Whistleblowing Policy

1.PURPOSE AND OBJECTIVE OF THE POLICY

The present policy aims at establishing and ensuring a comprehensive framework for the submission of reports and complaints through an independent channel protecting persons who report breaches (whistleblowers). This is based on the current institutional framework for reporting, as defined by Law 4990/2022 (Government Gazette A' 210/11.11.2022).

The objective of this policy is the management of reports and complaints, whether anonymous or not, concerning actions, omissions, or behaviors that contradict the Company's policies and procedures and may cause serious harm to its productive and commercial activities. Furthermore, they may impact its position, reputation, and credibility with partners, clients, as well as public entities involved in its business activities. The scope also includes compliance with current legislation and ethical standards.

The recent Law 4990/2022, which incorporates EU Directive 2019/1937, seeks to institutionalize an internal system allowing the timely identification of harmful behaviors. This mechanism enables the company, on the one hand, to be promptly informed about non-compliant behaviors and risks and, on the other hand, to take immediate measures to address them.

The company's internal policy focuses on creating a safe environment that allows employees, collaborators, and third parties to report confidentially or anonymously unethical or illegal behaviors. The crucial aspect for the success of this policy and the achievement of the goals of Law 4990/2022 is the protection of individuals who decide to report breaches they have become aware of. This protection is defined within the framework of the principles of accountability, transparency, social responsibility, and protection of public interest, principles that MEDICARE HELLAS consistently follows.

This policy also provides training for personnel and information for external entities collaborating with the company. The results and its interaction with other company policies may lead to the identification of needs for modification, updating, and adaptation of corporate compliance policies. This policy has been approved by the Administrative Board of MEDICARE HELLAS, ensuring high levels of ethical and professional behavior, guaranteeing zero tolerance for illegal actions, and protecting persons who report breaches.

Furthermore, Law 4990/2022 aims to provide protection to various categories of individuals, including:

Employees: Full or part-time, permanent or seasonal employees.
Non-Salaried, Self-Employed, Consultants, Home-Based Workers.
Administrative Staff and Shareholders: Including members of the administrative, managerial, or supervisory body, including non-executive members.
Volunteers and Interns: Whether paid or unpaid.
Contract Workers, Subcontractors, and Suppliers.
Former Employees and Prospective Employees.

Additionally, protection is provided to third-party legal and natural persons associated with the above, who may face retaliation in the workplace (e.g., colleagues or relatives of individuals submitting a Report).

2.BASIC DEFINITIONS

"Report or Complaint" is defined as the provision of information or clear and reasonable assessments, either orally or in writing, regarding actual or potential breaches.
"Reporting Channels" refer to the channels for submitting reports, including the methods, ways, and means that the whistleblower can use to submit the report, as well as the individual(s) to whom the report can be addressed.
"Whistleblower" refers to a natural person making an internal or external report or a public disclosure. This individual provides information about breaches acquired during their professional activities.
"Accused person" refers to the natural or legal person mentioned in the report and is directly connected to the breach. This person is identified in the report as the subject to whom the breach is attributed or is related to the person who is alleged to be responsible for the breach.
"Retaliation" pertains to any direct or indirect act or omission by the company that takes place in the workplace, causing or likely to cause unjustifiable harm to the whistleblower due to the report and not for any other reason. It includes breaches such as harassment, discriminatory treatment, negative evaluation, salary reduction, dismissal, and other burdensome practices.
"Sensitive Personal Data" includes information concerning racial or ethnic origin, political beliefs, religious or philosophical beliefs, participation in trade union organizations, processing of genetic data, biometric data for identification, health data, sexual life, and sexual orientation.
The " Reports Receiving and Monitoring Officer" (RRMO) is the individual responsible for receiving, managing, investigating, and monitoring reports.
The "Report Management Committee" (RMC) is a committee responsible for managing and investigating the report.

3.SCOPE OF THE POLICY

The established procedures determine the manner in which a report or complaint is received and assessed by personnel, shareholders, executives, members of the Management, clients, suppliers, and any third party possessing information about irregular or illegal actions related to MEDICARE HELLAS. These actions or omissions are contrary to the Company's policies and procedures, current legislation, as well as informal ethical rules.

Within the framework of this policy, employees at MEDICARE HELLAS are obligated to report or disclose serious irregularities, breaches, or punishable actions. This obligation extends to any individual associated with the company or providing services to it, whether a natural or legal person. Additionally, MEDICARE HELLAS encourages third parties associated with the company to report reprehensible behaviors or suspected incidents of illegal conduct.

Reports or disclosures, regardless of their origin, receive equal treatment and processing by the Responsible for Receiving and Monitoring Reports (RRMR) and the Company's Management.

4.SUBJECT OF REPORTS / COMPLAINTS

Under the scope of this policy, categories of irregularities and breaches must be reported, including cases outlined in Article 4 of Law 4990/2022 and Part I of its Annex. Specifically:

a) Breaches of EU law concerning the following areas:

Breaches related to sectors of public contracts.
Breaches affecting the areas of Financial Services, products, and markets, as well as the prevention of money laundering and terrorist financing.
Breaches concerning Product Safety and Compliance.
Breaches affecting Transportation Security.
Breaches in the areas of Environmental Protection.
Breaches in the fields of Radiation Protection and Nuclear Safety.
Breaches in the field of Food and Feed Safety, as well as Animal Health and Welfare.
Breaches in the field of Public Health.
Breaches in the field of Consumer Protection.
Breaches in the field of Privacy Protection and Personal Data, as well as Network and Information Systems Security.

b) Breaches affecting the Economic Interests of the Union under Article 325 of the Treaty on the Functioning of the European Union (TFEU), as specifically defined in relevant EU measures.

c) Breaches related to the internal market, as referred to in Article 26(2) of the TFEU, including violations of Union competition and state aid rules, as well as breaches concerning the internal market regarding acts that contravene rules on corporate taxation or settlements aimed at securing tax advantages that undermine the purpose or subject of the applicable corporate tax legislation.

Breaches may extend beyond the following categories:

Leakage of Confidential Information: Involves the disclosure of business secrets and plans related to the Company's strategic or general economic interests.
Criminal Activity: Includes acts related to criminal activity and breaches of criminal law.
Non-compliance with Legal or Professional Obligations or Regulatory Requirements.
Damage to the Environment: Involves acts causing environmental damage and violating environmental laws.
Bribery and Corruption: Covers cases of bribery and corruption at all levels.
Fraud, Embezzlement, Theft, Forgery.
Participation or Facilitation of Tax Evasion.
Breach of Policies and Procedures: Refers to acts that violate the Company's internal policies and procedures.
Behavior Harming Reputation or Economic Prosperity: Covers acts that may cause damage to the Company's reputation or economic prosperity.
Breaches of Privacy and Personal Data Protection.
Unauthorized Disclosure of Confidential Information.
Acts such as money laundering, competition law breaches, abuse of power and trust, breaches in accounting matters, and others.
Violence and Harassment in various forms.
Acts related to sexual exploitation and abuse.
Acts related to threats, extortion, and the use of violence.
Acts related to intentional concealment of the above illegal acts.
Illegal or irregular acts of another nature or circumstances worth investigating, taking into account their significant impact on the legal interests of the company, employees, and third parties.

5.BASIC PRINCIPLES OF POLICY

ANONYMITY

The protection of anonymity and confidentiality of personal data for each whistleblower is a fundamental principle of this policy. The aim is to create an environment of trust and security, encouraging individuals to report illegal activities or serious offenses. However, it is important to note that the disclosure of the whistleblower's identity may become mandatory, especially during investigations by competent public and prosecutorial authorities, in compliance with European or national law, as well as during administrative or judicial proceedings and investigations. In any case, in the event of disclosure, the whistleblower is provided with specific written information about the reasons for revealing their identity and confidential details, unless prohibited or undermining investigations or judicial proceedings.

TRANSPARENCY

The submission of reports aims to enhance transparency in corporate activities and strengthen compliance with company regulations.

SELFLESSNESS

Due to the fundamental philosophy of the internal self-monitoring process and the protection of the whistleblower's anonymity, the offering of ethical or material exchanges, rewards, privileges, or positive differentiations, such as promotions or favorable treatment, in exchange for a report, is not allowed. However, this principle can be waived only if the report concerns a significant issue for corporate life that could not be revealed otherwise. In this case, the awarding of ethical distinctions to the whistleblower must be made only upon the written request of the latter, following a relevant positive recommendation from the Report Receipt and Monitoring Officer, and a decision by the company's Board of Directors.

EQUALITY

Initially, each report is subject to equal examination by the RRMO and the Company's Management. Regardless of the origin or the reported act, their potential classification at a secondary stage is based on various criteria. These criteria include the seriousness of the act, especially if it has significant criminal implications, serious infringement of individual rights, the impact on the corporate reputation and financial protection of the company, as well as the immediate security measures that may need to be taken.

INDULGENCE

In the event that the whistleblower participated in the incident and bears part of the responsibility, they are not exempt from the consequences and liabilities. However, his reporting and contribution to the detection and investigation of illegal acts will be considered to his advantage. This will be interpreted as a genuine effort to rectify, especially regarding the company's claims against those responsible and the company's legal stance.

PROTECTION

A good-faith whistleblower is not subject to retaliation, regardless of the validity or outcome of their report, and is protected from any reactions from the accused individuals. However, if the whistleblower acts maliciously, causes harm, or could unlawfully and negligently cause damage to the rights of wrongly accused or third parties, the rights of these individuals are protected.

6.REPORT RECEIVING & MONITORING OFFICER (RRMO)

The Report Receiving and Monitoring Officer (RRMO) may be an employee of the company or a third party. If the RRMO is an employee, the execution of duties must not compromise independence or cause conflicts of interest with their RRMO responsibilities. Conflict of interest refers to situations where impartial execution of duties is objectively affected, especially when there is financial gain or loss for the RRMO, their family members, or individuals with special ties, enmity, or friendship. The RRMO is appointed by the legal representative of the company, serving for a calendar year, but may be terminated for any serious reason. The term is automatically renewed unless there is a resignation or a serious reason for termination.

The RRMO performs their duties with integrity, transparency, impartiality, objectivity, and social responsibility. They closely oversee confidentiality rules for matters arising during their duties. In case of a conflict of interest, the RRMO avoids managing specific cases, informing the management about the specific obstacle. Specifically, the RRMO's responsibilities include:

Providing relevant information about the possibility of submitting a report and disclosing relevant information at a visible point.
Receiving reports falling within the scope of this policy.
Confirming the receipt of the report to the whistleblower within seven (7) working days from the day of receipt.
Taking necessary actions to handle the report by the competent authorities. If the report is unclear, not assessable, submitted maliciously or abusively, or lacks incidents substantiating a violation of EU law or serious indications thereof, the RRMO archives it. The RRMO communicates the decision to the whistleblower. If the whistleblower believes that the case was not effectively addressed, they can resubmit the report to the National Transparency Authority.
Ensuring the confidentiality protection of the identity of the whistleblower and any third party named in the report.
Monitoring the report and maintaining communication with the whistleblower if further information is required.
Providing updates to the whistleblower about the actions taken within a reasonable timeframe, not exceeding three (3) months from the confirmation of receipt. If no confirmation has been sent to the whistleblower, the update is provided within three (3) months from the end of seven (7) working days from the submission of the report.
Providing clear and accessible information about the reporting procedures to the National Transparency Authority (NTA), as well as to public entities, institutions, or organizations of the European Union, as appropriate.
Designing and coordinating training activities related to ethics and integrity, participating in the development of internal policies to enhance integrity and transparency in the company.

7.REPORT CONTENT AND SUBMISSION PROCEDURE

Reports should be submitted in good faith and promptly as soon as the incident is identified by the whistleblower. While reports can be anonymous, there is also the option to submit a named report, which will always be treated confidentially to facilitate communication and provide additional information if necessary.

Absolute certainty about the offense or alleged misconduct is not required for submitting a report. It is sufficient for there to be reasonable and justified suspicion, concern, or indication, as perceived by a prudent person. However, the report must be clear and comprehensive, including as much detail as possible to facilitate the investigation. The report should include:

Information about the person (or persons) who may have committed the offense or their position, along with other useful information for identification.
Date or timeframe and location where the reported incident occurred.
Type of breach, as perceived by the whistleblower, and a detailed description if possible.
Reference to any potential documents that can confirm the validity of the reported events.

Please avoid including personal and sensitive data, as well as general information unrelated to the incident, that does not aid in the investigation and resolution of the issue. If such information is included, it will be deleted by the RRMO.

MEDICARE HELLAS is committed to ensuring protection and confidentiality in the reporting process in accordance with Law 4990/2022. Specifically:

Encourages Reporting: Encourages anyone who wishes to share suspicions of breaches in accordance with the law to submit a report.
Confidentiality in Handling Reports: Ensures that all reports received will be handled with absolute confidentiality, emphasizing the respect for the confidentiality of information.
Maintaining Confidentiality of the whistleblower: Commits to maintaining the identity of the whistleblower confidential throughout the process, unless disclosure is proven necessary for the effective investigation, such as in legal proceedings.

Anyone interested can submit a report to the Report Receiving and Monitoring Officer (RRMO) of MEDICARE HELLAS in three different ways:

By Phone
In Writing: The whistleblower can send a letter to the RRMO. The envelope must bear the indication "Attention of the Report Receiving and Monitoring Officer (RRMO)."
Via Email

Internal Report Submission to the Report Receiving and Monitoring Officer (RRMO) MEDICARE HELLAS S.A.

The current Report Receiving and Monitoring Officer (RRMO) of MEDICARE HELLAS S.A. is:

Konstantinos A. Zavoudakis, Chief Operating Officer

You can contact him and submit your report through the following methods:

Phone: (+30) 6977631209
Mailed Letter: Address: 2 Kalvou & Palaiologou Str., 15232 Chalandri, Athens, with the indication on the envelope "Attention of the Report Receiving and Monitoring Officer (RRMO)."
Email: yppa@medicare-hellas.gr

8.REPORT MANAGEMENT PROCESS

Reports will be submitted through a rigorous evaluation process with strict scrutiny, impartial judgment, and objectivity. Once the report is received, the Reports Receiving and Monitoring Officer (RRMO) immediately informs the company's legal representative. Simultaneously, a three-member Report Management Committee is recommended. This committee consists of:

A managerial executive, preferably from the department where the breach occurred.
The RRMO.
A member, internal or external, appointed by the Chief Executive Officer.

It is noted that no person mentioned in the report participates in the Report Management Committee, either as the accused, collaborator, or witness. The RRMO may communicate with the whistleblower throughout the investigation and may request clarifications, additional information, or assistance.

The Report Management Committee investigates reported incidents with discretion and confidentiality, without knowledge of the whistleblower's identity. Access by third parties to the report's details is restricted. Specifically, the report and critical events it contains are disclosed only to individuals deemed necessary for the investigation. These individuals are obligated to observe confidentiality and trust rules.

Those involved in any way in the investigation, including employees called upon to contribute due to their position, duties, and knowledge, must collaborate harmoniously and effectively to resolve the reported incident. Upon completion of the investigation, the Report Management Committee recommends the following actions to the company's management:

Closing the case if the report is deemed substantially unfounded.
Proposing the implementation of internal corrective measures.
Initiating necessary legal actions with the relevant authorities.

Internal corrective measures may include additional training for employees and collaborators, establishing new internal control measures, modifications to existing policies and procedures, imposition of disciplinary sanctions, as well as legal actions. In cases where a report includes issues beyond the scope of the Policy and the law, the Report Management Committee will take appropriate actions for effective resolution. These actions may involve assigning the case to a suitable individual or group.

Cases related to reports considered unfounded, malicious, or abusive will be archived without further action. In any case, the Report Management Committee will inform the whistleblower of the reason for archiving. In case of disagreement by the whistleblower regarding the effectiveness of the management, there is the possibility of submitting a report to the National Transparency Authority (NTA). If the report is accepted, appropriate measures will be taken for further investigation.

Submission of External Report to the National Transparency Authority NTA

The Whistleblower has the option to directly submit an external report or complaint to the National Transparency Authority (NTA). This complaint can be submitted in writing or through an electronic platform, also accessible to individuals with disabilities. Specifically:

• Electronically: By sending an email to kataggelies@aead.gr or through the relevant complaints form, available here: https://aead.gr/submit-complaint/ .

• By mail: By sending it to the postal address of the NTA: 195, Lenorman av. and Amfiaraou str., 104 42, Athens.

• In person (or through a legally authorized representative): By submitting the complaint/report at the NTA's facilities: 195, Lenorman av. and Amfiaraou str., 104 42, Athens.

9. REPORT ARCHIVE MAINTENANCE

The Reports Receiving and Monitoring Officer (RRMO) maintains a confidential archive containing all submitted reports and related documents. Upon handing over responsibilities to the next RRMO, the relevant archive is transferred to the successor.

Access to the archive is restricted to authorized administrative and judicial authorities, unless there is a compelling reason for the case to be declassified. This reason may be linked, for example, to the protection of the rights of third parties. In any case, the inviolable principles of confidentiality and trust must be upheld.

The archive is retained for a period of five (5) years from the date of submission of the report/complaint, provided there are no other legal reasons for its retention and in accordance with the company's policies.

10.PROCESSING OF PERSONAL DATA

The Company hereby confirms that the personal data of the Whistleblowers and other potentially involved parties, collected during the management of Reports, will be processed in accordance with applicable legislative provisions for the protection of personal data. Furthermore, the processing is limited to data that is absolutely necessary for investigating the legitimacy of the Report and its resolution. Personal data not directly related to the report or deemed excessive will not be collected. If, however, such data is inadvertently collected, it will be promptly deleted without delay.

Specifically, the initial processing of personal data is carried out by the Reports Receiving and Monitoring Officer (RRMO) for the purpose of executing the procedures outlined in this Policy. The RRMO acts as the Data Controller, except in cases specified by special laws governing the matter.

To ensure proper management of submitted Reports and full compliance with legislation, the processing of personal data is conducted with utmost respect for privacy, freedoms, fundamental rights, and the dignity of the individuals involved.

The personal data included in the Reports can be forwarded by RRMO to the corporate bodies, internal services that are competent on a case-by-case basis, as well as judicial authorities. This is done in order to initiate the necessary procedures to take, based on the Report, adequate judicial and/or disciplinary measures of protection. This applies in cases where the collected information and the investigation establish the legitimacy of the reported incidents.

During the assessments for the legitimacy of the Report, all necessary measures are taken to protect data from accidental or unlawful destruction, loss, or unauthorized disclosure. Finally, documents related to the Report are retained, both in hard copy and electronic format, for the required period ensuring the correct completion of the prescribed procedures according to this Policy.

11.PROTECTION OF WHISTLEBLOWER AND ACCUSED PERSON

PROTECTION OF THE WHISTLEBLOWER

The individual submitting a Report under this policy is protected against any retaliation that may arise from the Report itself. Regardless of whether the whistleblower makes a mistake, protection is provided under the condition that the whistleblower acts in good faith. Therefore, the whistleblower is entitled to protection if, at the time of submitting the Report, there were reasonable grounds to believe that the information about the breaches was true. The identity of the whistleblower is handled with absolute confidentiality.

In accordance with Law 4990/2022, specifically Article 14, any information directly or indirectly leading to the identification of the whistleblower is not disclosed to individuals other than authorized members of the personnel responsible for receiving or monitoring Reports, unless there is consent from the whistleblower. As an exception to this principle, disclosure of the whistleblower's identity and other relevant information is allowed only when required by union or national law, within the framework of investigations by competent authorities or judicial proceedings, and when such disclosure is necessary to serve the purposes of this policy or to ensure the defense rights of the accused person.

These disclosures are made after prior written notification to the whistleblower about the reasons for disclosing their identity and other confidential information, unless such notification jeopardizes investigations or judicial proceedings. Failure to provide this notification is considered a disciplinary offense for those subject to disciplinary law. After notification, the whistleblower is entitled to submit written comments to the authority making the disclosure, which are not disclosed to anyone. Specifically, in cases where the reasons presented in the comments are not deemed sufficient, the disclosure of the identity and other confidential details is not prevented. Moreover, no further safeguards for the identity of the whistleblower and information from which it can be inferred are affected, as provided by special provisions of union or national law.

PROTECTION OF THE ACCUSED PERSON

Under Law 4990/2022, specifically Article 21, comprehensive protection is provided to the accused person, ensuring the following rights:

Access to Legal Remedies: Accused persons have full access to all legal remedies and means necessary for their defense.
Fair Trial: They enjoy the rights of a fair trial, including the right to an effective remedy before an impartial court.
Presumption of Innocence and Rights of Defense: The presumption of innocence and rights of defense are ensured, including the right to be heard and the right to access their file.
Identity Protection: The identity of the Accused persons is protected during investigations arising from the Report or public disclosure.

12.PROHIBITION OF RETALIATION – PROTECTION FROM RETALIATORY ACTIONS

The term "retaliation" refers to the negative consequences that an individual may face in the workplace due to their involvement in a Report and/or an investigation related to submitted Reports.

Any form of retaliation is prohibited under Article 17 of Law 4990/2022, including threats and acts of revenge. Specifically, the following forms of retaliation are prohibited:

Termination, dismissal, or equivalent measures,
Demotion, neglect, or denial of promotion,
Removal of duties, change of workplace, salary reduction, changes in working hours,
Deprivation of training,
Negative performance evaluation or negative professional recommendation,
Reprimand, imposition of disciplinary or other measures, including financial penalties,
Coercion, intimidation, harassment, or marginalization,
Discrimination or unfair treatment,
Non-conversion of temporary employment contract into a permanent one,
Non-renewal or premature termination of a temporary employment contract,
Deliberate harm, including damage to reputation, especially on social media, or financial harm, including business loss and loss of income,
Listing on an unwanted list ("blacklist") based on sectoral or industry official or unofficial agreement, which may hinder future employment prospects,
Premature termination or cancellation of a contract for goods or services,
Revocation or cancellation of a license or permit,
Referral for psychiatric or medical monitoring,
Denial or deprivation of reasonable accommodations for individuals with disabilities.

Considering the recognized fear that prevents some employees from submitting any form of Report due to the risk of retaliation, this framework ensures a safe working environment that protects and encourages the submission of Reports for irregularities, omissions, or other illegal actions that employees become aware of.

Through this framework, every employee is encouraged to express their opinions without fear of retaliation. They are called upon to speak openly and provide honest and complete information when observing or suspecting illegal, unethical, or contrary behavior to the current institutional framework, as well as internal regulations governing the Company's operation.

In the event that an employee faces retaliation in the workplace, the Company encourages the employee to report the incident in writing to the Human Resources Department. When reporting the incident, the employee includes any information supporting their Report.

The Human Resources Department examines the credibility of the Report, conducts an investigation, and takes appropriate actions to resolve the incident. The Whistleblower is informed of the outcome of the Report upon completion of the process. Additionally, the Human Resources Department informs the Administrative and Disciplinary Board of any Report of retaliatory action.

The Company takes appropriate measures to restore the work environment of the employee who has faced retaliation. It also considers the possibility of transferring them to another department, if feasible and requested by the employee.

The Company expresses its support for the presumption of innocence, specifically for both the accused person and the whistleblower. We are committed to adhering to the framework for the protection of the whistleblower and the accused person from retaliation, upholding the principle of equality, even in cases where submitted Reports cannot be confirmed after a relevant investigation.

Corresponding consequences will be imposed in cases where it is confirmed that the employee, knowingly, submitted a false claim, provided false or misleading information, obstructed work during an investigation, or acted in bad faith in any way.

13.CRIMINAL SANCTIONS

The law provides for imprisonment and fines for individuals committing the following acts:

(a) Obstruction of Report Submission: Individuals who obstruct or attempt to obstruct the submission of a report are subject to imprisonment and fines.

(b) Malicious Proceedings: Individuals engaging in retaliation or initiating malicious proceedings against the whistleblowers are liable to imprisonment and fines.

(c) Violation of Identity Confidentiality: Individuals violating the obligation to maintain the confidentiality of the identity of the whistleblowers are subject to imprisonment and fines.

Additionally, individuals who knowingly make false reports or false public disclosures are punished with imprisonment for at least two years and a monetary fine.

In cases where any of the violations were committed for the benefit or on behalf of a legal entity, an administrative fine is imposed on it, ranging from a minimum amount of €10,000 to a maximum amount of €500,000.

14.INFORMATION, REVIEW, AND AMENDMENT

The Reports Receiving and Monitoring Officer (RRMO) ensures the comprehensive awareness of all company employees regarding the content of this policy. Information is disseminated through the delivery of informative materials, emails, or other suitable means, depending on the employee category. Additionally, this policy is accessible to any third party through the company's official website www.medicare-hellas.gr. The reporting process is easily identifiable through the company's official website, telephone, email, etc. Moreover, the reporting process provides straightforward and understandable instructions for potential whistleblowers.

The Company reserves the right to review this Policy to meet evolving needs and always comply with current legal and regulatory frameworks. This Policy will be periodically reassessed to confirm its adequacy or highlight the need for updates. In this way, modifications, updates, and revisions will be made to continuously improve the efficiency and effectiveness of the policy. Each new version will replace the previous one to ensure compliance with current requirements