective, diligent processing of any information received
  • Processing of information received under the principles of objectivity and impartiality
  • Implementation of a secure channel for communication and information management
  • Guarantee of confidentiality of the identity of the informant and of any other third party mentioned in the communications, as well as of the actions carried out during the processing of the communication
  • Access by the minimum essential personnel to the content of the information received
  • Guaranteeing the protection of bona fide informants, preventing them from being subjected to any form of reprisal, threat of reprisal or attempted reprisal due to their status as informants
  • Guaranteeing the protection of the persons concerned by informing them of the actions or omissions attributed to them, respecting their right of defence, their right to be heard, as well as guaranteeing their right to the presumption of innocence and their right to honour, and
  • Guarantee of immediate notification to and collaboration with the competent authorities regarding any information that could constitute a crime.

Complaints relating to situations of harassment at MIRAI ESPAÑA S.L. will follow their own procedure, of which the members of MIRAI ESPAÑA S.L. have been duly informed.

How may I clarify doubts relating to MIRAI GROUP’s internal information channel?

We are at your disposal for any clarification you may require regarding MIRAI GROUP’s internal information channel. The Head of the Internal Information System may be contacted at https://demo-4c19318e0bf80d55f2de.factorialhr.es/complaints