Whistleblowing

PRESSBROKERS, S.L. (Bitnovo®) has implemented an Internal Information Channel or Whistleblowing, in accordance with Directive (EU) 2019/1937 and its transposition into Spanish legal order through Law 2/2023, of February 20, as well as in compliance with the applicable regulatory framework regarding crypto-assets, including Regulation (EU) 2023/1114 (MiCA) and Delegated Regulation (EU) 2025/305.

Who can use it? This channel is available for:

  • Bitnovo® workers, even if their employment relationship has ended.
  • Members of the management or administration body.
  • External collaborators, service providers, agents, volunteers, interns, training personnel and people participating in selection or pre-contractual negotiation processes.

What can be reported?

  • Regulatory breaches regarding crypto-assets (MiCA Regulation).
  • Serious administrative, criminal or disciplinary infractions.
  • Serious breaches of Bitnovo®'s internal regulations.

Channel access: https://bitnovo.factorialhr.es/complaints

Accepted communications:

  • Identified or anonymous.
  • In writing, verbally or requesting an in-person meeting.

What happens after submitting a report?

  • An acknowledgment of receipt will be issued within a maximum period of 7 calendar days.
  • The communication will be evaluated and, if appropriate, an internal investigation will be opened.
  • Within a maximum period of 3 months (extendable for another 3 in complex cases), a response or conclusion about the actions taken will be provided.
  • In case the communication is not anonymous, and whenever possible, the reporting person will be informed about the conclusion of the procedure.

System principles and guarantees:

  • Confidentiality.
  • Possibility of anonymity.
  • Prohibition of retaliation.
  • Rights of affected persons.
  • Data protection: Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD).

External channels:

  • The Independent Authority for the Protection of Whistleblowers (A.A.I.)
  • Competent autonomous authorities or bodies, if they have been designated in accordance with article 12.2 of Law 2/2023.