1. Occupational Risk Prevention Policy

1.1 Institutional commitment and regulatory framework

CIC energiGUNE has established an occupational risk prevention policy aimed at ensuring the protection of employees’ health and safety and integrating prevention into all activities of the organization. This policy is based on the commitment of the management to continuously improve working conditions and to comply with current occupational health and safety regulations, particularly Spanish Law 31/1995 on the Prevention of Occupational Risks.

1.2 Integration of prevention into organizational activities

The organization establishes that prevention must be incorporated from the initial stages of planning projects, facilities and activities. For this purpose, an initial and systematic evaluation of the risks inherent to each workplace is carried out, and working conditions are periodically reviewed in order to identify potential risks and apply corrective measures appropriate to their nature.

Among the principles governing this policy is the consideration of occupational health and safety as a priority within the organization’s activities. This implies that safety requirements must be integrated into work processes and decision-making. In addition, management promotes a proactive attitude towards prevention and encourages the integration of preventive activities into daily operations.

1.3 Training, participation and continuous improvement

The policy also promotes the active participation of employees through information and training initiatives aimed at improving awareness of workplace risks and the measures necessary to prevent or reduce them. The design of facilities, equipment and processes must incorporate safety, hygiene and ergonomic criteria from the outset, with the objective of improving working conditions and minimizing occupational risks.

1.4 Coordination with external companies

Furthermore, when working with external companies or suppliers, the organization requires coordination of preventive activities and ensures that these entities comply with the applicable occupational health and safety regulations.

2. Harassment Prevention and Response Protocol

2.1 Principles and organizational commitment

CIC energiGUNE has established a specific protocol to prevent and manage harassment situations in the workplace. This protocol reflects the organization’s commitment to equal opportunities, respect for diversity and the creation of a safe, inclusive and respectful working environment for all individuals.

The policy states that any form of harassment, intimidation or bullying is unacceptable and constitutes serious misconduct that may lead to disciplinary action, including termination of employment. Such behaviors negatively affect the working environment, the health and well-being of affected individuals and the organizational climate of the center.

2.2 Code of conduct and responsibilities

The protocol establishes a code of conduct requiring all members of the organization to treat colleagues and any person related to the center with dignity and respect. Individuals in supervisory or leadership roles have a particular responsibility to actively prevent, detect and stop any inappropriate behavior.

2.3 Types of harassment

Behaviors considered as harassment include workplace or psychological harassment (mobbing or bullying), sexual harassment, sex-based harassment, harassment related to gender identity or sexual orientation, and cyber-harassment or any intimidating behavior carried out through digital means. These behaviors are characterized as unwanted conduct that violates a person’s dignity and creates an intimidating, hostile, degrading or humiliating environment.

2.4 Complaint management procedure

The protocol also establishes an internal procedure for managing complaints or reports. Whenever possible, an informal resolution is recommended as a first step. However, any affected individual may initiate a formal procedure. Throughout the process, confidentiality is guaranteed, investigations are conducted impartially, and protection against retaliation is ensured for individuals who report concerns in good faith.

Investigations are conducted objectively and confidentially, usually within a period of approximately thirty working days. Based on the results of the investigation, appropriate measures may be adopted, including disciplinary or corrective actions if harassment is confirmed.