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JB Capital Markets, S.V., S.A.

In accordance with the provisions of the Code of Conduct of Grupo de Inversiones Zulú S.L.U. (hereinafter “the Group”) and the regulations governing the protection of persons who report regulatory and anti-corruption violations, i.e. Law 2/2023 of 20 February, governing the protection of persons who report regulatory and anti-corruption violations (hereinafter “Law 2/2023”), the Group makes available to the members of the Group’s Board of Directors, employees (with present or terminated employment relationship), shareholders and agents of the Group, as well as those third parties (suppliers, contractors, subcontractors, customers, etc.), the information provided by the Group to the Group., of the Group) a Whistleblower Channel that allows (i) to report actions or omissions that may constitute a serious or very serious criminal or administrative offense, as well as any violation of the legislation in force, especially those included in the material scope of application of Law 2/2023; (ii) to report any allegedly unlawful acts or acts constituting breaches of the Code of Conduct, the Internal Rules of Conduct, any other internal regulations, such as those related to the prevention of money laundering and the financing of terrorism, as well as any irregular or inappropriate conduct; and (iii) to make inquiries regarding the interpretation and application of the manuals or internal regulations that must be complied with by members of the Board of Directors, Senior Executives, employees and agents of the Group or in case of doubt or concern as to whether a certain situation could be considered an act of those set forth in points (i) and (ii) above, all in accordance with the principles and guarantees detailed in the document “Whistleblower Protection”. To file a complaint, please contact:

  1. By sending an e-mail to canaldenuncias@jbcapital.com.
  2. By sending a letter to Calle Serrano Anguita, nº1, 28004, Madrid, to the attention of the Director of the Compliance Department of JB Capital Markets, S.V., S.A.U. (hereinafter “JB Capital”).
  3. Through a personal interview with JB Capital’s Director of Compliance.
  4. When the person being reported (individually or together with other persons) is a member of JB Capital’s Regulatory Compliance Department or the Criminal Compliance Body, the communication shall be made in one of two ways: (i) to the attention of the Director of JB Capital’s Legal Department at the postal address of Calle Serrano Anguita 1, 28004 Madrid; (ii) through a personal interview with the Director of JB Capital’s Legal Department.
  5. When the person being reported (individually or together with other persons) is the Director of the Legal Department of JB Capital, the communication shall be made in one of two ways: (i) A letter shall be sent to the attention of the Director of Compliance, the Director of Human Resources and the Head of Risk Management of JB Capital; (ii) A letter shall be sent to the attention of the Director of Compliance, the Director of Human Resources and the Head of Risk Management of JB Capital. (i) A letter shall be sent to the attention of the Compliance Director, HR Director and Head of Risk Management of JB Capital, without specifying the body to which they belong, to the postal address of Calle Serrano Anguita 1, 28004 Madrid; (ii) By personal interview with the Compliance Director of JB Capital and, in the absence of the latter, with the HR Director and/or the Head of Risk Management of JB Capital.

For more information on the Whistleblower Channel and its applicable data protection regulations, please refer to the following documents:

Data_protection_information

Whistleblower Protection