Anticipa’s Commitment

At Anticipa Real Estate, we firmly believe that our company should be guided by values that define how we work and interact with our environment. To this end, our work is based on values like excellence, teamwork, results orientation and transparency. We have zero tolerance for any type of behaviour that is illegal, inappropriate, fraudulent or contrary to good practice. Anticipa makes this commitment to its clients, users, suppliers, business partners and the public authorities.

Our commitment is based on the following principles:

I. Identifying and integrating all the actions needed to prevent, detect and react to any unlawful acts that may be committed.

II. Creating a climate of compliance and transparency.

III. Maintaining and improving channels to encourage people to report possible irregularities, raise doubts and put forward suggestions.

IV. Making it a requirement to provide information about any action that may constitute a crime, fraud or irregularity through the Complaints Channel.

V. Fostering a culture of ethics and compliance by: (i) encouraging responsible behaviour; (ii) raising awareness and establishing protocols and committees in order to correctly develop the aims of the company, so that each member of the organisation takes action and makes decisions in accordance with internal and external regulations; (iii) setting up programmes to provide training and information, and to raise awareness.

VI. Investigating all complaints about supposedly illegal or fraudulent conduct, and irregularities, in accordance with the Code of Conduct.

To this end, Anticipa has implemented and maintains a criminal risk management system focused on honouring the commitments made and minimising risk to the company. Furthermore, Anticipa has pledged to continually improve this system. For this purpose, it has created a body responsible for managing the system with sufficient authority and independence to carry out its task (Code of Conduct Committee).

Should the company become aware that an employee has breached the commitment described above, it will act in accordance with the penalty system established in the Code of Conduct and adopt the measures deemed appropriate. If necessary, it will apply the relevant penalty and/or take legal action pursuant to the regulations applicable to each case.

External Complaints Channel

The principles described above reflect the objective to strictly comply, at all times, with all standards, laws and principles that regulate corporate life. To this end, Anticipa has a Code of Conduct, which sets out the ethical principles and standards that must govern the behaviour of all company employees. This code is designed to guarantee ethics and integrity in our daily work, in all spheres of the organisation. Our responsibility encompasses prevention, detection and response, in order to ensure strict compliance with the regulations and ethical standards applicable to our operations.

Consequently, a Complaints Channel is open to all our stakeholders, so they can raise the alert to behaviour that is illegal, inappropriate or in breach of good market practices.

Where to direct your complaint

If you are aware of, or have proof or evidence of incidents of corruption, or illegal or irregular conduct by anyone linked with Anticipa, you can contact us through the following channels:

Email: denuncia@anticipa.com

You can use this address to send information about behaviour or a situation that may be considered illegal or irregular. Remember that when you send an email, you will indirectly transfer personal and traceable data, such as your IP address. These data may reveal the identity of the person sending the email and even of any email accounts created specifically for this purpose.

Post

Please write to:

Anticipa Code of Conduct Committee,

C/Roure, 6-8, 4ªpl,

08820 El Prat de Llobregat (Barcelona)

You may choose to make your complaint anonymously.

In person

You can come to our offices in person. Please make an appointment by telephoning +34 934 84 88 36 so we can ensure an authorised member of staff will be available to meet you.

How to make a complaint

If you wish to make a complaint in writing, we need you to provide us with as much information as possible, so we can analyse the issues you wish to raise.

- Describe the events simply, but in detail.

- Identify the people or companies involved, and the business area they belong to, if you know this.

- Tell us when the events occurred.

- If you have any documents to support your complaint or that could help resolve it, please send them to us.

- Give us any other information you consider relevant.

- Provide your contact details, unless you wish to make an anonymous complaint.

How your complaint will be handled

After receiving your complaint, the Code of Conduct Committee will analyse it. If there are signs of inappropriate behaviour, the investigation phase will begin. If not, the case file will be closed.

If you so request, you will be informed about the progress of your complaint.

Use of the information

Anticipa guarantees the confidentiality of all information and content provided, and of the identity of the person making the complaint. If personal data are provided, they will be processed in accordance with the applicable regulations, and they will only be kept for the time needed to look into the events described.