INFORMATION NOTE MAY 2025 HOLIDAY ENJOYMENT FOR FIXED-TERM DISCONTINUOUS JOINERS (SUMMARY: We are aware that the Labour and Social Security Inspectorate has issued an infringement report because the company paid three fixed-term employees the holidays they did not take at the end of the season. The Labour and Social Security Inspectorate argues that a serious infringement has been committed because holidays cannot be paid and has proposed a fine of 3,000 euros. It only establishes the possibility of paying holidays in the event of termination of contract, not the suspension of fixed-term employees. The above is derived from a Ruling by the TSJ of the Balearic Islands, which states that since the Workers' Statute establishes that holidays must be taken and cannot be paid (except for termination of the contract and not for suspension of the same as occurs in the case of fixed-term employees), therefore, in the case of the end of the season, fixed-term employees must take or have taken their corresponding holidays, in Consequently, employers are required to negotiate vacation periods with their employees. This issue affects ALL companies with permanent, intermittent employees, such as hotels, restaurants, shops, etc. The Social Chamber of the High Court of Justice of the Balearic Islands, in a ruling of February 26, declared several articles of the collective bargaining agreement for the hospitality sector in the same autonomous community null and void for violating workers' right to vacation time. Specifically, the judges believe that granting employers the power to unilaterally decide on rest days violates the Workers' Statute and, furthermore, European Union law. While it is true that collective bargaining agreements may contain provisions on annual vacation planning, it is not possible to attribute the determination of the vacation period or periods to the unilateral decision of the employer. Nor is it possible to establish in the collective bargaining agreement a mere five days' notice of the vacation start date, because workers have the right to know the period to which they are entitled at least two months before the commencement of their vacation. The collective bargaining agreement for the hospitality sector in the Balearic Islands fails to comply with the minimum and mandatory provisions of the Workers' Statute when it establishes that companies may distribute compensatory rest equivalent to working holidays. Nor does it do so when it establishes that the company may set the vacation entitlement to workers during the guaranteed employment period on the dates it agrees or demands, even before the accrual of the right to such vacation, whether continuous or split. Such a violation of the Workers' Statute implies the obligation to provide five days' notice. This contradiction between the Agreement and the Workers' ... It is not possible to introduce, through the Convention, a differentiated regime for temporary permanent employees regarding the enjoyment of vacation time and compensation for paid and non-recoverable working days during which they work. The provisions of the Convention, which allow employers to unilaterally determine the right to vacation time, thereby diminishing this right, are not only contrary to the provisions of the ET (Working Order), but also to EU law, which upholds that the purpose of the right to paid annual leave is none other than to allow workers to rest and enjoy a period of leisure and recreation. Specifically, the Judgment declares invalid Article 8.6 and the last paragraph of Article 17 of the hospitality agreement, which allowed employers to unilaterally decide the days on which the aforementioned employees would be able to take their vacation time, and furthermore, to notify them with only five days' notice, considering that they are contrary to Article 38 of the Workers' Statute and the doctrine of the Court of Justice of the European Union.

INFORMATION NOTE MAY 2025

CONSTRUCTION SECTOR PENSION PLAN

 SUBJECT: Measures of the Construction Collective Agreement regarding diversity, respect for and recognition of equality and non-discrimination based on sex, sexual orientation or identity (LGTBI) required for companies with more than 50 employees. Resolution of April 22, 2025, of the General Directorate of Labor, by which the Minutes of modification of the VII General Collective Agreement for the construction sector are registered and published. 

SUMMARY OF THE STANDARD: Preamble. The standard seeks to respect diversity and the recognition of equality and non-discrimination based on any individual condition and, in particular, based on sex, sexual orientation or identity (hereinafter, LGTBI). Purpose of the measures: To achieve real and effective equality for LGTBI people through awareness-raising and training for the workforce. In turn, companies will have a protocol (Annex XVIII) for the eradication of all behaviors that may be considered constitutive of workplace harassment against workers, including LGBTI people. The measures are developed within the framework of the following lines of action: - Prevent, correct, and eradicate any type of discrimination in access to employment, working conditions, professional promotion, training, etc. - Promote and guarantee equal treatment and opportunities for LGBTI people. Scope of application. Companies in the sector that, within the scope of this agreement, have more than fifty employees on their payroll. Companies with fewer employees than the number indicated above may apply, if they deem it appropriate, the planned measures contained in Annex XVII, as well as the protocol contained in Annex XVIII. "ANNEX XVII Planned and agreed measures to achieve real and effective equality for LGBTI people Equal treatment and non-discrimination clauses. An inclusive corporate culture will be promoted, fostering respect for diversity and expressly including respect for sexual orientation or identity, gender expression, and sexual characteristics, as well as the elimination of all forms of discrimination against LGBTI people. A declaration of principles will be established expressing this explicit and firm commitment. The commitments made regarding LGBTI people will be communicated to auxiliary companies, suppliers, and subcontractors. Access to employment. In personnel selection and hiring processes, real and effective equality will be guaranteed among all candidates, regardless of their identity or sexual orientation. To this end, the following measures are established: – It will be guaranteed that the access, selection, and hiring processes do not contain discriminatory elements based on sexual orientation and identity. – All job postings published will be written in inclusive language. – People participating in the selection processes will have adequate training to avoid any bias or stereotypes based on gender, sexual orientation or identity, or sexual characteristics. – Collaborations may be established with entities that promote the labor market integration of LGBTI people. Professional Classification and Promotion. Equal opportunities for LGBTI workers in professional development and promotion will be guaranteed. Training, awareness-raising, and inclusive language. The training provided will take into account the principle of equal opportunities and non-discrimination against LGBTI people across the board. Companies are required to: – Incorporate training activities aimed at the entire workforce. – Inform and disseminate information about all of these planned LGBTI measures among the entire workforce. – Training on sexual and gender diversity. – Carry out awareness-raising activities or workshops for the workforce. – Disseminate basic definitions and concepts on sexual, family, and gender diversity. Diverse, safe, and inclusive work environments. Safe and inclusive work environments will be promoted. The choice of workwear sizing will be facilitated. Protocol for action against harassment and violence against LGBTI people. (Annex XVIII) Companies that do not have such a protocol, and have more than fifty employees included within the scope of this agreement, will be subject to the following protocol contained in Annex XVIII of this agreement. Companies must inform all staff about the protocol for the prevention of harassment, as well as about the procedure for filing a complaint. ANNEX XVIII Protocol for action against harassment and violence against LGBTI people Scope of application. The protocol will apply to companies with more than fifty employees. Companies with fewer employees than the number indicated above may apply this protocol, if they deem it appropriate. Companies that have established a general protocol against harassment that provides measures for LGBTI people are excluded from the provisions of the previous letter. Guiding principles and guarantees of the procedure. In the internal procedures for dealing with situations of harassment based on sexual orientation, identity, and gender expression, the following guiding principles and procedural guarantees apply: – Agility, diligence, and promptness in the investigation and resolution of the reported conduct. – Respect and protection of the privacy and dignity of those affected. – Confidentiality. – Sufficient protection for the victim against possible retaliation. – Adversarial action to ensure an impartial hearing and fair treatment for all affected parties. – Restitution for victims: If the harassment resulted in a change in the victim's working conditions, the company must reinstate them to their previous conditions, if requested. – Prohibition of retaliation: Any act constituting retaliation is expressly prohibited and will be declared void. – Dissemination of the protocol: The parties agree on the importance of general awareness of this protocol. Timeframes for the procedure. The procedural deadlines, unless established by each company, may not exceed thirty working days, extendable if exceptional causes or circumstances arise, from the date of their initiation. During the procedure, the affected person will be granted a hearing period to present their arguments and submit any documents and evidence they deem appropriate. Procedure for action. - The procedure is initiated by a complaint filed by the affected person. - If the complaint is not filed directly by the affected person, their express consent must be included. - The affected person may request the presence of a member of the workers' legal representation. - The person or persons in charge of the investigation process will be designated by the company. - Within a maximum period of twenty-one working days, extendable if exceptional causes or circumstances arise, from the date the complaint is issued, a binding report must be issued in one of the following ways: Resolution of the procedure. In resolving the procedure, the necessary action measures will be taken into account the evidence, recommendations, and intervention proposals contained in the report issued following the appropriate investigation. Information. If complaints have been filed regarding harassment based on the sexual orientation, identity, and gender expression of LGBTI individuals, the company will inform its internal equality plan monitoring body every six months for statistical purposes. FULL TEXT OF STANDARD 1. Preamble. The negotiating parties consider Human Rights to be a fundamental premise. Respect for diversity and the recognition of equality and non-discrimination based on any individual condition and, in particular, based on sex, sexual orientation or identity, gender expression, or sexual characteristics, constitute a central axis of action, transversal in nature, and the backbone of the diversity and inclusion strategy, to guarantee the right to real and effective equality of lesbian, gay, trans, bisexual, and intersex (hereinafter, LGBTI) individuals. 2. Legal Framework. In line with the above, and in accordance with the provisions of article 15 of Law 4/2023, of February 28, for the real and effective equality of trans people and for the guarantee of the rights of LGTBI people, developed by Royal Decree 1026/2024, of October 8, this additional provision includes, in an articulated manner, the planned set of measures that are agreed and established, establishing the necessary mechanisms to promote the right to real and effective equality of LGTBI people, protecting equal treatment and non-discrimination based on sexual orientation and identity, gender expression or sexual characteristics of the same. 3. Participating parties. The aforementioned measures, described below, have been agreed upon through collective bargaining, with legal representation of the workers, as provided for in Article 15 of Law 4/2023, of February 28, on the real and effective equality of trans people and the guarantee of the rights of LGBTI people, and Articles 4, 5, and 6 of Royal Decree 1026/2024, which implements the aforementioned law. The privacy of the workers has been respected and guaranteed at all times in the aforementioned negotiation of the planned measures. In this regard, they subscribe to and sign this planned set of measures for the equality and non-discrimination of LGBTI people in the sector, which will become an integral and inseparable part of this agreement. 4. Purpose of the measures. These measures are framed and integrated within the framework of respect for human rights, diversity, equality, and non-discrimination. These measures establish and implement a planned, organized, and cross-cutting set of measures and resources in the sector to which the agreement applies. These measures aim to achieve real and effective equality for LGBTI people through workforce awareness and training, as well as the dissemination of good practices that promote and foster real and effective equality and contribute to the prevention of workplace harassment and violence. Companies will also have a protocol in place to eradicate all behaviors that may be considered workplace harassment against workers, including LGBTI people, promoting a free and healthy work environment that guarantees human dignity and equality, and also eradicating all types of violence, including sexual violence. In conclusion, the measures are developed within the framework of the following lines of action: – Prevent, correct, and eradicate all types of discrimination in access to employment, working conditions, professional advancement, training, etc. – Promote and guarantee equal treatment and opportunities for LGBTI people. – Commitment to contribute to the full integration of all workers, regardless of their sexual orientation or identity, gender expression, or sexual characteristics. – Training and awareness-raising among staff and dissemination of the agreed measures: raising staff awareness in this area is an essential measure. Therefore, the sector's commitment to real and effective equality, as well as to non-discrimination against workers, regardless of their sexual orientation or identity, gender expression, or sexual characteristics, is made public. 5. Scope. These measures will have the following scope of application: – Subjective or personal scope: These planned measures will be mandatory for all companies in the sector that, within the scope of application of this agreement, have more than fifty employees on their payroll, and for all employees to whom it applies. Companies with fewer employees than the number indicated above may apply, if they deem it appropriate, the planned measures contained in Annex XVII, as well as the protocol contained in Annex XVIII. – Territorial scope: The agreed planned measures will be applied throughout the territory of the Spanish state. – Temporal scope or validity: The agreed planned measures will have the same validity as this agreement. It will enter into force on the day following its publication in the "Official State Gazette". The planned and agreed measures to achieve the objective of real and effective equality for LGBTI workers are contained in Annex XVII of this agreement. «ANNEX XVII Planned and agreed measures to achieve real and effective equality for LGBTI people First. Equal treatment and non-discrimination clauses. Equal treatment and non-discrimination based on sexual orientation, identity, gender expression, or sexual characteristics of LGBTI people will be guaranteed in all working conditions, always applying them in accordance with the principle of equal opportunities and non-discrimination. An inclusive corporate culture will be promoted, fostering respect for diversity and expressly including respect for sexual orientation or identity, gender expression, and sexual characteristics, as well as the elimination of all forms of discrimination against LGBTI people. A declaration of principles will be established expressing the explicit and firm commitment not to tolerate any type of discriminatory practice within the company based on sexual orientation and identity, as well as gender expression and/or sexual characteristics. The commitments assumed in relation to LGBTI people will be communicated to auxiliary companies, suppliers, or subcontractors. Second. Access to employment. In personnel selection and hiring processes, real and effective equality will be guaranteed among all candidates, regardless of their identity, sexual orientation, gender expression, or sexual characteristics. To this end, the following measures are established: – Access, selection, and hiring processes will be guaranteed to be free of discriminatory elements based on sexual orientation, identity, or gender expression, with special attention to transgender people as a particularly vulnerable group, prioritizing the training and suitability of the individual for the position, regardless of their sexual orientation or gender expression. – All published job offers will be written in inclusive language and meet the necessary requirements for the position. – Those participating in the selection processes will have appropriate training to avoid any bias or stereotypes based on gender, sexual orientation, identity, or sexual characteristics. Interviews will be conducted without mentioning the personal or family circumstances of the interviewees, which are not relevant to the selection process. – Collaborations may be established with organizations that promote the employment of LGBTI people. Third. Professional Classification and Promotion. Equal opportunities for LGBTI workers will be guaranteed in professional development and promotion, for which objective criteria will be followed. Fourth. Training, awareness-raising, and inclusive language. The principles of equal opportunities and non-discrimination against LGBTI people will be taken into account in a cross-cutting manner in the training provided. Companies are required to: – Incorporate training activities aimed at the entire workforce, including middle management, executive positions, and employees responsible for managing people and human resources, including: a glossary of definitions and basic concepts on sexual, family, and gender diversity; a guide to the use of inclusive language; and a protocol for preventing, detecting, and responding to discriminatory harassment or violence based on sexual orientation and identity, gender expression, and sexual characteristics. – Inform and disseminate among the entire workforce about all of these planned LGBTI measures. – Training on sexual and gender diversity for those responsible for reporting channels. – Carry out awareness-raising activities or workshops for the workforce on topics such as the harassment prevention protocol; discrimination-free and inclusive environments; equal treatment and non-discrimination. – Promote the use of inclusive language and audiovisual material in company communications. – Disseminate the basic definitions and concepts on sexual, family, and gender diversity contained in Law 4/2023, of February 28, for the real and effective equality of trans people and for the guarantee of the rights of LGBTI people, and disseminate them to the entire workforce. Fifth. Diverse, safe, and inclusive work environments. Safe and inclusive work environments will be fostered to prevent situations of harassment and violence at work. Employees will be facilitated to choose the size of workwear and, whenever possible, PPE, without assuming their preference based on their gender. Possibility of including questions regarding discriminatory harassment or violence based on sexual orientation, gender identity, gender expression, and sexual characteristics in company-conducted work environment surveys and psychosocial risk surveys. Sixth. Protocol for action against harassment and violence against LGBTI people. Companies that have a general protocol against harassment and violence that provides measures for LGBTI people, or specifically expands it to include them, will be subject to this protocol. Companies that do not have such a protocol and have more than fifty employees included within the scope of this agreement will be subject to the protocol contained in Annex XVIII of this agreement. Companies with fewer employees than the aforementioned number may apply, if they deem it appropriate, the protocol contained in Annex XVIII. Companies must inform all employees about the protocol for preventing harassment, as well as the procedure for filing a complaint. Seventh. Leave and social benefits. Full respect for family diversity will be guaranteed, as well as equal access to permits, social benefits, and legally or conventionally recognized rights, without discrimination based on sexual orientation, identity, and gender expression, including for transgender individuals. Marriage and legally registered common-law partnerships will be treated equally, with full respect for family diversity, taking into account the existence of different family models. Eighth. Disciplinary Regime. Behavior that violates the sexual freedom, sexual orientation, identity, and gender expression of employees will not be tolerated. Should such behavior occur, the disciplinary regime will be applied as provided and regulated in this agreement. Ninth. Confidentiality. Given the nature and special protection afforded by data relating to sexual identity or orientation and gender expression, the company will treat such data with the utmost confidentiality and secrecy, exercising extreme rigor and prudence in the processing and management of such data, using it exclusively for those matters where it is essential to do so. All persons involved in the management and processing of such data shall undertake to treat such information confidentially.» «ANNEX XVIII Protocol for action against harassment and violence against LGBTI persons I. Declaration of principles. The dignity of the person, their freedom in its most comprehensive sense, the free development of personality, the right to privacy, physical and moral integrity, the principle of equality and non-discrimination based on any personal or social condition or circumstance, together with the rest of the rights thus recognized, make up the set of fundamental rights that must be respected in accordance with the Spanish Constitution. The scope of protection is multi-level since the European Union has approved various regulations with the aim of protecting workers who are likely to be discriminated against on the basis of their sexual orientation or identity. It is necessary to refer to Directive 2007/78/EC on equal treatment in employment, which includes sexual orientation among the grounds for non-discrimination, Directive 2006/54/EC, which prohibits discrimination in employment, and Directive 2004/38/EEC on free movement, which enshrines non-discrimination. Internally, the Workers' Statute enshrines respect for human dignity, privacy, and fair treatment, taking into account the due consideration of workers and including protection against verbal or physical abuse of a sexual nature, harassment based on racial or ethnic origin, religion or belief, disability, age, or sexual orientation. The recent Royal Decree 1026/2024, of October 8, which develops the planned set of measures for equality and non-discrimination of LGBTI people in companies, establishes in Annex II the obligation to draw up an action protocol against harassment, which is fulfilled by this text. The explicit and firm commitment is expressed not to tolerate within the company any type of discriminatory practice considered harassment based on sexual orientation, identity, and gender expression, and any conduct of this nature is expressly prohibited. II. Scope of application. a) The protocol will apply to companies with more than fifty employees, regardless of the legal relationship that binds them to the company, and provided that they carry out their activity within the organizational scope of the company. Companies with fewer employees than the number indicated above may apply this protocol, if they deem it appropriate. b) Companies that have established a general protocol against harassment that provides measures for LGBTI people, or expands it to include them, or a specific protocol for action against harassment and violence against them, are excluded from the provisions of the previous letter. c) The corresponding protocols, mentioned in the previous letters, will also apply to those applying for a job, to the company's staff, suppliers, clients, and visitors. III. Definitions. The definitions contained in Article 3 of Law 4/2023, of February 28, for the real and effective equality of trans people and for the guarantee of the rights of LGTBI people are included: a) Direct discrimination: a situation in which a person or group of which they are part is, has been, or could be treated less favorably than others in a similar or comparable situation due to their sexual orientation and sexual identity, gender expression, or sexual characteristics. The denial of reasonable adjustments to people with disabilities will be considered direct discrimination. For this purpose, reasonable adjustments are understood to be the necessary and appropriate modifications and adaptations to the physical, social, and attitudinal environment that do not impose a disproportionate or undue burden, when required in a particular case in an effective and practical manner, to facilitate accessibility and participation and guarantee that people with disabilities can enjoy or exercise all rights on an equal basis with others. b) Indirect discrimination: occurs when an apparently neutral provision, criterion, or practice causes or may cause one or more people a particular disadvantage with respect to others on the basis of sexual orientation, sexual identity, gender expression, or sexual characteristics. c) Multiple and intersectional discrimination: multiple discrimination occurs when a person is discriminated against, simultaneously or consecutively, for two or more of the reasons provided for in this law, and/or for another cause or causes of discrimination provided for in Law 15/2022, of July 12, on comprehensive equal treatment and non-discrimination. Intersectional discrimination occurs when several causes included in the previous section concur or interact, generating a specific form of discrimination. d) Discriminatory harassment: any conduct carried out on the basis of any of the causes of discrimination provided for in this law, with the objective or consequence of violating the dignity of a person or group to which they belong and of creating an intimidating, hostile, degrading, humiliating, or offensive environment. e) Discrimination by association and discrimination by mistake: Discrimination by association exists when a person or group to which they belong, due to their relationship with another person who suffers from any of the causes of discrimination based on sexual orientation and identity, gender expression, or sexual characteristics, is subjected to discriminatory treatment. Discrimination by mistake is discrimination based on an incorrect assessment of the characteristics of the person or persons discriminated against. f) Affirmative action measures: differences in treatment aimed at preventing, eliminating, and, where appropriate, compensating for any form of discrimination or disadvantage in its collective or social dimension. Such measures shall be applicable as long as the situations of discrimination or the disadvantages that justify them persist and must be reasonable and proportionate in relation to the means for their development and the objectives they pursue. g) Intersexuality: the condition of those persons born with biological, anatomical, or physiological characteristics, sexual anatomy, reproductive organs, or chromosomal pattern that do not correspond to the socially established notions of male or female bodies. h) Sexual orientation: Physical, sexual, or emotional attraction to a person. Sexual orientation may be heterosexual, when one feels physical, sexual, or emotional attraction only toward persons of the opposite sex; homosexual, when one feels physical, sexual, or emotional attraction only toward persons of the same sex; or bisexual, when one feels physical, sexual, or emotional attraction toward persons of different sexes, not necessarily at the same time, in the same way, to the same degree, or with the same intensity. i) Sexual identity: Internal and individual experience of sex as each person feels and defines it, which may or may not correspond to the sex assigned at birth. j) Gender expression: Manifestation that each person makes of their sexual identity. k) Trans person: Person whose sexual identity does not correspond to the sex assigned at birth. l) LGBTI family: A family in which one or more of its members are LGBTI people, including homoparental families, that is, those made up of lesbian, gay, or bisexual people with minor offspring who are permanently under care, guardianship, or parental authority, or with adult offspring with disabilities in their care. m) LGBTIphobia: Any attitude, behavior, or discourse of rejection, repudiation, prejudice, discrimination, or intolerance towards LGBTI people for being LGBTI, or for being perceived as such. n) Homophobia: Any attitude, conduct, or speech that rejects, repudiates, prejudices, discrimination, or intolerance toward homosexual persons for being homosexual, or for being perceived as such. o) Biphobia: Any attitude, conduct, or speech that rejects, repudiates, prejudices, discrimination, or intolerance toward bisexual persons for being bisexual, or for being perceived as such. p) Transphobia: Any attitude, conduct, or speech that rejects, repudiates, prejudices, discrimination, or intolerance toward trans persons for being bisexual, or for being perceived as such. q) Induction, order, or instruction to discriminate: Any inducement, order, or instruction to discriminate for any of the reasons established in this law is discriminatory. The inducement must be specific, direct, and effective in causing another person to engage in discriminatory behavior. IV. Guiding principles and procedural guarantees. In the internal procedures for dealing with situations of harassment based on sexual orientation, identity, and gender expression, the following guiding principles and procedural guarantees apply: – Agility, diligence, and promptness in the investigation and resolution of the reported conduct, which must be carried out without undue delay, respecting the deadlines established for each part of the process. – Respect and protection of the privacy and dignity of the affected individuals, offering fair treatment to all involved. – Confidentiality: Those involved in the procedure are obliged to maintain strict confidentiality and confidentiality; they will not transmit or disclose information about the content of the complaints filed, under investigation, or resolved. – Sufficient protection for the victim against possible retaliation, taking into account the care of their safety and health, taking into account the possible physical and psychological consequences arising from this situation and especially considering the work circumstances surrounding the person attacked. – Adversarial protection to guarantee an impartial hearing and fair treatment for all affected individuals. – Restitution for victims: If the harassment resulted in a change in the victim's working conditions, the company must reinstate the victim to their previous conditions, if requested. – Prohibition of retaliation: Any act constituting retaliation, including threats of retaliation and attempted retaliation, against individuals who file a complaint through the appropriate means, appear as witnesses, or assist or participate in an investigation into harassment, is expressly prohibited and will be declared void. – Dissemination of the protocol: The parties agree on the importance of general awareness of this protocol. Therefore, the companies undertake to disseminate and facilitate this protocol among their employees. This entire procedure is without prejudice to the provisions set forth in Law 2/2023, of February 20, regulating the protection of individuals who report regulatory violations and the fight against corruption, in their respective personal and material scope. V. Time limits of the procedure. The procedural deadlines, unless established by each company, may not exceed thirty working days, which may be extended if exceptional causes or circumstances arise, from the date of their initiation. During the procedure, the affected person shall be granted a hearing period to present their arguments and submit any documents and evidence they deem appropriate. VI. Procedure for action. a) The procedure shall be initiated by a complaint filed by the affected person or by whomever they authorize, before the person or persons in charge of the investigation process, or through the complaints channel established by the company. If the complaint is not filed directly by the affected person, their express and informed consent must be included to initiate the protocol procedures. The affected person may request the presence of a member of the legal representation of the workers at their workplace in the statement they provide during the investigation process. b) The person or persons in charge of the investigation process shall be designated by the company; In the event that the company has already designated individuals to conduct inquiries or investigations, in relation to other harassment protocols, the company may agree that these individuals will undertake the investigation process. Individuals who are related by blood or marriage, or who have a close friendship or manifest enmity with any of the individuals affected by the investigation, or who have a direct or indirect interest in the investigation process, may not be in charge of the investigation. c) Upon receipt of the complaint, as soon as possible, taking into account the circumstances of the case, the application of this protocol will be assessed and, where appropriate, the adoption of precautionary or preventive measures. d) Within a maximum period of twenty-one working days, which may be extended if exceptional causes or circumstances arise, from the date the complaint was issued, a binding report must be issued in one of the following ways: i) Confirm evidence of harassment covered by the protocol and, if appropriate, propose the opening of disciplinary proceedings. ii) If no evidence of harassment covered by the protocol is found. The report must include, at a minimum, a description of the events, the methodology used, an assessment of the case, the results of the investigation, and the precautionary or preventive measures taken. VII. Resolution of the procedure. In resolving the procedure, the necessary action measures will be taken, taking into account the evidence, recommendations, and intervention proposals contained in the report issued after the appropriate investigation. If there is evidence of harassment based on sexual orientation, identity, or gender expression, disciplinary proceedings will be initiated for proven harassment, corrective measures will be requested, and, if appropriate, protective measures will continue to be applied to the victim. If there is no evidence of harassment, the complaint will be closed. VIII. Information. If complaints are filed regarding harassment based on the sexual orientation, identity, and gender expression of LGBTI individuals, the company will inform its internal equality plan monitoring body, if such a body exists within the company, on a semi-annual basis, for statistical purposes, of the total number of complaints and whether or not evidence of harassment has been found in them, while respecting the confidentiality of the affected individuals. Likewise, the company will inform, in the same terms as the previous paragraph, the legal representatives of the employees at the affected individuals' workplace. In accordance with the conference we attended as a professional firm yesterday held by the National Construction Confederation, we are informing you of the latest developments regarding the Construction Sector Pension Plan. It goes without saying that all of this will entail a considerable new workload for users of the Aporta   Vida Caixa Platform, whether the company itself, or a tax or labor consultancy.

• Entry into force: 01-02-24. From that date, the monthly proportional share of the contributions established in the agreement will be included in the employees' payroll. The contribution will be paid at the end of the month and charged to the company account on the 22nd or the previous business day. Arrears from January 1, 2022 to January 31, 2024 may be paid by the deadline of April 30, 2024 in a single payment. The contribution of employees who are not registered with the company as of February 1, 2024, will not be entered.
• This contribution is part of the salary and is paid as "salary in kind" and is mandatory for all active employees as of 01-02-24, that is, the company is required to make the payment and the employee cannot renounce it or request its payment directly from it (the payment or contribution is made to VIDA CAIXA)
• The company will make the payment exclusively to VIDA CAIXA (not to any other bank) through the Aporta   Vida Caixa platform.
• The Plan covers retirement, death and Permanent Disability.
• The Plan is not taxed
• The Plan does contribute to Social Security
• It must be included in the Treasury form 345 annually
• As it constitutes salary, it is taken into account when calculating dismissal compensation.
• In the event of Temporary Disability, maternity, paternity, breastfeeding and reduced working hours while caring for children, payments must continue
• Payments cease in the event of leave of absence, termination of employment and retirement.
• The contribution manager is exclusively VIDA CAIXA.
• The contribution will be made through the Aporta   Vida Caixa platform. To do so: - 1. You must register as a user on the Aporta   Vida Caixa platform (this can be the company itself, the tax consultancy, or the employment consultancy). - 2. To register the company on the Aporta   Vida Caixa platform, you will need a tax identification number (CIF) or national identity document (DNI) and current account ownership. - 3. All employees must be registered on the Aporta   Vida Caixa platform. All employees must have their address, email address, and mobile phone number. - 4. All contributions from each and every employee must be submitted monthly to the Aporta   Vida Caixa platform.
• In the event of subcontracting works or services, the main company is jointly and severally liable for one year following the completion of the contract.

INFORMATION NOTE JUNE 2025

SUBJECT: The European Committee of Social Rights (ECSR) of the Council of Europe states that in Spain, compensation for unfair dismissal is not sufficiently dissuasive for employers. The ECSR ruling confirms that the compensation is not sufficiently high, considering the reinstatement of the dismissed worker based on the characteristics of each case. The European Committee of Social Rights (ECSR) of the Council of Europe has ruled in favor of Spanish unions and states that Spain “violates” the European Social Charter with regard to compensation for unfair dismissal, since its amount is not sufficiently dissuasive for employers. Thus, the ruling issued by the ECSR confirms that the compensation set by Spanish legislation “is not sufficiently high to repair the damage suffered by the worker in some cases and is not dissuasive for employers.” Consequently, according to the ECHR, the actual harm suffered by the dismissed worker may not be adequately taken into account, given the specific characteristics of each case, giving rise to the possibility of obtaining additional compensation based on the harm that may be caused to the worker. Furthermore, the European Committee of Social Rights considers the possibility of compulsory reinstatement of an employee in the event of dismissal as one of the remedies available to national courts in cases of unfair dismissal. Therefore, the Committee believes that national courts should be able to assess the suitability of reinstatement. The Second Vice President of the Government and Minister of Labor and Social Economy, Yolanda Díaz, has confirmed that she will open a social dialogue table to address the regulation of unfair dismissal after the European Committee of Social Rights of the Council of Europe ruled that Spanish legislation "violates" the European Social Charter due to the insufficient compensation granted to workers in the event of unfair dismissal. NOTE: In light of the above, this professional office insists once again that it is extremely important that in any dismissal that is going to be carried out, even if the company is willing to acknowledge that it is unfair, it is absolutely necessary to elaborate on the reasons for it. These must be specific facts and, if possible, the date on which they occurred, even if only approximate. All of this is to minimize unwanted risks, such as additional compensation or even an unfair dismissal.