LOEWE

            Alert Policy

            1. Introduction

            The Loewe Group is committed to complying with all applicable laws and regulations and to conducting its business on the basis of the values and rules set out in the LVMH Code of Conduct, the internal guidelines, principles and policies of the LVMH Group, the Loewe Group(Under article 42 of the Code of Commerce, Loewe, S.A., Manufacturas Loewe, S.L. and Loewe Hermanos, S.A. form the Loewe Group. Loewe, S.A. is the dominant company.) and of any company of the Loewe Group.

            The Loewe Group encourages open communication and dialogue. All individual included in the scope of application of this policy are invited to use the Loewe Group internal system of information described in this policy.


            2. Scope of application

            This document contains the (i) policy that defines the general principles applicable to the internal system of information (the “Loewe Group ISI”) and informant protection and (ii) the procedure to manage the information received applicable at the Loewe Group in Spain (the “Loewe Group Alert Policy” or “Alert Policy”), comprised by Loewe, S.A., Manufacturas Loewe, S.L. and Loewe Hermanos, S.A. (all the “Loewe Group”), part of the LVMH Group.

            The Loewe Group Alert Policy applies to the following individuals that have obtained information regarding potential infractions in the framework of his/her relationship (employment/professional, as applicable to each case) with a company of the Loewe Group (the “Possible Reporter/s”):

            a. Employees of a company of Loewe Group.

            b. Self-employed rendering services for a company of the Loewe Group.

            c. Shareholders and members of the administration body, management and supervising bodies of a company of the Loewe Group, including non-executive members.

            d. Any person that works for or under the supervision and direction of contractors, subcontractors, and providers of a company of the Loewe Group.

            e. Informants that communicate or reveal publicly information about infractions obtained in the framework of a terminated employment relationship with companies of the Loewe Group, volunteers, interns, employees in training periods regardless of the fact that they receive or not a remuneration, as well as prospective employees whose employment relationship has not yet started where the information is obtained during the selection process or the pre-contractual negotiation.

            The Loewe Group ISI is applicable for the Possible Reporters to report any breach of the LVMH Code of Conduct and internal guidelines, principles and policies of the LVMH Group, Loewe Group and anycompany of the Loewe Group, and the following breaches (all defined as the “Reportable Breach/es”; the reporting of Reportable Breaches is defined as “Alert”):

            (i) Any acts or omissions that may constitute infringements of European Union law provided that:

            (1) They fall within the scope of the acts of the European Union listed in the Annex to Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons reporting breaches of Union law, irrespective of the qualification of such acts or omissions by the domestic legal system;

            (2) They affect the financial interests of the European Union as referred to in Article 325 of the Treaty on the Functioning of the European Union (TFEU), or

            (3) They affect the internal market, as referred to in Article 26(2) of the TFEU, including infringements of the European Union rules on competition and aid granted by States, as well as infringements relating to the internal market in connection with acts that infringe the corporate tax rules or practices intended to obtain a tax advantage that distorts the object or purpose of the legislation applicable to corporate taxation.

            (ii) Actions or omissions that may constitute criminal offences and serious or very serious administrative infringement. In any case, this shall be understood to include all those criminal offences and serious or very serious administrative offenses that imply a financial loss for the Treasury and the Social Security.

            For illustrative purposes, this Alert Policy is also applicable to report criminal offences and other conducts against sexual freedom and moral integrity in the workplace (focusing specifically on sexual harassment or harassment due to sex), LGTBI discrimination, specifically breaches of the protocols in place at the companies of the Loewe Group to prevent these situations, or infringements of occupational health and safety regulations.


            3. Purpose of the Alert Policy

            The purpose of this Alert Policy is to describe how the reports can be filed and should be processed within the Loewe Group, pursuant to and in compliance with Law 2/2023, February 20, regulating the protection of the individual informing about infractions of laws and the fight against corruption (“Law 2/2023”).


            4. Responsible of the Loewe Group ISI

            The person appointed by Loewe, S.A. as responsible of the management of the Loewe Group ISI is Paula Álvarez Álvarez (the “Responsible of the Loewe Group ISI”). As such responsible, this person is in charge of receiving the reports filed within the Loewe Group ISI and of processing them according to the approved procedure to manage reports within the Loewe Group ISI, explained in section 6.


            5.Reporting channels

            Reports can be made through either the local reporting channels (section 5.1) or the LVMH Alert Line (section 5.2) (the “Reporting Channels”).


            5.1. Local reporting channels

            Reports should be filed to the following email address ethicscommittee@loewe.es (the reports can be sent in writing or as an audio message) or phone number +34 912 041 300, asking to be directed to the Responsible of the Loewe Group ISI. The local reporting channels are directly managed by said Responsible of the Loewe Group ISI.

            If the employee voluntarily chooses to do so, he/she may seek advice and discuss his/her concerns with his/her direct or indirect superior. When it appears from such an exchange that the concern may fall within the scope of this Alert Policy, the superior shall encourage the employee to report it. The employee shall be free to submit any information he/she deems appropriate at any time, in accordance with the provisions of this Policy.


            5.2. LVMH Alert Line

            Reports can also be made by using the “LVMH Alert Line”, the online interface implemented by the LVMH Group at worldwide level.

            The LVMH Alert Line can be accessed directly at https://alertline.lvmh.com, from the LVMH website and Loewe website.

            This interface offers a fully confidential and secure way to report ethical concerns related to the LVMH Group and to exchange information through a secured postbox. It also allows the author of a report to file a report anonymously (if they wish so).

            Under article 6 of Law 2/2023, LVMH Holding is providing the service of the management of the reception of reports of the Loewe Group companies through the LVMH Alert Line. The LVMH Alert Line is hosted and operated by an external service provider specialized in the processing of alerts, whose servers are located within the European Union and which is bound by strong confidentiality and security commitments. The external service provider’s employees are not involved in the processing of reports and do not have access to the information exchanged via the interface.


            6. Key steps ofthe procedureto managereports


            6.1. Submission of the Report

            6.1.1. Ways to submit a report

            Any Possible Reporter may file a report (the “Reporter”) in writing or orally, or both, through the local reporting channels above defined.

            The oral report may be filed via the above phone number or sending a recorded audio message through to the above email address. By request of the Reporter, the oral report can also be filed in a meeting within 7 calendar days from the Reporter’s request.

            When done in a meeting or by phone, the communication will be recorded in one of the following ways and the Reporter will be reminded of his/her data protection rights:

            (i) Through the recording of the conversation in a secure, lasting and accessible format;

            (ii) Through the transcript of the complete and exact conversation. The informant will have the right to check, amend and accept with his/her signature the transcription of the conversation.

            Reporters can choose to file a report anonymously. However, Reporters are encouraged to identify themselves since anonymity may make the investigation process more complex. In addition, an anonymous informant cannot be afforded the protection established by Law 2/2023 and referenced in section 9 in the terms defined in it.

            Reporters are encouraged to provide contact details such as a domicile, email address or safe place to receive notification in order to enable the exchange of information. Otherwise, the author of the report will not be able to be informed on the progress of the evaluation of their report.


            6.1.2. Content and supporting documents

            Reporters should describe the facts they are reporting as clearly as possible, providing complete and precise information and documents to facilitate the processing of their report, it being noted that such information/documents may be used for the purpose of the investigation.

            ·      Reporters can communicate documents, files and information at any stage of the evaluation process.

            ·      Not providing enough information may result in some delay in processing the report.

            The report should not provide details about the private life of anyone or personal appreciation, unless strictly necessary and relevant.


            6.2. Acknowledgement of receipt

            When the report is received through any of the Reporting Channels, the Responsible of the Loewe ISI will send to the Reporter a written acknowledgement of receipt within seven (7) calendar days of submission of the report, unless no contact information or means of contact has been provided, or doing so can compromise confidentiality.

            Acknowledgement of receipt of the report does not imply it is admissible (see section 6.4).


            6.3. Assignment of the report

            6.3.1. Coordinator responsible for handling the report

            When the report is received, the Responsible of the Loewe ISI will name a person in charge of evaluating the report (the “Coordinator”), making sure there is no conflict of interest (A conflict of interest may occur when personal interests impair or appear to impair the ability of an employee to perform his or her responsibilities in the best interests of the Loewe Group. The personal interests of employees include any direct or indirect, financial or non-financial benefit for the employees themselves or for members of their family, for their friends or personal relations, or for organizations with which they or their family, friends or personal relations have or have had a business relationship.)or a situation that may affect their impartiality. The Coordinator will primarily be the Ethics & Compliance Correspondent at the company of the Loewe Group, save for the cases explained below.


            6.3.2. Cases where the Report may be handled by the Group

            As a general rule, the report is processed by the Coordinator of the relevant company of the Loewe Group, as described above (section 6.3.1).

            By exception and unless expressly objected by the author of the report, the report should be processed by the Group in the following cases:

            - when the allegations involve the Ethics & Compliance Correspondent of the company of the Loewe Group or if there may be a conflict of interest or a situation that may affect their impartiality;

            - when the persons targeted by the report include a member of the Group's Executive Committee, or a member of the company of the Loewe Group Top Management including the Chairman, the Chief Executive Officer, a General Manager, or a member of the CODIR/COMEX;

            - when the report contains allegations of a potential act of Retaliation (as defined in section 9 below) further to a report that was handled by the company of the Loewe Group.

            In such cases, the LVMH Group Privacy Ethics & Compliance Director would become the Coordinator as soon as he/she receives the report and the LVMH Investigation Committee (committee set up at Group level and made up of the Group General Counsel, Group Talent Management Director and Group Privacy Ethics & Compliance Director) would handle the report.

            In the event where the allegations would have been made against one of the members of the LVMH Investigation Committee or if there may be a conflict of interest or a situation that may affect their impartiality, the report should be handled by the remaining two members.

            In addition, the Group should be involved in the processing of the report, in coordination with the company of the Loewe Group, in the following cases:

            - when it is clear that the allegations contained in the report could cause major damage to the reputation of the LVMH Group as a whole (most sensitive cases);

            - or whenever the company of the Loewe Group wishes to involve the LVMH Group, notably because the report involves a certain level of complexity.


            6.4. Assessment of the admissibility of the report by the Coordinator

            After the acknowledgement of receipt is sent and before any further steps are taken, the Coordinator (as identified above, section 6.3) assesses the admissibility of the report to determine whether it qualifies as an Alert covered by this Alert Policy.


            6.4.1. Criteria of admissibility and qualification as Alert

            For the information received through the Reporting Channels to qualify as an Alert, the following criteria must be met:

            (iii) the reported facts must have occurred or be very likely to occur within any company of the Loewe Group or in relation to its activities;

            (iv) the Report shall contain allegations of existing or reasonably suspected misconducts related to Reportable Breach; and

            (v) the author of the report is a Possible Reporter.

            The Reporter may be asked to provide further information so the admissibility of the report can be assessed.

            Any false report or containing false statements made knowingly and deliberately, any disclosure of misleading information, or any bad faith act, could lead to disciplinary or legal action in accordance with applicable laws.


            6.4.2. Information of the author of the report

            The author of the report is informed of whether the report qualifies as an Alert under the present Alert Policy or not. In the latter case, the Reporter is informed of the reasons why the report was deemed inadmissible and, where possible, is advised on possible alternate avenues for their concern to be addressed.


            6.5. Investigation process

            Once the report has qualified as an Alert, it gives rise to an adequate and fair investigation which will be carried out within a reasonable timeframe.

            The purpose of the investigation is:

            - to establish whether the allegations set out in the Alert are accurate and substantiated;

            - to collect potential evidence;

            - to ultimately determine what actions should be taken to remedy the reported facts, when necessary.

            At any stage of the investigation process, the author of the report may be asked to provide further information necessary to establish whether the allegations are accurate and substantiated.


            6.5.1. Setting up of an investigation team

            The Coordinator sets up an investigation team to carry out the investigation.

            Members of the investigation team are selected from the relevant departments (Finance, Internal Control, IT...), for their impartiality (Members of the Investigation Team who may have a potential conflict of interest will inform the Coordinator as soon as possible.)and their ability to handle the Alert, taking into account the nature and the severity of the allegations.

            3

            Measures are taken to ensure that each member of the investigation team respect the confidentiality of Alerts (see below, section 7).

            In some cases, the investigation team (or the LVMH Investigation Committee) may be assisted by a third party (experts in a specific field and/or legal advisors) in the conduct of the investigation. Such third party shall be provided only with the information strictly necessary in the context of its mission and shall be subject to a confidentiality obligation.

            Members of the Human Resources team of the relevant company of the Loewe Group can assist on the investigation but will not be a part of it and will not have access to personal data contained in the Loewe Group ISI, unless when disciplinary measures may be taken against an employee.


            6.5.2. Principles applicable to the investigations

             

            The key principles to be observed in the conduct of investigations related to an Alert are as follows:

            - Compliance with applicable laws and regulations;

            - Neutrality and impartiality:

            ·      Any investigation is proportional to the nature and the severity of the allegations and the related risks for the relevant company of the Loewe Group and the LVMH Group.

            ·      The person(s) against whom the allegations have been raised has/have the right to be informed about the breaches attributed to him/her and be afforded the opportunity to give his/her/their own version of the facts at the appropriate time to guarantee the adequate investigation.

            ·      Respect of the innocence presumption and the honor of the person(s) against whom the allegations have been raised.

             

            - Confidentiality as per section 7 below.

            - Track-recording of the steps taken to investigate. Only strictly necessary and relevant information regarding the handling of the Alert should be collected, in compliance with the applicable data protection laws.

            - Reporting to the Public Prosecutor's Office or the European Public Prosecutor's Office, as appropriate, where the facts reported to a company of the Loewe Group may lead it to believe they could constitute a criminal offence following the internal process in the company of the Loewe Group.

            Means that may be put in place for the purpose of investigating the reported allegations may include analyzing emails and video cameras, conducting interviews, requesting the assistance of outside counsels or experts.


            6.6. Closing of the Alert - Investigation report and follow-up actions

            After enough information have been gathered for the investigation purposes, the Alert can be closed.


            6.6.1. Investigation report

            An investigation report is drawn up, containing the reasoned, factual conclusions reached by the investigation team regarding the reported allegations.

            If it is considered that the allegations are inaccurate or not sufficiently substantiated, the Alert is closed without any follow-up actions to be taken.

            If it is found that the allegations are substantiated, follow-up actions may be taken.


            6.6.2. Potential follow-up actions

            Where applicable, any follow-up actions must be implemented within a reasonable period of time after the issuance of the investigation report, in coordination with the relevant departments (Human Resources Department, Legal Department, Internal Audit Department, etc.).

            Follow-up actions include any adequate corrective measures taken at company of the Loewe Group or Group level to properly address the consequences of the Alert, including:

            - disciplinary measures;

            - initiation of legal actions or report to an authority;

            - termination of a third party business relationship;

            - dedicated training;

            - awareness-raising campaigns;

            - revision of internal rules or processes.


            6.6.3. Reporting

            Each company of the Loewe Group will have a registry of the Reports received and the internal investigations carried out, preserving, in all cases, the required confidentiality. This registry will not be public and will comply with the rules established in article 26 of the Law 2/2023.

            The Group Privacy Ethics & Compliance Director informs the Group’s top management of the most sensitive cases, preserving the required confidentiality and without infringing the rules of the Law 2/2023.

            Each company of the Loewe Group reports annually statistics of all Alerts that they have processed to the Group Privacy Ethics & Compliance Director who communicates statistics to the Group’s top management and to the Ethics and Sustainable Development Committee of the LVMH Board of Directors.


            7.Information delivered to the persons involved in the Alert


            7.1. Information delivered to the author of the Alert

            If means of contact have been provided, the author of the report will:

            - be provided with regular feedback on the progress of the processing of the Alert, to the extent possible;

            - be provided in writing, within a reasonable timeframe not exceeding three (3) months from the acknowledgement of receipt (or from the elapse of the seven (7) calendar days’ period to acknowledge receipt, when this is not done), timeframe which can be extended for three (3) additional months in cases of special complexity, with information regarding the measures that were taken or that are contemplated in order to evaluate the accuracy of the allegations or, if applicable, regarding the measures taken to remedy the reported facts (and the reasons for these measures); and

            - be informed of the outcome of the evaluation of the Alert once the investigation is concluded, and of the closure of the Alert.

             

            7.2. Information delivered to the persons whose Personal Data is processed in connection with an Alert

            If providing the following information would not prejudice the conduct of the investigation (for instance, regarding the preserving of evidence), any person whose Personal Data (The term “Personal Data” shall have the meaning assigned in the GDPR.) is processed in connection with an Alert (including the person(s) mentioned or targeted by the Alert) should be informed of that fact no more than one (1) month after the beginning of the processing of their Personal Data as part of the Alert process. This information contains all the information required by the General Data Protection Regulation 2016/679 of 27 April 2016, art. 14.

            If providing the information would prejudice the conduct of the investigation, it may be provided at a later stage (i.e. at the latest when the investigation is terminated and the Alert is closed).


            8.Confidentiality

            The Loewe Group is committed to taking all adequate measures to ensure the integrity and confidentiality of E&C Alerts, at all stages of the evaluation process, with respect to:

            - the identity of the author of the Report,

            - the identity of the person(s) targeted by the Alert,

            - the identity of the person(s) mentioned in the Alert, and

            - the facts that were reported and the information that was gathered during the evaluation process.

            Any person having access to such information is bound by an obligation of confidentiality. Any breach of this confidentiality obligation constitutes a very serious infraction and may lead to disciplinary or legal sanctions in accordance with applicable laws.

            As an exception, in the event of a request from a competent judiciary or administrative authority, or where required by applicable laws, such confidential information may be disclosed.

            Any person receiving a report outside the established channels must immediately send it to the Responsible of the Loewe ISI.


            9.Protection of the author ofthe report and guarantee of the absence of Retaliation

            The Loewe Group is committed to taking all adequate measures to protect Reporters and the person assisting them, according to the rules established in the Law 2/2023.

            • Under no circumstances may the Reporter’s identity be disclosed to anyone unless with his/her express agreement (excluding the cases mentioned in section 7 above).
            • Any obstacle to the exercise of the right to report may lead to disciplinary or legal action in accordance with applicable laws.
            • The Loewe Group ensures that no retaliation is taken against the Reporter or any person who assisted him/her, as provided by the law from time to time. The general principles of prohibition of retaliations currently established in Law 2/2023 are defined in sections 9.1 and 9.2 below.

            With respect to external stakeholders, such actions include negative changes to their relationship with the Loewe Group including termination of a contract.

            If anyone believes that they may be subject to retaliation, they must immediately inform the Ethics & Compliance Correspondent or the Group Privacy Ethics and Compliance Director, and those engaging in such act will be appropriately disciplined.


             

            9.1 Conditions for protection

            Under current Law 2/2023, Possible Reporters who report or publicly disclose (Public disclosure shall be understood to mean the making available to the public of information on Reportable Breaches (i) and (ii) section 2 above.)Reportable Breaches (i) and (ii) section 2 above shall be entitled to protection provided that the following circumstances are met:

            (a) they have reasonable grounds to believe that the information referred to is true at the time of the communication or disclosure, even if they do not provide conclusive evidence, and that the said information is a Reportable Breach (i) and (ii) section 2 above,

            (b) the communication or disclosure has been made in accordance with the requirements of this this Policy.

            Expressly excluded from the protection provided for in section 9.1 below pursuant to Law 2/2023 are those persons who communicate or disclose:

            (a) Information contained in communications that have been inadmissible by any internal information channel or for any of the causes provided for in article 18.2.a) of Law 2/2023.

            b) Information linked to claims regarding interpersonal conflicts or affecting only the informant and the persons to whom the communication or disclosure refers.

            c) Information that is already fully available to the public or that constitutes mere hearsay.

            d) Information that relates to acts or omissions that are not Reportable Breaches (i) and (ii) section 2 above.

            Persons who have publicly communicated or disclosed information on Reportable Breaches anonymously but who have subsequently been identified and who meet the above conditions shall be entitled to the protection contained therein.

            For a Possible Reporter who publicly discloses Reportable Breaches (i) and (ii) section 2 above to be afforded the protection one of the two following criteria must be met in addition:

            a) That it has made the communication first through internal and external channels, or directly through external channels, in accordance with this Alert Policy, without appropriate action having been taken thereon within the established time limit.

            b) That it has reasonable grounds to believe that either the breach may constitute an imminent or manifest danger to the public interest, in particular where there is an emergency situation, or there is a risk of irreversible damage, including a danger to the physical integrity of a person; or, in the case of communication through an external information channel, there is a risk of retaliation or there is little likelihood that the information will be dealt with effectively due to the particular circumstances of the case, such as concealment or destruction of evidence, collusion of an authority with the perpetrator of the infringement, or that the authority is involved in the infringement.

            The conditions for protection provided for in the preceding paragraph shall not apply when the person has disclosed information directly to the press in accordance with the exercise of the freedom of expression and truthful information provided for in the Constitution and its implementing legislation.


            9.2 Prohibition of retaliation

            Acts constituting retaliation, including threats of retaliation and attempts of retaliation against persons who submit an Alert are expressly prohibited.

            Retaliation currently means under Law 2/2023 any acts or omissions that are prohibited by law, or that directly or indirectly result in unfavorable treatment that places the persons who suffer them at a particular disadvantage with respect to another in the employment or professional context, solely because of their status as whistleblowers, or because they have made a public disclosure.

            The person whose rights have been harmed as a result of its communication or disclosure, once a two-year period has elapsed, may request protection from the competent authority which, exceptionally and in a justified manner, may extend the period of protection, after hearing the persons or bodies that could be affected. The refusal to extend the protection period must be justified.


            10.Contact

            Any questions or request for information about this Alert Policy must be addressed to the Group Privacy Ethics and Compliance Director via the email address mailto:ethics@lvmh.com or the Ethics & Compliance Correspondent at Loewe in the email mailto:address ethicscommittee@loewe.es.