Ethics and transparency

Right to anonymity

The Ethics and Compliance Channel allows both written and oral reports to be made anonymously. However, Repsol encourages reporters to identify themselves wherever possible, as this facilitates the processing of messages.

General commitment of confidentiality

Anyone participating in the processing of a report received or in any ensuing investigation, whether directly or indirectly, must observe strict rules of confidentiality regarding the information disclosed to them.

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 circumstances may any information that could lead to the identification of any of the persons involved in a report or investigation of such report be shared with anyone outside the reception and processing of a report, except where such disclosure may be required pursuant to a regulatory requirement or a legal proceeding.

Prohibition of retaliation

The reporter(s) and any persons assisting in an investigation may not be penalized or suffer any negative consequences or retaliation for this reason. 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 to them and to be heard by the investigator(s). This person also has the right to the 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 centralized channel

Repsol's Ethics and Compliance Channel is managed by an independent organization that provides reporting persons with various means of submitting reports (telephone, mail, or electronic form) regarding anything perceived to be a breach of the Company's Code of Ethics and Business Conduct or Crime Prevention Model, or of a possibly illegal act or infringement of applicable regulations. Any Repsol Group employee who receives a report regarding possible breaches that fall under the scope of the internal information system must immediately send it to the Ethics and Compliance Committee through the Ethics and Compliance Channel. Failure to meet these obligations by the recipient of any such report will be considered an extremely grave infraction.

System manager

The Ethics and Compliance Committee is the organizational body responsible for Repsol's reporting system. Its management duties and responsibilities are deposited the Company's Chief Compliance Officer.