EthicsPoint - Repsol Foundation

REPSOL FOUNDATION COMPLIANCE CHANNEL

Repsol Foundation is firmly committed to our culture of compliance and ethical integrity. We understand this to mean that individuals who report irregular or illicit conduct play an essential role in uncovering and preventing such infractions, protecting the correct and proper workings of Repsol Foundation, and generally contribute to the well-being of society as a whole. Therefore, it is of the utmost importance that reporters receive active and all-encompassing protection, without neglecting the rights of those affected by their reports or the investigations launched as a result.

Repsol's Foundation Compliance Channel and internal information system exist to ensure these needs are met in accordance with the law and in line with the following principles:

Right to anonymity The Compliance Channel accepts anonymous messages. However, Repsol Foundation encourages reporters to identify themselves wherever possible, as this facilitates the processing of messages. General guarantee of confidentiality All persons participating, either directly or indirectly, in the processing of reports received and in any ensuing investigation must observe strict rules of confidentiality regarding the information received. Confidentiality of the reporter's identity The confidentiality of all information related to the persons affected — and especially the reporter's identity should this information be disclosed — is one of our guiding principles. Under no circumstance may any information that could lead to an identification of any of the persons involved be shared with anyone outside the reception and processing of a report. Prohibition of retaliation The reporter(s) and any persons assisting in an investigation may not be penalized nor suffer negative consequences or retaliation of any kind. This guarantee can be expanded to include other persons associated to the reporter in some way or form.

Rights of persons subject to investigation A person who is under investigation has the right to be informed of the actions or omissions attributed them and to be heard by the investigator(s). This person also has the right to presumption of innocence, in addition to other rights afforded by law. Personal data protection All personal data will be processed according to applicable data protection law and pursuant to Title IV of the Whistleblower Protection Law in force in Spain. One preferential channel Repsol Foundation’s Compliance Channel is managed by an independent organization that provides reporting persons with means of submitting reports (mail, or electronic form) regarding anything perceived to be a breach of Repsol Foundation's Code or Crime Prevention Model, or of a possibly illegal act or infringement of applicable regulations. System manager The Compliance Committee is the organizational body responsible for Repsol Foundation’s reporting system. Its management duties and responsibilities are deposited the Repsol Foundation's Compliance Officer.

Repsol's Foundation Compliance Channel is a place to ask questions and raise concerns about irregularities, illicit conduct, or possible breaches of Repsol's Foundation Code of Ethics and Conduct under full confidentiality and without fear of retaliation. Messages can be sent through the channel at any time, 24 hours a day.

Report A Concern Speak up regarding actions or behaviours you believe are inconsistent with Repsol Foundation's Code Ask A Question Got a question about our Code? Ask it here Follow Up Check the status of an existing question or concern

Why should I report what I know?

Integrity, responsibility and transparency are fundamental values at Repsol Foundation. We have set ambitious goals and meet them through consistent high performance, with high ethical standards as the basis for our business all around the world. We are expected to take the time to understand the elements of our Code of Ethics and Conduct and have these as the basis for the way we work. It is also a personal responsibility to speak up about any potential breach of our Code. Every time we ask a question or raise a concern, we create an opportunity to improve. When we take action and report questionable conduct, we are protecting ourselves as well as Repsol’s Foundation reputation. Remember, an issue cannot be addressed unless it is brought to someone’s attention.
What happens after I contact the Repsol Foundation Compliance Channel?

Once you submit a question or concern via web, you will receive a report key and password which can be used to follow up on your case. Then, an electronic summary is sent to a Case Manager within Repsol Foundations´s Compliance team for review and to determine next steps.
Who else can I speak to?

Repsol Foundation encourages you to use any resources available to speak up. In addition to using the Repsol Foundation Compliance Channel, you can speak to your line manager, another member of management or a member of Compliance team.
Are reports to the Repsol Foundation Compliance Channel secure and confidential?

Repsol Foundation uses NAVEX's case management application called EthicsPoint to support the administration of the Repsol Foundation Compliance Channel. EthicsPoint is hosted on NAVEX's secure servers to prevent any possible breach in security. NAVEX makes these reports available only to specific individuals within Repsol Foundation who are responsible for evaluating the reports. Any report you make will be kept confidential to the fullest extent possible consistent with the law and good business practices.
Can I report through the Repsol Foundation Compliance Channel emergencies or customer complaints?

The Repsol Foundation Compliance Channel is not an emergency service. Please do not use this site to report events presenting an immediate threat to life or property. Reports submitted through this service may not receive an immediate response. If you require emergency assistance, please contact your public emergency services.

The Repsol Foundation Ethics & Compliance Channel is not a channel for customer complaints or inquiries.

Read Repsol Foundation’s Code

If you prefer, you may submit your communications by postal mail to the following address:
C. de Méndez Álvaro, 44, 28045 Madrid, to the attention of Repsol Foundation Compliance Officer