Additional Provision on Data Protection Policy

Data controller

Sener Grupo de Ingeniería, S.A., with Tax ID Code (NIF) A-48914113, and registered address at Calle Cervantes 8, Gexto (Las Arenas), 48930, Vizcaya, will process the personal data to manage and investigate the communications sent through the Ethics Hotline.

We also inform you that the Sener Group has a Data Protection Officer, who can be contacted at any time via the email address [email protected].

Purpose and lawfulness of processing

The management of the Ethics Hotline by Sener Grupo de Ingeniería has the objective of processing and investigating the communications made regarding breaches of the law and/or internal policies of the Sener Group and applicable legislation, as well as questions and concerns related to them.

The lawfulness of the processing is based on the following legal basis:

• Compliance with the obligations established in Law 2/2023 regulating the protection of persons reporting breaches of regulations and the fight against corruption.
• The consent granted by the informant for the processing of his or her personal data, where the informant has chosen to provide such data.

Data processed

Personal data provided through the Ethics Hotline form, such as identification and contact details of the persons identified (persons involved, witnesses or third parties and, if applicable, the informant), as well as additional data included in the communication (city, country, attached documents, etc.) will be processed by Sener Grupo de Ingeniería.

Users of the Ethics Hotline may maintain their anonymity by filling out only the required data, marked with an asterisk, necessary to investigate the reported event. Sener Grupo de Ingeniería guarantees the confidentiality and anonymity of the communications. If you want to obtain more information about the communications management, click here to view Standards for the Ethics Hotline Sener Group.

Data communications and international data transfers

he data provided will be handled and, if necessary, transferred to interested third parties, consultants or public authorities for the purposes of investigating and clarifying the reported events, to determine responsibility, implement corrective actions and, when applicable, impose applicable legal and/or disciplinary actions before the responsible entities in each case. Likewise, the data being processed may be communicated to the rest of the Sener Group companies, based on the legitimate interest in properly managing the Ethics Hotline in a coordinated manner for all the entities. Likewise, the data being processed may be communicated to the rest of the Sener Group companies, based on the legitimate interest in properly managing the Ethics Hotline in a coordinated manner for all the entities.

Personal data related to the management of the Ethics Hotine will only be transferred internationally in the case of communications related to Sener Group subsidiaries located outside the European Economic Area. In these cases, the Sener Group has adopted appropriate safeguards for the protection of personal data, in accordance with current data protection regulations.

Data conservation

The personal data processed as a result of the management of the Ethics Hotline will be kept for a period of 3 months, from the receipt of the corresponding communication.

If it is decided to open an investigation, personal data will be kept for the time necessary to carry out the relevant enquiries and, subsequently, may be duly blocked for the corresponding legal periods for the sole purpose of responding to possible claims or legal requirements.

Data protection rights

Users of the Ethics Hotline may exercise their rights of access, rectification, erasure, opposition, limitation, portability and revocation of consent by sending an email to [email protected], indicating which right they wish to exercise and proving their identity.

However, the rights of access and opposition are appropriately restricted to effectively protect the informant, the investigation itself and third parties involved.

In addition, you may contact our Data Protection Officer, at any time via email [email protected], as well as file a complaint with the Spanish Data Protection Agency.