RULES OF USE OF ETHICAL CHANNEL

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1. INTRODUCTION

Glovoapp23, S.L. holder of VAT number B-66362906 (hereinafter, Glovo) has created this Ethical Channel in order to receive and manage communications related to:

• Violations of applicable legislation, the Code of Ethics or the remaining Glovo internal regulation.
• Answer enquiries about the Code of Ethics or internal regulations.

Glovo's Ethical Channel complies with the provisions set out in the Organic Law 03/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights and is aligned with Directive (EU) 2019/1937 of the Parliament Council and Council of October 23, 2019, on the protection of persons who report infringements of Union law.

The following rules of use regulate the management of the Glovo Ethics Channel in accordance with the provisions of the Glovo Code of Ethics and the Policy for whistleblowing.

2. SCOPE

At all levels of Glovo, there is an obligation to collaborate in raising awareness of the zero-tolerance policy adopted by Glovo towards law infringement, violation of the Code of Ethics and of the its internal regulations, which is why you should pay attention to any risk or non-compliance behaviour that may be detected. Said risk or non-compliance behaviour shall be immediately reported through this Ethical Channel upon detection.

The Ethical Channel will constitute reporting channel for any employee, collaborator, client or supplier who is aware of any type of behavior that is contrary to the ethical principles contained in the Glovo Code of Ethics, or any type of action that involves a breach of the law and / or internal regulations.

You can also submit enquiries through the Ethics Channel about Glovo’s Code of Ethics and other internal Glovo regulations.

3. USE OF THE CHANNEL

Glovo's Ethical Channel allows you to provide the following information through a web form:

3.1. To make reports:

Identification and contact data: necessary data to identify and contact the whistleblower in case it is necessary for collecting additional information. However, the whistleblower can choose not to submit said data directly to Glovo or to remain anonymous by leaving the following form fields blank:

• Name (except in case the whistleblower chooses to report through anonymous methods, which requires the inclusion of a pseudonym in the field “Name”):
• Email
• Phone number

Mandatory information: this is the information that the whistleblower shall provide in the form. Basically, it is about describing the facts that presumably constitute an infringement of the Code of Ethics or of Glovo's internal or external regulations, and the company where the facts allegedly occurred. The boxes on the form are as follows:

• Company to which the communication refers
• Non-compliance or risk of non-compliance that you want to communicate

Finally, the whistleblower may attach the documentation deemed necessary to provide evidence of the reported facts.

Upon duly completion of the aforementioned steps, the whistleblower will be required to accept these "Rules of Use" as well as the "Privacy Policy" of the Ethical Channel in order to complete the form and send it for processing.

3.2. To make enquiries:

In the event that you wish to raise a question, it is necessary that you identify yourself in order for Glovo to address the query, so it is mandatory to complete both sections described above ("Identification and contact data" and "Mandatory information"). In the event that you do not provide your data, no answer will be provided to your enquiry due to impossibility

4. CHANNEL MANAGEMENT

The HQ Compliance Committee is responsible for managing the Ethical Channel and answering the submitted enquiries, notwithstanding the fact that the HQ Compliance Committee has currently outsourced the management of the Ethical Channel to the law firm Ribas.

Once a communication is received in the Ethics Channel, the external manager will carry out an initial evaluation of the fundamentals of the communication and will forward it to the HQ Compliance Committee to begin processing it. In the event that the complaint is about a member of the HQ Compliance Committee, it will be forwarded to another member of the Committee to proceed with processing.

The members of the HQ Compliance Committee will analyze and resolve the complaints and enquiries received, giving them the treatment they deem most appropriate in each case. They will act in each intervention with total independence and full respect for the people affected and will guarantee, at all times, confidentiality in the treatment of the complaints they process.

In the event that the type of communication received does not fit within the Ethical Channel nor does there exist a specific channel for its management, it will be sent to the competent department or area, in order for it to be managed by it, or it will be filed if it will be appreciated that it is a vain, trivial or inconsequential communication.

5. RESPONSE PERIODS

The communication will receive an acknowledgment of receipt as soon as it has been registered in the Ethical Channel. Once it was resolved, or within a maximum period of 3 months, the communicator will receive a response from the HQ Compliance Committee.

6. GUARANTEES OF THE ETHICAL CHANNEL

All communications received through the Ethical Channel will be governed by the following guarantees:

• Security measures: the Ethics Channel will have the appropriate technical and organizational security measures to avoid the risk of disclosure, unavailability and loss or destruction of information, that is, the confidentiality, availability and integrity of the communications received will be guaranteed.
• Confidentiality: the confidentiality of the identity of the whistleblower and of any third party mentioned in the communication, as well as the facts mentioned, will be guaranteed, with only authorized personnel having access to the communication.
• Privacy: the processing of personal data will be carried out in accordance with current applicable legislation on data protection.
• Diligent and motivated response: communications will be answered respecting the established deadlines and will always be sufficiently motivated by responding to the different questions raised.
• Regarding the rights of the complainant: the rights of the whistleblower will be respected, especially the absence of reprisals against complainants in good faith.
• Rights of the accused: the rights of the person concerned will be respected, especially the presumption of innocence.

7. FALSE REPORTS

A false report will be understood as a report made knowing that it is not true or is misleading.

In the event that a false report is detected, the corresponding measures established by current legislation, collective agreement or applicable internal regulations will be adopted against the whistleblower.