Compliance

Code of Conduct

1. Introduction

This document sets out the body of rules and general principles of corporate governance and professional conduct applicable to all employees, collaborators, suppliers, and clients forming part of L35 ARCHITECTS, with the aim of fostering a generalized culture of compliance within the scope of its activities.

One of the objectives established by L35 ARCHITECTS is the definition and development of specific actions intended to improve the quality of its services and to enhance transparency and trust vis-à-vis all its stakeholders. To this end, the Company has approved this Code of Conduct, which generally defines its framework of relations.

L35 ARCHITECTS carries out the functions described in its Articles of Association based on the following:

Mission: A company founded, from its inception, on the idea that architecture is a service to the community, and that the profession constitutes a collective endeavor rather than an individual mission.
Vision: To pursue excellence in design through creative freedom and diversity, by developing the profession as a team and incorporating the skills and experience of all its members.
Values: The principles and values of L35 ARCHITECTS are to promote the human, professional, and personal development of all collaborators, based on individual freedom and responsibility, and to conceive architecture as an art, an indispensable contribution to culture.

2. Individuals, Groups, and Institutions

The categories of individuals, groups, or institutions that participate and whose contribution is necessary to fulfill the mission of L35 ARQUITECTOS include, among others, the shareholders of the Company, clients, suppliers, employees, public authorities, and the local, regional, and national communities in which the Company operates or may operate.

We propose and promote ethical conduct that fosters a relationship of trust between the Company and the involved stakeholders. Those of us who make up this organization consider good reputation to be an essential intangible asset that enhances both our internal and external relationships with all parties with whom we interact.

3. Pillars of the Code of Conduct

In particular, and among all corporate principles and values of the Company, this Code is built upon the following fundamental pillars:

The ethical structural principles, which shall govern any business conduct or action, in general terms, with respect to all economic and social stakeholders with whom trust is to be generated.
The standards of conduct applicable to collaborators of L35 ARCHITECTS, specifically with respect to each category of economic and social stakeholders with whom the Company interacts in the course of its business activity, including shareholders, clients, suppliers, employees, social agents, public authorities, and competitors.
The implementation mechanisms designed to establish control systems for the compliance with and corporate development of the Code of Conduct and all ethical structural principles and standards of conduct contained therein.

4. Addressees

This Code of Conduct is addressed to all members of L35 ARCHITECTS, regardless of their position or status within the organization, and is binding upon all of them—from partners to internal collaborators—as ethical conduct is the responsibility of each and every one.

L35 ARCHITECTS shall promote that all companies in which it holds an interest, associated firms and/or internal collaborators, as well as its principal suppliers and external collaborators, adopt conduct consistent with the ethical structural principles set forth in this Code.

Likewise, and taking into account that L35 ARCHITECTS carries out some of its projects in countries such as Turkey, Chile, Brazil or France, this Code of Conduct shall be valid both in Spain and abroad, always taking into consideration the cultural, linguistic, social and economic differences of the various countries in which L35 ARCHITECTS carries out its activity, as well as the legal regulations applicable in each of them.

5. Ethical structural principles

5.1. Our strict compliance with legality and human rights

All professionals of L35 ARCHITECTS shall maintain strict respect for the applicable legal system in all territories in which they carry out their activities, including any regulations applicable in the corresponding Autonomous Communities or Municipalities where the activity is carried out.

L35 ARCHITECTS ensures compliance with the conditions contained in current legislation.

This commitment is likewise extended to professionals of companies in which L35 ARCHITECTS holds a participation, as well as to collaborating studios in other countries.

In accordance with the above, all actions of the Company and of the persons who comprise it shall scrupulously respect the laws, human rights and public freedoms and shall adopt all measures that guarantee respect for fundamental rights, the principles of equal treatment and non-discrimination, protection against child labor exploitation, and any other principles set forth in the Universal Declaration of Human Rights and in the United Nations Global Compact regarding human rights, labor rights, environmental matters and the fight against corruption.

Within the scope of its professional activity, any entity or person collaborating or maintaining relations with the Company shall diligently respect the applicable legal system, the Code of Conduct and the internal regulations of the Company.

5.2. Involvement of our shareholders

L35 ARCHITECTS assumes the firm commitment to create and promote the necessary conditions to guarantee the participation of shareholders in decisions within their competence, guaranteeing equal access to information and likewise safeguarding the interest of the Company and of all shareholders against initiatives not governed by the principles of transparency and fairness.

5.3. Quality and excellence as our fundamental pillar

L35 ARCHITECTS directs its own activity toward satisfying and protecting its clients, addressing all requests that may favor the improvement of the quality of the services provided. For this reason, L35 ARCHITECTS directs its activities toward achieving excellent quality standards in its services.

As has been upheld since the origin of the Company, “Giving more than what is necessary is seeking excellence, and in that sense is demanding more than what is indispensable,” this being one of the basic principles to be followed in the operation of L35 ARCHITECTS.

5.4. The reputation and prestige of the Company as a letter of introduction

L35 ARCHITECTS has a solid reputation thanks to its extensive experience of more than 50 years and to a human team that is solvent, loyal and committed to the values and know-how that make up the culture of the Company.

Each and every one of its professionals shall participate in the task of strengthening the prestige of L35 ARCHITECTS and of safeguarding its reputation.

L35 ARCHITECTS shall always ensure the maintenance of the values of the Company.

In particular, L35 ARCHITECTS has a supervisory committee, which shall ensure the maintenance of the values of the Company, the mission and professional strategies, as well as the supervision of the functioning of the departments in accordance with the Company’s organizational chart.

5.5. Protection and promotion of our human resources

The people of L35 ARCHITECTS are an indispensable factor for its success. The Company promotes the professional development of its members, taking into account the possible balance between objectives, needs and expectations of employees. Likewise, the Company promotes the permanent adaptation and improvement of the competencies and capacities of the entire organization.

Such is the importance that L35 ARCHITECTS attributes to the human factor, that the personnel dependent on the Company are considered, for all purposes, as internal collaborators, regardless of the designation granted to them in this Code of Conduct or in other documents related to the current Crime Prevention Plan.

L35 ARCHITECTS considers that safety is an individual responsibility and a basic condition of employment, which is why it will not allow unsafe behaviors that may cause serious damage to people and/or facilities. For this reason, Occupational Risk Prevention is a priority chapter for L35 ARCHITECTS, and it already has a Prevention Program with the purpose of eliminating or reducing occupational risks for all persons who carry out their professional performance in the Company, as well as in the projects in which L35 ARCHITECTS participates.

5.6. Prevention against money laundering and irregular payments

L35 ARCHITECTS has policies to prevent and avoid, in the course of its activities, the carrying out of irregular payments or money laundering originating from illicit or criminal activities, materialized in a Money Laundering Prevention Manual.

In application of said Manual, the members of L35 ARCHITECTS shall remain alert to those cases in which there may be indications of lack of integrity of the persons or entities with which the Company maintains relations, reviewing with special attention extraordinary payments not foreseen in the corresponding agreements or contracts.

5.7. Respect for the culture and customs of countries

L35 ARCHITECTS considers diversity as something clearly positive and understands that the cultural and customary differences that exist in the different countries of the world in which it is present must always be deserving of profound respect by those who form part of the Company.

The relations of the Persons Subject to this Code of Conduct with people from other countries must always be free of prejudice, governed by tolerance and must respond to positive attitudes, with recognition of the values of other cultures, respect for their traditions and customs and, ultimately, favoring cordial and respectful understanding with the world.

5.8. Respect and commitment of the Company to the community and the environment

Among its objectives, L35 ARCHITECTS seeks to obtain a certain profitability while generating quality employment and producing benefits for society and its environment in general, which implies a way of doing business that does not involve questionable practices nor taking excessive risks that may jeopardize the continuity of the business and the jobs generated.

L35 ARCHITECTS is firmly committed to the protection and respect of the environment and therefore carries out its activity under the premise of minimizing negative environmental impacts and preventing pollution, promoting research, development and innovation that improve productive processes and seeking the training of its employees and professionals on proper environmental management and optimal management of natural heritage.

5.9. Confidentiality and transparency in all Company relations

Information is one of the main assets of L35 ARCHITECTS for the management of its activities.

All professionals of L35 ARCHITECTS shall use this resource with the utmost caution, preserving its integrity, confidentiality and availability and minimizing the risks arising from its disclosure and misuse both internally and externally.

Does it respect the confidential nature of information at work?

L35 ARCHITECTS undertakes to transmit information about the companies that comprise it in a complete and truthful manner, allowing shareholders, analysts and the remaining stakeholders to form an objective judgment about it.

6. Criteria of conduct

The specific criteria of conduct shall be inspired and applied in accordance with the strictest compliance with the legal system, which shall in all cases govern their application, and shall be mainly oriented towards the following objectives:

The involvement of our shareholders, internal and external collaborators.
Quality and excellence in service in order to obtain the loyalty of our Clients.
The reputation and prestige that we must convey to our suppliers and business collaborators.
Promotion and protection of all workers.
Compliance with the strictest legality in relation to public bodies.
Respect and commitment to the community and the environment.

6.1. Relationship with shareholders

Creation of value for our shareholders.
Obtaining a return on our shareholders’ investments and the continuous maximization of value for them is a fundamental objective of our organization and, to this end, the business and financial strategies of L35 ARCHITECTS are determined, reviewed and adopted, maintaining the necessary balance and equilibrium with the objectives of all the persons who form part of it.

In any case, the maximization of the value of L35 ARCHITECTS, in the interest of shareholders, must necessarily be carried out in compliance with the requirements imposed by Law, performing in good faith the contracts entered into with workers, suppliers and clients and, in general, observing those ethical principles and criteria of conduct provided for in this Code of Conduct.

Truthful information.
The information transmitted to shareholders shall be truthful, complete and up to date and shall adequately reflect the situation of the company. This principle shall be complied with in an especially scrupulous manner with regard to financial information.

L35 ARCHITECTS provides all the information and documentation necessary so that shareholders’ decision-making may be based on knowledge and understanding of business strategies and management development and may serve to obtain the expected return on the invested capital.

6.2. Relations with clients

Honesty and professional responsibility.
Any relationship with our clients must comply with a high level of commitment to honesty and professional responsibility, in addition to respecting the regulations applicable to relations with our clients.

Therefore, commitments undertaken with clients must be respected, giving due advance notice of any change, modification, alteration or variation in verbal and written agreements, promoting transparency in the relationships of our organization and acting with integrity in all professional dealings with our clients.

Likewise, L35 ARCHITECTS shall require its clients to behave in accordance with business ethics, terminating any commercial or mercantile relationship with those who do not maintain acceptable corporate ethics or who assume as their own business practices of dubious legality.

Contracts and promotional activity with clients.
Contracts and promotional activity with clients of L35 ARCHITECTS must be clear and direct, in accordance with current regulations, so that our clients have all relevant information for decision-making.

L35 ARCHITECTS undertakes not to use misleading or false advertising instruments. Marketing activity shall be carried out by providing all relevant information to our clients for appropriate decision-making.

Confidentiality and privacy.
Sensitive information relating to our clients must be treated with absolute discretion and confidentiality and may only be disclosed to its legitimate holders or under official request, always with the appropriate legal guarantees.

Commercial dealings with clients must be carried out, when appropriate, in an environment that can guarantee the privacy and confidentiality of conversations, negotiations and documentation used.

Conflicts of interest.

Is there a conflict of interest?

Can my interests interfere with those of the company?

Any economic, family, friendship or other type of relationship of our professionals with clients may affect independence in decision-making and could represent a potential risk of disloyal conduct due to a conflict between personal interests and those of L35 ARCHITECTS.

Consequently, when such circumstances arise, they must be brought to the attention of the Compliance Committee, the body responsible for the review, updating and continuous compliance with the Crime Prevention Plan.

In particular, a conflict of interest shall be understood to exist when there is a direct or indirect collision between the interest of the company and the personal interest of any professional of L35 ARCHITECTS, as defined above, or of any person related thereto.

Therefore, behaviors that compromise the independence of L35 ARCHITECTS or of its clients in decision-making must not be accepted as a general rule.

Gifts, presents and favors.
L35 ARCHITECTS shall not give or accept any type of gift or present that may be interpreted as exceeding normal commercial or courtesy practices.

How should I act in the event of offers of advantages and/or gifts?

In particular, any form of gifts, presents or favors to clients that may influence their independence in decision-making, or that may induce the granting of any type of favor by L35 ARCHITECTS or its employees and executives, is prohibited.

Thus, any gift from L35 ARCHITECTS shall be characterized by having only symbolic value and by being intended to promote its brand image. Any gift offered for this purpose must be managed and authorized in accordance with corporate protocols.

Complaints management.

Any claim or complaint shall be welcomed by our organization, as it will help us realign our course toward excellence and professionalism in our services and products.

For this reason, the professionals of L35 ARCHITECTS undertake to receive, respond to, channel and, where appropriate, resolve any claim or complaint raised by our clients.

Business opportunities.
No professional of L35 ARCHITECTS may use the Company’s name or invoke their professional status to carry out transactions on their own behalf or on behalf of related persons.

6.3. Relations with suppliers and other collaborators

Mutually beneficial relationships.
L35 ARCHITECTS considers its suppliers and collaborators to be a fundamental part of achieving its objectives and seeks to establish mutually beneficial relationships that allow for a balanced distribution of benefits in both the short and long term.

Compliance with legislation and social values of suppliers.
Relationships shall be maintained only with suppliers who conduct their activities in compliance with applicable regulations and who meet minimum requirements, particularly with regard to their employees’ working conditions, respect for Human Rights, and compliance with quality standards that ensure product safety.

L35 ARCHITECTS shall require its suppliers and subcontractors to provide a declaration clearly identifying the good or service supplied, stating that the production or provision process has been carried out in accordance with the regulations of the country of origin, and confirming their willingness to allow verification of compliance. In cases where the legislation of the country in which the supplier operates does not meet the minimum standards required under applicable international agreements, such agreements shall be adopted as the minimum acceptable standard.

Gifts, gratuities, and favors.
The prohibition on offering or accepting gifts previously established shall also apply to relationships between L35 ARCHITECTS and its suppliers and collaborators. This prohibition shall apply equally to all professionals and employees of L35 ARCHITECTS. Purchasing departments shall exercise particular care to avoid such practices.

6.4. Human resources

Recruitment and professional promotion.
L35 ARCHITECTS avoids any form of discrimination with respect to its collaborators.

In the context of people management and development processes, as well as during recruitment and promotion phases, decisions are based on the suitability of professional profiles and on merit-based considerations.

Access to positions and responsibilities is likewise determined based on competencies and capabilities.

Training.
L35 ARCHITECTS provides all employees with informational and training tools aimed at assessing their specific competencies and enhancing their professional development.

Training responds to objectively identified organizational needs and takes into account the professional growth of individuals.

Gender equality.
Professionals of L35 ARCHITECTS shall respect the right to equal treatment and equal opportunities between women and men.

In general, they shall actively promote the absence of any form of direct or indirect discrimination on the grounds of sex and shall uphold and effectively apply the principle of equality between women and men in the workplace, advancing measures that facilitate the reconciliation of work and family life.

The principle of equal treatment and equal opportunities between women and men shall be guaranteed in access to employment, vocational training, professional promotion, and working conditions.

L35 ARCHITECTS shall adopt appropriate measures and decisions in response to any conduct that constitutes or results in discrimination on the grounds of sex.

Occupational health and safety.
L35 ARCHITECTS declares its firm commitment to maintaining and developing its Occupational Risk Prevention system, assuming the protection of employees as its primary objective in this area and promoting the integration of prevention at all levels.

To this end, L35 ARCHITECTS shall adopt the necessary measures to eliminate or reduce risks, ensure compliance with applicable legal requirements, promote employee consultation and participation, and raise awareness among all employees regarding risk prevention.

Moral integrity.
L35 ARCHITECTS undertakes to safeguard the moral integrity of its professionals by guaranteeing the right to working conditions that respect human dignity. To this end, it protects employees against acts of psychological violence and combats any discriminatory or harmful attitude or behavior affecting individuals, their convictions, or their preferences.

The necessary measures shall be adopted to prevent and, where appropriate, remedy sexual harassment, workplace harassment (mobbing), and any other form of violence or discrimination, avoiding among all professionals of the Company any behavior or discourse that may harm personal sensitivity.

6.5. Relations with Public Administrations and public-sector organizations

Legality and integrity in our relations with public bodies.
The principle that shall at all times govern the relations between L35 ARCHITECTS and the public bodies, authorities, and officials with whom it interacts shall be that of the strictest compliance with the applicable legal framework.

In particular, with regard to the obligations assumed by L35 ARCHITECTS vis-à-vis Public Administrations, special attention shall be paid to the strict compliance with the various applicable regulations, especially those relating to training subsidies, as well as tax, social security, and anti-money laundering regulations, where applicable.

Gifts, gratuities, and favors.
The prohibitions set forth in the relevant section regarding gifts, gratuities, and favors to clients shall apply equally to the relationship between L35 ARCHITECTS and Public Administrations and sector organizations, with even greater rigor where appropriate.

6.6. Relations with the Community and the environment

L35 ARCHITECTS maintains environmental policies and a sustainable commercial and industrial development strategy, in accordance with current environmental legislation.

The environmental policy of L35 ARCHITECTS is also supported by the awareness that respect for the environment may represent a competitive advantage in an increasingly broad and demanding market in terms of quality standards and responsible conduct.

Ethics Channel

What is the Ethics Channel?

The Ethics Channel is a communication tool that enables the prevention, detection, investigation, and resolution of any situation involving non-compliance with legislation, the Code of Ethics, or the internal regulations of L35 ARCHITECTS, through the reporting by employees and/or third parties of risk situations and/or suspected breaches.

Our Ethics Channel is available to all employees, collaborators, and other third parties linked to the entity, and is configured as an opportunity for improvement, a tool for active and responsible participation that strengthens the culture of integrity, compliance, and transparency we uphold.

Reporting a suspicion or risk through the Ethics Channel is not reporting misconduct, but collaborating. Each communication represents an opportunity to improve, reinforce our culture of integrity, and protect the interests of L35 ARCHITECTS and all its members.

Why is it necessary?

The implementation of the Ethics Channel at L35 ARCHITECTS responds, firstly, to compliance with current regulations regarding the protection of whistleblowers. Directive (EU) 2019/1937 of 23 October establishes the obligation for public and private entities to have appropriate channels in place so that any person may confidentially or anonymously report breaches of European Union law, as well as actions or omissions that may constitute a criminal offence or a serious or very serious administrative offence. This Directive required transposition into national legislation, which in Spain was implemented through Law 2/2023 of 20 February, regulating the protection of persons who report regulatory breaches and combating corruption.

However, at L35 ARCHITECTS we do not limit ourselves to complying with such legal obligations, but rather act on the conviction that the communication of risks is one of the most valuable tools available to reinforce our institutional culture, promote continuous improvement, and preserve the trust of all our members, collaborators, and society at large.

The aforementioned Law 2/2023 constitutes the first general regulatory framework in Spain that systematically regulates the protection of persons reporting regulatory breaches. One of its fundamental pillars is the protection of the rights of the persons involved, particularly the rights of defence, presumption of innocence, and privacy of those concerned, while also guaranteeing the absence of retaliation against those who report in good faith.

Ethics Channel and Internal Information System

The commitment of L35 ARCHITECTS goes beyond merely enabling an Ethics Channel. Therefore, and in compliance with the provisions of Law 2/2023, we have implemented an internal information system, within which our Ethics Channel is integrated. In addition to fulfilling legal obligations regarding the receipt, processing, and investigation of communications, the internal information system develops its own management model that reinforces transparency, institutional integrity, and continuous improvement.

While the Ethics Channel constitutes the means by which any person may inform the entity of risk alerts or suspicions, the internal information system is the complete structure that enables the orderly, rigorous, and safeguarded management of all communications received.

OUR INTERNAL INFORMATION SYSTEM INCLUDES:

A Head of the Internal Information System, formally and specifically appointed to manage the communications received in accordance with the principles of independence, confidentiality, and diligence. The Head performs their duties independently and autonomously from the rest of the bodies of L35 ARCHITECTS, without receiving instructions of any kind.
A protocol for the reception, registration, and classification of communications.
The possibility of imposing disciplinary measures if the reported non-compliance is confirmed.
A procedure for internal investigation, rigorous and impartial with respect to the facts reported.
A procedure for preliminary assessment, determining whether the communication should be admitted or archived.

The procedures that make up our Internal Information System are developed in accordance with the guiding principles established by current regulations and adopted by L35 ARCHITECTS:

Confidentiality, both of the identity of the informant and of any person involved, as well as of the content and development of the procedure.
Integrity and traceability, through the recording and monitoring of all actions carried out.
Diligence and promptness, respecting deadlines and avoiding undue delays.
Impartiality and independence, especially in the investigation and assessment of the facts.
Protection against retaliation, guaranteeing a safe environment for those who report in good faith.
Respect for the rights of the parties, including the presumption of innocence, the right of defence, and the protection of personal data.

In this way, L35 ARCHITECTS demonstrates its intention to have a system that is not only legally valid, but also truly useful, robust, and aligned with the ethical values that must guide the actions of any professional organisation.

Our Ethics Channel: Procedure and Characteristics

The Ethics Channel of L35 ARCHITECTS is permanently accessible through the corporate website, and its use is simple and secure.

Go to L35 Ethics Channel

Our Ethics Channel has been designed to ensure clear and efficient communication, while maintaining at all times guarantees of confidentiality, integrity, and respect for the rights of all persons involved.

The use of the Ethics Channel is intuitive and guided step by step, with clearly visible instructions.

To submit a new communication, the informant must complete a written form in which they may describe the facts, provide documentation if desired, and select the preferred method of communication:

Anonymously, without providing personal data.
Confidentially, indicating their identity, which will be treated with absolute discretion.

It is recommended to describe the facts in as much detail as possible, in a concrete and objective manner, in order to facilitate their analysis and, where appropriate, subsequent investigation.

At the request of the informant, the communication may also be made through a face-to-face meeting with the Head of the Internal Information System and/or their external advisors within a maximum period of 7 days from the request. The meeting will be documented through a secure, durable, and accessible recording. Prior to this, the informant will be informed that the communication will be recorded and that their data will be processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.

CONSULTATION AND FOLLOW-UP OF THE COMMUNICATION

When submitting a written communication through the Ethics Channel form, the system will automatically generate a unique reference number. This number will be provided to the informant at the time of submission and must be kept in order to:

Access the acknowledgement of receipt of the communication.
Check at any time the status of the communication and whether it is in process or completed.
Access, once the procedure has been completed, the final resolution or closure report when it has been uploaded to the platform.

However, when submitting the communication, the informant may indicate an email address to receive notifications, expressly stating their wish to be notified through this channel.

HOW DO WE PROCEED AFTER RECEIVING A COMMUNICATION?

ACKNOWLEDGEMENT OF RECEIPT
Within a maximum period of seven calendar days, acknowledgement of receipt of the communication will be provided to the informant through the platform or via the email address expressly provided for this purpose, unless this could compromise the confidentiality of the communication.
PRELIMINARY ANALYSIS AND ADMISSIBILITY
The Head of the Internal Information System will analyse the communication to determine whether it should be processed or archived, based on its content and compliance with legal requirements. Only communications that report facts or conduct falling within the scope established by Law 2/2023 and the internal policies of L35 ARCHITECTS will be admitted. The communication will be deemed inadmissible and will be archived in the following cases:

1.When the facts reported lack credibility.
2.When the reported facts do not constitute any of the infringements included within the scope of Law 2/2023 or do not represent any breach of the internal regulations of L35 ARCHITECTS.
3. When the communication is manifestly unfounded. The decision of inadmissibility will be communicated to the informant within a maximum period of 10 working days from the date of the acknowledgement of receipt, by means of a reasoned report.
INTERNAL INVESTIGATION AND INFORMATION FILE
If it is determined that the reported facts may constitute any of the infringements or breaches included within the scope of the Ethics Channel, in accordance with Article 2 of Law 2/2023 or contrary to the regulations of L35 ARCHITECTS, the Head of the Internal Information System will inform the informant of the admission of the communication for processing and will notify the Compliance Body. The Compliance Body will inform the Administrator and an information file will be opened, within which a confidential, impartial, and diligent investigation will be carried out, in accordance with the principles of the system and guaranteeing the rights of all parties. At this stage:

1. The Compliance Body may request collaboration from other areas of the company or resort to independent third parties, if deemed necessary.
2. All evidence considered useful and relevant to clarify the facts will be examined.
3. The alleged responsible parties, those involved, and individuals with knowledge of the facts whose testimony is deemed useful and necessary will be heard.

The investigation phase will have an initial maximum duration of one month, extendable for justified reasons. In any case, the procedure must be resolved within a maximum total period of three months from the receipt of the communication, in accordance with Article 9 of Law 2/2023.

The Head of the Internal Information System will ensure compliance with the established deadlines, guarantee the confidentiality of informants and other involved parties, protect their data, and ensure the diligent handling of the procedure through access controls, traceability of actions, secure storage of documentation, and the application of appropriate technical and organisational measures.
CONCLUSIONS REPORT
Once the investigation has been completed, the Compliance Body will prepare a conclusions report which shall include, at a minimum:

1. An assessment of the facts, specifying whether or not they constitute an infringement or breach, based on an analysis of the evidence gathered.
2. The measures proposed to be adopted, which may be corrective or disciplinary, or, alternatively, a proposal to archive the case.
3. Recommendations for resolution.
4. Where the adoption of internal measures is appropriate, access to the collected information will be granted to the personnel responsible within the Human Resources Department and/or any other departments that may be competent.
RESOLUTION
The conclusions report will be submitted to the Administrator who, after assessing the outcome of the investigation, will proceed in one of the following ways:

1. To order the closure of the file, if it is considered that the reported facts do not constitute a criminal offence, do not breach internal regulations, nor infringe applicable regulations as provided for in Article 2 of Law 2/2023.
2. To adopt the corrective or disciplinary measures deemed appropriate, taking into account the recommendations set out in the conclusions report of the Compliance Body, and, where appropriate, to initiate the corresponding disciplinary proceedings against the alleged offender, in accordance with the provisions of the Disciplinary System of L35 ARCHITECTS.
COMMUNICATION OF THE RESOLUTION TO THE INFORMANT
The conclusions report will be made available to the informant, who may access it through the Ethics Channel using the unique reference number assigned to the communication, unless they have expressly requested to be notified by email.

EXTERNAL REPORTING CHANNEL

The reporting person may also report any acts or omissions falling within the scope of Law 2/2023 to the Independent Whistleblower Protection Authority, either directly through its designated external reporting channel or following prior communication through the internal channel established by L35 ARCHITECTS.

OUR ETHICS CHANNEL: SECURE AND SAFEGUARDING

The Ethics Channel of L35 ARCHITECTS operates in accordance with the key principles established by applicable legislation, which govern the entire system, ensure its legitimacy and effectiveness, and reflect best practices in compliance and ethical governance, guaranteeing:

CONFIDENTIALITY

L35 ARCHITECTS guarantees, at all times, the confidentiality of the identity of the reporting person, as well as that of any third parties mentioned in the report and any other individuals involved. Access to such information shall be restricted solely to those persons strictly authorised to manage the system, and always in accordance with applicable data protection regulations.

Even in cases where the reporting person discloses their identity, it shall be preserved with the utmost level of confidentiality. Anonymous reporting is also permitted, without this affecting the handling of the report.

FUNCTIONAL AND OPERATIONAL INDEPENDENCE

The Channel operates independently from other systems or areas within L35 ARCHITECTS. Its management is entrusted to a System Manager with specific competencies and functional autonomy, responsible for ensuring that the established procedure is conducted in accordance with the principles of impartiality and objectivity.

PROTECTION AGAINST RETALIATION

L35 ARCHITECTS has adopted a firm and explicit zero-tolerance policy towards any form of retaliation. Effective protection is guaranteed for those who report in good faith, whether identified or anonymous, and mechanisms are in place to prevent, detect and sanction any actions involving intimidation, discrimination or harm resulting from the legitimate use of the Channel.

This protection also extends to those who cooperate in an internal investigation or act as witnesses to the reported facts. The protection provided by L35 ARCHITECTS applies to all individuals who report, in good faith, facts that may reasonably constitute an infringement, even if they do not possess conclusive evidence. In order to fully benefit from these guarantees, the report must relate to matters falling within the scope of the Channel, such as legal, ethical or regulatory breaches. No certainty regarding the facts is required—only a reasonable belief in their truthfulness at the time of reporting.

RIGHTS OF THE PARTIES INVOLVED

Respect for the rights of all parties involved is guaranteed at all times, in particular:

The right to information of the persons concerned, who shall be informed, at the appropriate time and without compromising the investigation, of the existence of a report in which they are mentioned.
The right of defence, including the possibility to submit evidence, present arguments and appeal internal decisions where предусмотрed by applicable regulations.
The presumption of innocence, ensuring that no person is deemed responsible until the investigation has been concluded and a reasoned decision has been issued.

All actions shall be carried out with due proportionality, without prejudice, and with full respect for the dignity, privacy and integrity of individuals.

REMEMBER: REPORTING A RISK IS A RESPONSIBLE ACT AND AN ETHICAL DUTY

HOW TO USE THE ETHICS CHANNEL PROPERLY

The Ethics Channel must be used exclusively to report facts or situations that may reasonably constitute a legal, ethical or internal breach related to L35 ARCHITECTS. It should not be used for general enquiries or personal complaints. For such purposes, the appropriate designated channels should be used.

WHAT SITUATIONS SHOULD BE REPORTED THROUGH THE ETHICS CHANNEL?

Reported situations must be directly related to the actions of employees of L35 ARCHITECTS, persons acting on its behalf or representation, and/or third-party collaborators in the course of their duties. In accordance with Law 2/2023 and the internal regulations of L35 ARCHITECTS, the Ethics Channel may be used to report facts that may constitute:

Allegedly criminal conduct, whether by action or omission.
Serious or very serious administrative offences.
Breaches of the Code of Ethics or other internal policies of L35 ARCHITECTS.
Violations of national or European Union regulations in areas such as procurement, data protection, public health, environment, security, institutional integrity, etc.
Irregular, negligent or abusive actions that may jeopardise regulatory compliance or the reputation of L35 ARCHITECTS.
Situations involving conflicts of interest.

Reporting: An opportunity for improvement

Each report received provides an opportunity to reinforce our principles, prevent irregular situations and improve our performance as an organisation. Reporting is a tool for mutual protection. Communicating a potential irregularity helps protect L35 ARCHITECTS and all its members. Thanks to such reports, it is possible to:

Identify and correct failures or weaknesses.
Prevent risks that could lead to economic, reputational or legal damage.
Protect those who act responsibly.

Our objective is not to punish, but to improve. And improvement is only possible with the participation of all those who are part of L35 ARCHITECTS.

This Ethics Channel Policy shall be communicated and made available to all employees and other persons within its scope of application through the usual communication channels of L35 ARCHITECTS. Likewise, in compliance with Article 25 of Law 2/2023, this Policy shall be accessible from the homepage of the L35 ARCHITECTS website, in a separate and easily accessible section.

This Policy shall enter into force on the date of its approval by the Governing Body and, from that moment, shall fully replace the previous version issued in February 2024, which has been reviewed and updated with the dual objective of:

Adapting to the provisions of Law 2/2023, of 20 February, on the protection of persons reporting regulatory breaches and on the fight against corruption.
Keeping the Crime Prevention Plan of L35 ARCHITECTS updated and aligned with the principles of continuous improvement, institutional responsibility and regulatory compliance.