COMPLIANCE POLICY
COMMITMENTS
- Comply with all obligations under this Policy and the Programme.
- Comply with all criminal laws applicable to the Company.
- Continuously improve the Programme and related business processes.
SCOPE OF APPLICATION
This Policy and the Programme apply to the Company, its Governing Body, Senior Management, employees and any other related parties.
For the purposes of entering into any business relationship, acceptance of this Policy and the obligations arising from it shall be proposed.
OBJECTIVES
- Reinforce the zero tolerance policy with regard to the commission of criminal offences.
- Establish a model capable of identifying the most important criminal risks and establish measures for their prevention, detection and management.
- To involve all the organisation’s personnel in this system.
- To assure society that the Company complies with the duties of supervision and control in the exercise of its activity, and that it establishes the appropriate measures to prevent the commission of crimes.
- Periodically review these objectives.
GENERAL PRINCIPLES
- Compliance with criminal legislation, the Code of Conduct and the rest of its internal protocols is required of all members of THE COMPANY, and expressly prohibits the commission of criminal acts.
- THE COMPANY undertakes to comply with all the obligations derived from this Policy, as well as the set of protocols, procedures and policies that form part of the Compliance programme.
- The interested parties are obliged to report all suspicious events or conduct relating to criminal risks, guaranteeing confidentiality and the absence of reprisals to the informant, through the channel provided for this purpose. The interested parties are obliged to report all suspicious events or conduct relating to criminal risks, guaranteeing confidentiality and the absence of reprisals to the informant, through the channel provided for this purpose.
- The existence of the Regulatory Compliance and Crime Prevention Committee is announced, as the body that will exercise the functions of the person responsible for Compliance. The Regulatory Compliance and Crime Prevention Committee is independent of the Governing Body and will act as the authority responsible for the management, implementation and verification of compliance with the Compliance programme.
- Failure by members of THE COMPANY to comply with the obligations arising from this Policy and the Compliance programme as a whole will give rise to the application of the disciplinary regime provided for in the Workers’ Statute and the applicable Collective Bargaining Agreement, and in the case of any business partner, those provided for in the specific procedure applicable to it.
You can consult the Criminal Compliance Policy of Gestión Hotelera la Marina, S.L. by clicking on this link.
INTERNAL INFORMATION SYSTEM OF GESTION HOTELERA LA MARINA, S.L. – WHISTLEBLOWING
Welcome to the Gestión Hotelera la Marina, S.L. Internal Information System.
The Internal Information System has been implemented by Gestión Hotelera la Marina, S.L. in the framework of its programme for the prevention of the commission of crimes and in accordance with the legal requirements and demands established in Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law (known as the ‘Whistleblowing Directive’) and in the applicable national transposition regulations (in Spain, Law 2/2023 of 20 February, regulating the protection of persons who report breaches of regulations and the fight against corruption).
You can consult the Internal Information System Policy of Gestión Hotelera la Marina, S.L. by clicking on this link.
We invite you to read this document in which you will be able to see that the System and the internal reporting channels have been implemented for the reporting of certain breaches of which you are aware within the ‘Material Scope of Application’ of said System, such as, for example, actions or omissions that may constitute:
1) – a legal or regulatory breach of European Union Law;
2) – a serious or very serious criminal or administrative offence, such as those involving financial loss to the Public Treasury and Social Security;
3) – a breach of the Group’s internal regulations or codes of conduct; or,
4) – any contingency that may pose a risk to the reputation of Gestión Hotelera la Marina, S.L. or any of its subsidiaries.
Thus, we remind you that this internal information and complaints channel is not the communication channel for Customer Service complaints, interpersonal conflicts that exceed the material scope of application of the System or other commercial complaints, among others. To do so, if your notification is a complaint of commercial origin, you can go to the following link.
If you wish to report a regulatory infringement specific to the matters covered by the Information System, you can do so through the following alternative channels:
- A) Maintaining the anonymity of the informant: Through the following web mailbox
Note: Once the complaint form has been created and sent, the platform automatically assigns an identification code to the complaint which must be kept by the informant and which will allow them to consult the processing status of their communication. This platform is operated by an external supplier to Gestión Hotelera la Marina, S.L. - B) Reporting directly to the system administrator, either verbally or in writing, through the following alternative channels that do not guarantee anonymity:
By sending a letter in a sealed envelope addressed to the attention of the person responsible for the system, to the offices of GESTION HOTELERA LA MARINA, S.L. at the following address: Avenida Cuenca, nº 6, 03503, Benidorm (Spain). The envelope must be marked ‘Confidential’.
By holding a face-to-face meeting at your express prior request, whose conversation will be documented or recorded on a secure storage device.
In any case, whatever the channel chosen by you, Gestión Hotelera la Marina, S.L. will treat the information communicated with due confidentiality in compliance with the provisions of the applicable regulations.
For further information on the procedure for handling complaints, protection of informants, prohibition of reprisals, treatment of personal data and other relevant aspects, please consult the aforementioned Internal Information System Policy.
