INTERNAL INFORMATION SYSTEM
 

LENOX MERIDIAN, S.L. (hereinafter, the Entity) has implemented an Internal Information System (SIIF), which integrates the different internal information channels of the organization and is configured as a fundamental axis for fostering a culture of ethical, responsible, and sustainable action, with the duty of supervision, control, and prevention in compliance matters. The system constitutes the preferred channel and a mandatory tool for diligently channeling communications regarding infringements and normative breaches, with total protection for informants, without the risk of reprisals, and with the necessary protection measures.
The SIIF has been designed, configured, and is managed with the necessary security, confidentiality, data protection, and informant protection measures and mechanisms. For this purpose, we have the collaboration and support of the external expert BONET consulting, which provides high levels of professionalism, experience, independence, confidentiality, and compliance with the applicable regulatory framework.
Therefore, the Entity has provided the SIIF with a series of guarantees, including anonymity/anonymization, appropriate record-keeping, information preservation and non-alteration, prevention of conflicts of interest, informant protection, and prohibition of reprisals. To learn in detail about the principles of action and the fundamental guarantees that govern the Entity’s Internal Information System in accordance with the requirements imposed by the new regulations, you can view and access the General Policy of the Internal Information System.

Information Channels
The Entity has enabled different internal information channels that allow the submission of communications in written or verbal format. To this end, the Entity has the configuration, design, and support of an external expert in order to provide the highest levels of professionalism, experience, independence, confidentiality, data protection, informant protection, and other applicable areas for this type of channel. In our Policy, you can find expanded information on the technical characteristics of the channels. The channels of our SIIF are as follows:

Online/Digital Channel
The Entity makes available an online tool through which any employee or person related to the Entity can submit a written communication via the following link: https://corporate-line.com/cnormativo-lenoxmeridian
This tool has security measures that guarantee the protection of information, the identity of the informant and those affected by it, as well as the confidentiality and reservation of the entire process of managing and processing the communication.

Face-to-Face/Physical Channel
Another channel provided by the Entity for its employees and those third parties related to it is the face-to-face channel, which allows the submission of verbal communications through a face-to-face meeting or video conference.
In order to ensure compliance with the commitments and guarantees set forth in our Policy and the regulatory framework applicable to this type of communication, the Entity has entrusted this function of managing these communications to the external expert BONET consulting, to guarantee the protection of the informant’s identity both in the process of requesting a prior appointment, in the submission of a communication in face-to-face format, and in the place of its realization. BONET’s professionals are responsible for managing the requests to submit communications through this channel, as well as for collecting and preserving all the information provided in said request. As established by law, such meetings will be documented by means of an anonymized recording, with the prior consent of the informant.
To use this channel, you must request an appointment through the following contact methods:
Telephone: 911087727 / 930460116
The informant assistance hours are as follows:
Monday to Thursday from 8:30 a.m. to 2:00 p.m. and from 3:00 p.m. to 6:00 p.m.
Friday from 8:30 a.m. to 2:30 p.m.
Email: siifexterno@sistema-interno-informacion.com

In order to guarantee the necessary protection and security measures of this type of communication, communications presented directly by telephone or email will not be made or recorded. These two tools are exclusively enabled to coordinate with technical personnel the day, time, and place to carry out the communication in face-to-face format.
We appreciate your compliance with the instructions described above to access and properly use the official channels provided by the Entity for the submission of communications and the application of all our necessary security and protection mechanisms.