ACTA HOTELS has established an Ethical Channel in accordance with Law 2/2023, of February 20, regulating the protection of individuals who report regulatory violations and combat corruption, so that anyone, whether a member of the Group or not, can report any type of unlawful conduct, particularly those that may have criminal relevance or are contrary to the principles and values of ACTA HOTELS.
The Ethical Channel consists of the following communication pathways to the Group:
a) Through the following link https://whistleblowersoftware.com/secure/canaleticoactahotels to the Whistleblower Software platform, where you can choose whether you want the communication to be received by the person responsible for the internal information system, Ms. Carolina Rodero, or by the independent law firm RCD Legal.
b) Verbally, by directly communicating the notice to the person responsible for the Internal Information System, with whom you can hold an in-person meeting to explain and detail the facts subject to communication.
c) Through the physical mailboxes set up in the Group's facilities.
d) By means of communication from employees to their superiors or responsibles in the Group.
Aside from the above, any formal communication from a judicial body or a Public Administration will be considered a valid means to become aware of a non-compliance.
Communications can be made both anonymously and identified, receiving the same treatment and consideration.
Through the Ethical Channel, any non-compliance committed by members of ACTA HOTELS, or by third parties not included but maintaining relationships with the Group in the context of their professional work, can be reported.
Also, through the Ethical Channel, any member of the Group or an outsider can raise their questions about the regulatory compliance system of ACTA HOTELS.
To regulate the use of the Ethical Channel and the procedure for investigating and resolving communications, ACTA HOTELS has approved and and implemented a Whistleblowing Policy and a Protocol for managing, investigating, and resolving communications.
ACTA HOTELS has taken the necessary measures to prevent any form of retaliation against whistleblowers, including threats or attempts of retaliation, and will ensure that all informants have access, as appropriate, to the support measures necessary to guarantee their effective protection.
Informants may also address their reports to the Independent Authority for the Protection of Whistleblowers in Catalonia (Oficina Antifrau de Catalunya, website: www.antifrau.cat) or to the Independent Authority for the Protection of Whistleblowers (A.A.I.), the national-level authority, depending on the geographic scope of the report.