1. Introduction

Oxford Oil Additives is committed to ensuring that people feel safe when seeking advice and raising concerns. This is why the company has implemented a management model that prevents, detects, and mitigates the commission of crimes within the company, in accordance with Law 2/2023 of February 20, 2023.

2. Objective

In order to prevent or detect any irregular conduct that may occur, we have established a Whistleblowing Channel. This allows all staff, customers, collaborators, or suppliers to report irregularities, providing them with a tool to fulfill the duty to inform and report potential risks or breaches of the Law, any other internal regulations, or any actions implemented by the Company that could be considered unlawful or criminal.

3. Operation of the Whistleblowing Channel

3.1 Communication:

Reports will be made through the website https://ooadditives.com by filling out the Whistleblowing Channel form.

3.2 Content of the Report:

The reports received must contain the necessary data to analyze the reported facts. Therefore, the communications received must at least meet the following requirements:

1. Clear and detailed description of the facts
2. Identification of the location where they took place
3. Identification of the persons involved in the reported behavior or those aware of it
4. Timing of when the event occurred or has been occurring
5. Submission, if deemed necessary, of documents, files, or other information considered relevant for the evaluation and resolution of the report

3.3 Handling the Report:

The principles of confidentiality govern the management of the Whistleblowing Channel. The anonymous submission of irregularity reports ensures that no one will know the identity of the whistleblower. The reports received will only be known by a limited number of people, those who need to know for the investigation or corrective actions according to applicable laws. Persons who report in good faith will be free from reprisals or victimization for making the report.

3.4 Verification of the Reported Facts:

All reports made under this policy will be investigated promptly and thoroughly.

The specific action taken in any particular case depends on the nature and seriousness of the reported conduct or circumstances and the investigation results. If misconduct is confirmed through an investigation, the company will take appropriate and proportionate measures to prevent further misconduct.

3.5 Resolution:

When possible and deemed appropriate, the whistleblower may be provided with a notice on the status of the investigation. Given the sensitive nature of many investigations arising from whistleblower reports and certain limitations according to applicable laws, we do not commit to providing the whistleblower with any updates or the outcome of an investigation. Specific information will be provided on a case-by-case basis.

To the extent permitted or required by applicable laws, the reported information may be communicated to public bodies or competent authorities for the prosecution of crimes. In doing so, the Company will strive to maintain the confidentiality of the whistleblower’s identity.