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NTT DATA EMEAL Group Whistleblowing SystemYour collaboration is highly appreciated

As a worldwide company, part of NTT DATA Group, we advocate compliance with all international and national laws and regulations in those jurisdictions in which we conduct our activities. Also, we keep in its development a behavior and an attitude in accordance with our company Values, so that the achievement of our Vision is carried out through proper and honest practices in which we apply same Business Ethics and Compliance standards.

For this purpose and taking into consideration our Code of Ethics and Professional Conduct (which includes the NTT DATA Global Compliance Policy) and other regular communication channels internally implemented (e.g. our current internal Professional Alert System or Whistleblowing System, spontaneous communications to the Compliance Committee or to Managers, Directors and Partners), we have decided to intensify said communication channels by implementing this global and external System. This System also extends to the NTT DATA Europe and Latin-America Foundation (hereinafter “NTT DATA EMEAL Foundation”), part of the NTT DATA EMEAL Group.

The information that is to be obtained through this external channel will help the company, and its Foundation, to maintain, at a global level, the fulfillment of Compliance obligations, as well as to prevent and detect Compliance risks and, of course, to protect our appreciated reputation.

This Whistleblowing System allows you to report the following:

Any violation of our Values, behavior principles and guidelines for employees included in said Code of Ethics, as well as in our internal policies and regulations.
Any infringement of the rules, principles and guidelines of the NTT DATA EMEAL Foundation´s Code of Conduct and Good Governance.
Any breach of the legislation in force.
Any incident that may imply a risk for the company’s or the Foundation’s business and reputation.
Any other conduct considered as generating an ethical conflict.
Any other fact or circumstance that could come up in a relevant company risk.

The information communicated through this external System will be strictly kept under confidentiality and anonymity (if you agree so), maintaining its integrity and security. According to these criteria, when provided, the information is automatically encrypted and remains strictly confidential. Access to the System is only given to the law firm Cuatrecasas, who is linked to the commitment of professional secrecy and who is the external provider that independently and exclusively collaborates in the System management.

Likewise, we agree not to take any form of retaliation, directly or indirectly, against professionals who report communication through this external System, who will have our complete support, except in cases of false accusation.

The present Whistleblowing System may be used by all NTT DATA EMEAL Group and NTT DATA EMEAL Foundation professionals, as well as by any third party maintaining any interest or interacting with our Group or the Foundation, on behalf of it or as its representatives (customers, suppliers, agents, other related third parties, etc.).