1. SUMMARY

AIRDNA, LLC's whistleblower system is intended to enable employees and other persons to submit anonymous reports, and to record such reports in a comprehensible process that ensures the protection of the informants. Our objective is to create an open work environment within AIRDNA, LLC, including its affiliate and subsidiary entities, to encourage anyone who is part of our organization to raise their voice on wrongdoings. This policy is also intended to ensure, from a technical and organizational perspective, that reports of violations are processed, stored, and archived with the necessary confidentiality.

2. DEFINITIONS

• Internal Information System: A management system established by AIRDNA, LLC to protect individuals who disclose administrative and criminal incidents, in accordance with applicable law.
• Informant: An individual who reports events that may involve irregularities covered by this policy.
• Internal Channel: Authorized procedures by AIRDNA, LLC to receive confidential or anonymous reports through verbal, written, or in-person communication.
• Internal Information System Manager: A designated individual or committee responsible for ensuring the system's effectiveness.
• The Organization: Refers to AIRDNA, LLC, and its affiliate and subsidiary entities.
• Business Partners: Natural persons or legal entities with a commercial relationship with AIRDNA, LLC.
• Third Party: Any person or entity independent of AIRDNA, LLC.
• Stakeholders: Individuals or entities affected by decisions or activities of AIRDNA, LLC.

3. REGULATORY FRAMEWORK

Spanish Law 2/2023, dated February 20, regulates the protection of individuals reporting regulatory violations and combating corruption, incorporating EU Directive 2019/1937 of the European Parliament and the Council, dated October 23, 2019, regarding the protection of individuals who report breaches of European Union law.

The two objectives set by the Directive are: protecting Informants and establishing a basic regulatory framework for reporting channels. AIRDNA LLC, has agreed to adopt a new mandatory policy that integrates applicable law into the Organization's internal regulatory framework. 

4. PURPOSE AND SCOPE

This policy aims to:

• Establish a mandatory Internal Information System for all members of AIRDNA, LLC.
• Provide an effective mechanism to report any misconduct affecting corporate compliance, breaches of the law, our Code of Conduct or internal policies.
• Implement effective communication channels for reporting irregularities while ensuring Informant anonymity and protection.
• Assure stakeholders that AIRDNA, LLC has effective compliance and risk mitigation measures.

This policy applies to:

• Current or former employees, directors, and officers of AIRDNA, LLC in all locations worldwide.
• Contractors, subcontractors, suppliers, consultants, and associated Business Partners.
• Volunteers, trainees, and job applicants with relevant knowledge of violations.
• Representatives and legal advisors assisting Informants.

5. EXCLUSIONS

This policy does not cover:

• Knowingly false or misleading reports based on personal disputes.
• Information obtained unlawfully.
• Other complaints or communications through internal or external reporting channels previously determined to be inadmissible.

6. FUNDAMENTAL PRINCIPLES

• Confidentiality and anonymity protection.
• Protection from retaliation or threats.
• Safeguarding legal rights of accused individuals.
• Ensuring the confidentiality of the investigation process and data protection.
• Accessibility to internal communication channels.
• Ensuring all reports are reviewed and acted upon.
• Maintaining independence of the Internal Information System.
• Disciplinary measures for non-compliance.

7. INTERNAL INFORMATION SYSTEM

The AIRDNA, LLC Internal Information System consists of:

• Internal Information System Manager: An independent internal or external individual ensuring compliance.
• General Procedure: Establishes the procedures for the operation of the Internal Information System and investigation of reports.
• Risk Assessment and Objective Planning: Identifying the areas  or activities over which the reports may occur, analyze the risk of not addressing them in an appropriate or timely manner, mitigating risks and defining measures to improve the efficacy of the Internal Information System.
• Training and Awareness: Ongoing education for employees and stakeholders.
• Internal Reporting Channels: Secure methods for submitting reports.
• Periodic Review System: Regular assessment and policy updates as may be needed over time, or in response to organizational changes.
• Disciplinary System: Enforcement of disciplinary measures for internal policy violations.

8. POLICY REVIEW AND MODIFICATION

The policy will be reviewed and modified based on:

• Significant events requiring updates.
• Regulatory changes.
• Organizational restructuring.
• Annual reviews for continued relevance.