Digital disconnection protocol

Limiting the use of technology outside working time, to ensure that rest time, leave and holidays or sick leave are respected.

1. Regulations

At Fundació Dénia Ciutat Creativa de la Gastronomía de la Comunidad Valenciana (in advance Fundació Dénia Creativa) we have drawn up this protocol of measures regarding the exercise of the right todisconnection, which expressly implies the disconnection of digital devices, not being obliged in any case toanswer emails, messages and professional calls outside working hours, nor during any type of leave, days offand/or holidays for staff.

The laws on which this protocol is based are:

•  LOPDGDD (Organic Law 3/2018, of 5 December, on the Protection of Personal Data and Guarantee ofDigital Rights).
•  Workers' Statute (Royal Legislative Decree 2/2015, of 23 October, approving the revised text of theWorkers' Statute Law).
•  Telework Law (Royal Decree-Law 28/2020, of 22 September, on teleworking).
• Law31/1995, of 8 November 1995, on the Health ans Safety at Work Act.

2. Scope of application

This protocol shall apply to all persons working in Fundació Dénia Creativa, whatever their professional group and category,regardless of whether they carry out their tasks in person or remotely. Likewise, neither the contractual formnor the working hours shall have any influence.

The  staff  of  Fundació Dénia Creativa undertake to make appropriate use of the technological and computer resourcesmade available by the company, avoiding, as far as possible, their use outside working hours.

3. Objetive

The measures set out in the Protocol shall be aimed at establishing measures to ensure that employees can effectively enjoy their rest and holiday time, and that their personal and family privacy is preserved and that they have a good work-life balance.

4. Acciones de implantación/formación/sensibilización

Action 1

Fundació Dénia Creativa guarantees staff the right to digital disconnection at the end of the working day, irrespective ofthe type of working day, type of contract or any speciftc working conditions and working hours. Pursuant toArticle 88.3 of Organic Law 3/2018, attention is paid to "the cases of total or partial remote work, as well aswork at the employee's home linked to the use of technological tools for work purposes".

For these purposes, all devices and tools likely to maintain the working day beyond the legal limits will be taken intoaccount, in particular: laptops, the company's own mobile applications, e-mails, company chat or any other that may beused.

Action 2

Staff have the right not to use digital devices outside their working day, nor during rest periods, eave, leaveand/or holidays, and not to read or respond to any communication, regardless of the medium and channelused, once their working hours are over, except in the case of force majeure or exceptional circumstances thatmay be detrimental to the company.

Action 3

Calling and attending face-to-face or telematic meetings shall be done within the limits of the working day, andmay not extend beyond the end of the working day or normal working hours, respecting rest time and holidayscorresponding to the localities where they are present, and shall indicate the start and end time.

Action 4

Exceptional circumstances of force majeure shall be deemed to exist in the case of events that may pose aserious or obvious risk to Fundació Dénia Creativa, the urgency of which requires an immediate response from staff. In such cases,the measures guaranteeing the right to digital disconnection shall not apply.

The time that staff have spent outside their working day as a result of such circumstances shall becompensated by means of days or hours of free availability.

Action 5

For better management of working time, at the end of the day immediately preceding the start of holidays or absences, staff shall endeavour to activate the automatic reply for absence in their e- mail or instant messaging account and the date on which they will resume work. They should also designate a person from the same team for tasks requiring urgent handling. Likewise, if emails or messages are sent outside of normal working hours, it will be conftgured as a deferred sending of the email or message.

Action 6

Staff shall not be discriminated against or penalised in their professional development for exercising the right to digital disconnection.

5. Mesures to be taken

Fundació Dénia Creativa has established a series of measures to ensure that the measures set out in this protocol are being implemented withinthe company:

• Staff, at the time of signing the employment contract, will be given a copy of the company's DigitalDisconnection Protocol Fundació Dénia Creativa by signing ANNEX I.
• All work-related communication will be carried out through the tools and devices made available to staffby the company.
• At the beginning of the year, the working calendar with the respective public holidays will be published onthe intranet, corporate website and the company's internal notice board.
• Rocío Pastor Domínguez, in charge of occupational risk prevention, could be consulted whenevernecessary on possible risks and/or cases of technostress and analyse the impact of digital disconnectionpolicies from the point of view of psychosocial risks.
• Staff will be surveyed on an annual basis in conjunction with the digital disconnection risk assessment ofthe workstation.
• For proper review and monitoring of compliance with this digital disconnection protocol, compliance withthe actions outlined in this agreement will be monitored by staff from theRocío Pastor Domínguez team responsible for the management and welfare of Fundació Dénia Creativa staff.
• In the event that FUNDACIÓ DÉNIA CIUTAT Fundació Dénia Creativa staff consider that the appropriate measures are not being taken to ensuredigital disconnection, they can report this toRocío Pastor Domínguez via e-mail or the company's whistleblowing channel.

6. Disemination and validity

This Digital Disconnection Protocol will be available and permanently updated in this web site of the company's Fundació Dénia Creativa.

This document will be subject to possible modiftcations for the best adjustement and adaptation to newdevelopments that may arise in this area.