Sustainability Report 2022

The Code of Ethics sets out basic principles in terms of internal control and prevention of corruption, regulating aspects such as the transparency, rigor and the reliability of information and the control of all records, as well as covering bribery and measures against corruption, the prevention of money laundering and irregularities in payments. The Code of Ethics online course , available to the entire workforce, promotes these principles and fosters the necessary collaboration of all PRISA employees in preventing all forms of crime and inappropriate behavior. By December 31, 2022, a total of 2,800 employees out of a total of 7,222 had completed the course. The 2021 Compliance Policy is, in effect, a declaration of the Group’s commitment to regulatory compliance. However, the organization sees the concept of compliance as going further than merely complying with applicable laws and internal regulations. It also includes the promotion of a culture of ethics and corporate integrity within the Group in all its daily activities. With this policy, PRISA thus reinforces its commitment to the company’s very purpose and to the values, principles and standards of conduct as promulgated in the Code of Ethics. The Anti-Corruption Policy , revised and updated in July 2022, establishes PRISA's commitment to the fight against corruption in all its forms, in all areas In 2022, PRISA has renewed its Anti-Corruption Policy, Competition Policy, Gifts Policy and the protocol for the prevention of money laundering . The fight against corruption and bribery and in all the countries in which it operates. Also in 2022, the protocol for the prevention of money laundering was updated and approved with the aim of reinforcing measures to prevent money laundering from criminal or illegal activities. This procedure is applicable across all Group companies . The Investment and Financing Policy defines the applicable framework for the analysis, approval and control of investment or divestment projects and coverage of the financial, control and financial risk management needs of the businesses. The Gifts Policy , updated and approved in July 2022 by the PRISA Board of Directors , gives guidance to employees and management bodies on making the right decisions regarding the acceptance and offering of gifts, services, or other hospitality, within the framework of the Group's commercial relations. The Competition Policy , also updated and approved by the Board of Directors in July 2022, establishes PRISA's commitment to promoting free competition and avoiding conduct that constitutes or may constitute collusion, abuse, or restriction of free competition. Its compliance applies to companies, staff, and managers of the Group. With the aim of using employee training and awareness-raising to minimize the risks of corruption and bribery, an anti-corruption course was launched in 2022. It is available to all employees on the PRISA Campus training platform, which can be accessed through the intranet. As of December 31, 2022, 3,563 employees out of a total of 7,222 had completed the course. The Crime Prevention and Detection Model is another of the pillars on which the compliance model is built, in line with the general organizational and management requirements set out in sections 2 and 5 of article 31 bis of the Spanish Criminal Code for Spanish Subsidiaries. The resulting model undergoes a continuous process of reappraisal and is regularly updated to ensure its effectiveness and the correct operation of said controls. Specifically for the prevention and detection of corruption and bribery, it is essential to have a matrix for criminal risks and controls. Meanwhile, the Group has at its disposal another set of policies and procedures that serve as additional measures to prevent bribery and combat corruption, among which the following are notable: procedure for engaging with public administrations; procedure for the granting of restrictive powers of attorney; and travel and business expenses policy . With regards to the protocol for action in cases of corruption, bribery or money laundering, the complaints or whistleblowers’ channel and compliance emails are made available to all employees and third parties. The key indicator at PRISA’s disposal for assessing the risk of corruption, in all its forms in both the public and private sectors, is the number of complaints received and substantiated each year via the Whistleblower Channel. Of the complaints received and investigated in 2022, six were related to cases of corruption . Three were found to be substantiated: two cases involved employee fraud and a third related to a regulatory breach. In all three cases, various measures were taken to strengthen controls, and the appropriate disciplinary regime in accordance with the country's legislation was applied. initiative and oversight, as well as the functions of the criminal prevention body provided for in the Penal Code. Among other functions, the CCO is responsible for ensuring and promoting the ethical behavior of the Group's employees and for identifying, managing and mitigating compliance risks. The CCO reports directly to the Audit, Risk and Compliance Committee . In 2022, both PRISA business units were provided with their own respective Chief Compliance Officers in order to strengthen compliance and to increase coordination of common compliance objectives between PRISA and its subsidiaries. The most significant business unit subsidiaries (Brazil, Mexico, Colombia, Argentina, and Chile) have also established compliance units or have designated a compliance officer. PRISA has a whistleblower or complaints channel , which is accessible on its corporate website (www.prisa.com ), on the intranet and via a post office box in Madrid, through which any person, anonymously and confidentially, can report any irregularity or breach of both external and internal regulations . The procedure governing said channel regulates the reporting of irregularities, guarantees that there will be no retaliation against whistleblowers who report alleged non-compliance or irregularities in good faith, describes the process of investigation, resolution, the application of sanctions (if applicable) and the communication of decisions taken. The complaints channel is managed by the CCO . PRISA employees can send queries related to the Code of Ethics and other internal regulatory, ethics and compliance matters to the compliance email (cumplimiento@prisa.com) managed by the CCO. Similar emails associated with each business's Compliance Unit (CU) redirect to the Group's compliance mailbox. A procedure similar to that for complaints received through the whistleblower channel is followed when processing complaints received through these emails. In 2022, 37 complaints were received, 13 more than in 2021 (24). Of these, 11 were deemed to be substantiated, 2 are under ongoing investigation (from which no significant consequences are expected) and 24 were deemed to be unfounded. In cases where complaints were found to be substantiated, the disciplinary measures provided for in the corresponding legislation were applied, and controls were generally reviewed and strengthened to mitigate future risks. It should be noted that no complaints or significant sanctions were made against PRISA in 2022 for non- compliance with the legislation or regulations in any of the markets where it operates. Since 2022, PRISA's two business units also have each had their own Chief Compliance Officer . PRISA Sustainability Report 2022 41