Compliance

LABORATORIO ARAGÓ, S.L. announces its Crime Prevention Model (MPD) that meets the legal requirements in terms of corporate criminal liability, whose objective is to prevent its legal structure from being used to commit crimes and at
the same time implement good corporate governance and a culture of compliance.

LABORATORIO ARAGÓ has proceeded to implement a Crime Prevention / Criminal Compliance Model in accordance with art.31 bis of the Spanish Penal Code.

In 2010, with the reform of the Criminal Code, the criminal liability of companies was introduced in Spain. Later, in 2015, the need for companies to have organization and management models for crime prevention (Crime Prevention
Models) was established.

Since 2017, LABORATORIO ARAGÓ has been implementing and developing an internal structure for the prevention of the commission of crimes within the scope
of the entity.

Scope of the DPM

LABORATORIO ARAGÓ has proceeded to implement an internal organization for crime prevention that is structured around:
1. Criminal risk analysis.
2. Risk map.
3. Implementation of transversal controls for the prevention, detection, and mitigation of risks.
4. Implementation of specific controls for the prevention, detection, and mitigation of risks.
5. Creation of a Compliance Committee.
6. Opening of a Complaints Channel.
7. Internal audits.
8. External expert advice.

COMPLIANCE COMMITTEE / COMPLIANCE OFFICER:
A multi-person COMPLIANCE COMMITTEE has been created, made up of various Compliance Officers.
The COMPLIANCE COMMITTEE is the body in charge of ensuring the coordination and supervision of the operation and compliance with the Crime Prevention Model implemented.
Their roles and responsibilities are detailed in the entity “Compliance Committee and Ethics Channel Protocol”.

ETHICS AND COMPLAINTS CHANNEL.
LABORATORIO ARAGÓ has proceeded to create an Ethics Channel – for complaints as a high-level control measure, so that any direct member (administrators, employees, professionals, and managers) or related (collaborators or suppliers) can communicate any indication or suspicion of committing conduct that may involve:
• Failure to comply with applicable regulations, protocols, procedures, and internal controls.
• Commission of acts that are not in accordance with ethical principles and good business practices.
• Commission of acts that could be criminal.
The operation of the complaints channel and the processing thereof is detailed in the entity “Protocol of the Compliance Committee and Ethics Channel