Whistleblowing Channel

In compliance with Spanish Law 2/2023 of 20 February, regulating the protection of persons reporting regulatory breaches and combating corruption, QILIMANJARO QUANTUM TECH S.L. makes this whistleblowing channel available as the preferred means of reporting any legal breaches detected within our organisation.

What can be reported?

You should report facts or well-founded suspicions regarding irregularities, such as:

• Breaches of EU law, provided they affect the financial interests of the EU or impact the internal market.
• Serious or very serious administrative breaches.
• Acts constituting a criminal offence.

Employees or any third party may report potential concerns in complete confidence. No form of retaliation will be tolerated against anyone who, in good faith, reports a breach or raises questions about Qilimanjaro’s internal regulations or legislation, nor against anyone who cooperates in an investigation into alleged misconduct.

Who can report?

Anyone who, in a work or professional context with Qilimanjaro, has obtained information regarding the aforementioned breaches, including: staff (current or former), candidates in recruitment processes, suppliers, customers, contractors and any other third parties.

What safeguards are in place?

Qilimanjaro’s whistleblowing channel has been designed to provide an environment of maximum security and protection for the whistleblower, based on the following principles:

• The absolute confidentiality of the whistleblower’s identity and that of any third party mentioned in the report is guaranteed. The system allows reports to be submitted completely anonymously if desired.
• Qilimanjaro expressly prohibits any form of retaliation, discrimination or adverse consequences against individuals who report matters in good faith. This protection extends to all staff and third parties.
• The whistleblower is protected provided they act in good faith, understood as the provision of reliable information which the sender reasonably believes to be true, even if a breach cannot ultimately be proven.
• All reports are analysed by Qilimanjaro’s Compliance Unit, a collegiate body that guarantees independence, professionalism and objectivity in conducting internal investigations to clarify the facts.
• The whistleblower is entitled to receive an acknowledgement of receipt of their report and to be informed of the status and outcome of the investigation, always within the legal framework of confidentiality.

How can I report?

To ensure accessibility, the whistleblower may choose from the following channels:

• Via the following form at: https://qilimanjaro.bizneohr.com/whistleblowing-channel
• The whistleblower may request a face-to-face meeting with the Compliance Unit, which will take place within a maximum of seven days.

Without prejudice to the use of this internal channel, whistleblowers may approach the competent authorities via the Spanish Independent Whistleblower Protection Authority (Autoridad Independiente de Protección del Informante) or the Anti-Fraud Office of Catalonia (Oficina Antifrau de Catalunya) to submit their report through these external reporting channels.

We encourage you to report any suspicions or actual misconduct via this channel.

Through this open channel, we guarantee your anonymity when submitting a report regarding misconduct and throughout the entire process of your case.

Your report must contain the following information:

• The type of misconduct or illegal behaviour you wish to report.
• Identification of the possible perpetrators
• The location where it occurred.
• When it occurred. Please state the time, date and whether it is a recurring incident.
• Any documentation to which you have had access. If you do not have access to the documentation but know that it exists, please include the type of documentation and where it can be found.
• Details of any other action you have taken in relation to the misconduct.

Note: It is important to read the content of the Data Privacy link before submitting a report. You should not submit personal data that is not clearly relevant to the report. If you submit this type of information, we may remove it without informing you.

Types of reports: The following types of conduct, amongst others, can be reported via this channel:

1. Fraud, corruption or bribery
2. Workplace or sexual harassment.
3. Discrimination on the grounds of gender, race, religion, sexual orientation or disability, amongst others.
4. Breaches of privacy and data protection
5. Any other behaviour that breaches the law or Qilimanjaro’s ethical principles

Anonymity

You are not required to provide personal information. The tool allows you to submit a report anonymously, so you can remain anonymous. If you voluntarily provide your details, they will be treated with absolute confidentiality.

See Qilimanjaro’s whistleblowing channel management policy and procedure