Legal
department

As usual, there have been no legal actions or investigations regarding unfair competition or monopolistic practices at Aciturri during 2022.

There is also no record of any formal complaints regarding violations of customer privacy in 2022. There have been no leaks, theft or loss of customer data of which the organization is aware.

However, in compliance with confidentiality obligations to customers, and also with the intention of protecting its own confidential information, Aciturri has all suppliers or third parties sign non-disclosure agreements before any sensitive or confidential information is forwarded to them or made accessible to them. In 2022, some eighty NDAs have been signed.

As usual, there have been no legal actions or investigations regarding unfair competition or monopolistic practices at Aciturri during 2022.

Employee contracts also include specific clauses relating to confidentiality.

Aciturri has a Responsible Advertising Policy, approved by the Chief Executive Officer in 2012, aimed at all stakeholders, with special emphasis on customers. This document refers to issues such as respect for legality, good faith, no incitement to violence, illegal behavior or discrimination, respect for good taste, the environment or truthfulness.

There is no record of any non-compliance related to marketing communications in 2022.

Throughout the 2022 financial year, the Aciturri Group companies have paid nine financial penalties, for a total amount of € 6,678.97.

Specifically, the following penalties have been paid: four penalties amounting to 1,968.04 € (575.77 € + 626.02 € + 307.08 € + 459.17 €) for errors in the customs management of a supplier before the Burgos Customs Administration of the Tax Agency; a penalty amounting to 300 €, for not identifying the driver responsible for a traffic offence before the Territorial Traffic Office of Álava of the Basque Government Department of Security; a penalty amounting to 2. 346.73 €, as a consequence of a tax inspection of the Tax on Economic Activities for the years 2017 to 2021, before the City Council of Berantevilla; a sanction of 143 €, for an infraction derived from the delay in sending data related to the Annual Industrial Products Survey 2020, imposed by the National Institute of Statistics; and two sanctions amounting to 1. 1,921.20 (1,470.60 € + 450.60 €) for infractions derived from sanctioning proceedings imposed by the Directorate General of Labor of the Community of Madrid.

There is no record of cases that have resulted in non-monetary sanctions.