SEAT:CODE advocates for a culture of corporate compliance, aligning with both national laws, international legislation, and the Company's and Volkswagen Group's internal regulations. That's why we provide employees, business partners, and third parties with the following points of contact:

REPORTING SYSTEM

Our irregularity reporting system

Compliance with legal and internal regulations and the principles established in our Code of Conduct and Business Partners' Code of Conduct is of the utmost priority at SEAT:CODE. The success of our company is based on Integrity and Compliance. To meet these standards, it's important to learn from potential misconduct by employees or suppliers and put a stop to it. Therefore, SEAT's Analysis Office, together with the Volkswagen Investigation Office (hereinafter, the Investigation Office), operates an independent, impartial, and confidential irregularity reporting system.

A key pillar of our Reporting System is the principle of procedural fairness. It also ensures the highest possible protection for whistleblowers, involved individuals, and employees contributing to the investigation of reported misconduct.

This also includes providing opportunities for anonymous reporting and communications. We ensure not to take any steps to identify anonymous whistleblowers, who do not misuse our reporting system. Retaliation against whistleblowers and all individuals contributing to investigations at SEAT:CODE will not be tolerated. Involved individuals are presumed innocent until a violation is proven. Investigations will be conducted with the utmost confidentiality. Information will be processed in a fair, prompt, and protected process.

How do we process your report?

Employees of the Investigation Office thoroughly examine each report for potential misconduct by Group employees and systematically follow up. First, you will receive a receipt confirmation. Then, the Investigation Office evaluates your report. This includes gathering data particularly from the Whistleblower. Only if this initial assessment shows grounds for suspecting a violation, will an investigation by a specific Investigation Unit be initiated. Subsequently, the investigation results will be evaluated by the Investigation Office, and appropriate measures will be recommended. You will be provided with information about the status and outcome of the procedure without undue delay.

Possible violations of the Code of Conduct for business partners by suppliers, including severe risks and violations of human rights and the environment by direct and indirect suppliers, can also be reported to the Investigation Office, as well as reports requiring immediate action. The Investigation Office will inform the responsible departments, who will process the matter accordingly. This particularly includes taking necessary measures to minimize or terminate violations and/or risks.

• Processing time varies depending on the subject of the procedure

Find more information about the procedural principles of the Volkswagen Group's Complaints Procedure here.

SUBMITTING A REPORT TO OUR REPORTING SYSTEM

The Reporting System offers various channels for reporting potential misconduct by employees, allowing for quick review and reaction by our company if necessary.

However, this does not affect the legal right to contact designated authorities as described below.

For basic information about the Reporting System in Spanish, click https://code.seat/assets/docs/WBS_Basic_Information_ES.pdf

SEAT's Whistleblowing Channels

Transparency

Transparency channels are managed internally by SEAT's Analysis Office, which is part of SEAT's Compliance and Integrity Department.

You can contact SEAT's Analysis Office via email or phone:

Email: transparencia@seat.es

Phone: +34 900 103 220 (working hours from 8 a.m. to 3 p.m.).

Upon request by the whistleblower, reports can be communicated via in-person meeting within a maximum period of seven days.

Local Ombudsman

Our local Ombudsman, Dr. David Velázquez, is a retired judge, independent lawyer, and Doctor of Law who has been appointed due to his extensive professional experience. He is bound by the oath of professional secrecy to maintain strict anonymity of whistleblowers' identities, if requested, and to treat the provided data with the utmost confidentiality.

You can contact our local Ombudsman via email or phone:

• Phone: +34 609 665 001

• Email: david.velazquez@miombudsman.es

Volkswagen Group's Whistleblowing Channels

24/7 Hotline

You can submit a report 365 days a year, 24 hours a day, using the international toll-free number:

+800 444 46300*.

If your local phone provider does not support toll-free service, you can call the following paid number:

+49 5361 946300.

*Depending on the country you're calling from, the international toll-free hotline number may not be available because some phone network providers do not support the service. In that case, use the offered paid number or your country-specific number.

Country Free Number Local Number

Brazil 0800-5912743 021-23911381

Mexico 001-800-4610242 0155-71000355

Slovak Republic 0800-002576 02-33325602

USA 833-6571574 908-2198092

South Africa 0800-994983 021-1003533

Malaysia 1-800-819523 0154-600099

Argentina 0800-6662992 011-52528632

Germany 0800 444 46300 05361-946300

Online Whistleblowing Channel

You have the option to use a web-based communication platform https://www.bkms-system.com/bkwebanon/report/clientInfo?cin =22vwgroup16&c=-1&language=eng to contact the Investigation Office in many languages. This system is confidential and technically secured.

Even if your preferred language is not offered on the reporting channel, you can use any language to submit your report. You can also communicate with the Investigation Office in any language via email or mail.

Ombudsmen

Volkswagen has appointed external lawyers to act as Ombudsmen. They advise on the Whistleblowing System or ensure that whistleblower reports are sent anonymously to the Investigation Office if desired.

If you want to contact the Ombudsman, you can find their contact details here: https://www.ombudsmen-of-volkswagen.com/

Email

You can contact Volkswagen's Central Investigation Office via E-Mail:

io@volkswagen.de

Postal Address / In Person

Postal Address:

Volkswagen AG, Central Investigation Office Mailbox 1717 Berliner Ring 2 38436 Wolfsburg, Germany

In Person:

Please make an appointment in advance by emailing io@volkswagen.de.

Have more questions or need a local contact?

Questions or improvement suggestions regarding the Reporting System can also be directed to the Investigation Office.

If you have been interviewed regarding an investigation, you have the opportunity to provide your opinion to the Ombudsman as an independent body.

Additionally, the Local Whistleblowing System Responsible / Compliance Officer can also be reached via transparency@seat.es.

External Whistleblowing Channel in Spain

In Spain, you can direct reports of potential misconduct to the "Independent Authority for Whistleblower Protection, A.A.I.", a body entrusted with external whistleblowing channel functions according to Law 2/2023, of February 20.

External Whistleblowing Channel in Catalonia

In Catalonia, you can report your concerns to the Catalan Anti-Fraud Office, a body provisionally assigned external whistleblowing channel functions by Law 3/2023, of March 16.