GRUPO HOTELES PLAYA, S.A. carries out its activities and operations in compliance with all relevant laws and regulations, and implements internal guidelines, policies, and procedures to ensure that such laws and regulations are followed.
GRUPO HOTELES PLAYA, S.A. identifies, manages, and communicates to the Governing Body and Management the risk of criminal non-compliance that must be prevented.
The inappropriate behavior of a single executive, employee, or person performing functions for GRUPO HOTELES PLAYA, S.A. can potentially damage our image and reputation in a very short period of time. Therefore, we must actively prevent and avoid this possibility.
To achieve this, it is required that all members of GRUPO HOTELES PLAYA, S.A., whether directors, shareholders, executives, or employees (hereinafter, the Personnel), carry out their activities with a firm commitment to comply with current legislation and regulation, our ethical principles, our Compliance Manual, and our internal policies, as well as with the procedures and controls established in the Company.
The purpose of this Policy is to inform the personnel of GRUPO HOTELES PLAYA, S.A., as well as third parties related to it, a resounding message opposing the commission of any illicit, criminal, or other acts.
In no case is the commission of a crime justified (and is prohibited) by the personnel, even if such action would produce, apparently, a benefit of any kind for GRUPO HOTELES PLAYA, S.A.. Likewise, the Company is willing to combat these acts and prevent a possible deterioration of its image and reputational value.
This Compliance Policy constitutes the reference framework of the existing Compliance Model at GRUPO HOTELES PLAYA, S.A., known by all personnel and driven by the Governing Body. Its scope covers those activities within the processes developed in the Company and the people who carry them out.
The main reasons for implementing an effective and efficient Compliance Management System are as follows:
A Compliance Management System helps to ensure and increase the value of GRUPO HOTELES PLAYA, S.A. and to protect Management from personal liabilities.
GRUPO HOTELES PLAYA, S.A. has a Compliance Management System consistent with the organization’s purposes and complying with the minimum requirements.
To establish an effective system, the following steps are followed:
The Management of GRUPO HOTELES PLAYA, S.A. is responsible for developing and implementing a Compliance Management System based on the application of appropriate policies and procedures that ensure compliance with all applicable laws and regulations.
The appointment of a Compliance Officer does not exempt Management from its ultimate responsibility to establish an effective criminal compliance system.
The Management of GRUPO HOTELES PLAYA, S.A. communicates its clear commitment to criminal compliance (“greater hierarchy greater demand”) and complies with the requirements of this criminal compliance policy and the implemented criminal compliance management system.
GRUPO HOTELES PLAYA, S.A. is committed to the continuous improvement of the criminal compliance management system.
A higher-ranked person has been designated to act as “Compliance Officer.”
The Governing Body has appointed a Compliance Officer, who has a legal and economic understanding of compliance issues; is reliable and trustworthy.
The responsibilities and tasks delegated to the Compliance Officer (whether coinciding with the Governing Body or not) are well defined and documented, which is done through a letter of appointment from the Governing Body addressed and endorsed by the Compliance Officer himself.
The Compliance Officer has sufficient resources to fulfill their obligations properly.
The Compliance Officer works together with the company’s management and collaborates fully with the other bodies of the Organization.
The Criminal Compliance Management System is based on a documented process in which criminal compliance risks are identified and evaluated. The identification and evaluation of risks are repeated at fixed intervals or in specific response to an extraordinary event, significant change in the structure or activity of GRUPO HOTELES PLAYA, SA, changes in case law, or relevant legislative changes.
Once the risk identification and evaluation process is completed, measures are developed to eliminate the cause of non-conformity and prevent its recurrence.
GRUPO HOTELES PLAYA, SA develops or, as appropriate, reviews existing compliance-related documents (taking into account the results of risk identification and evaluation).
Employees receive basic compliance training, and their attendance at such training is documented.
The company’s staff’s contribution to the effectiveness of the criminal compliance management system is essential for them to help prevent and detect criminal risks, avoid their materialization, and recognize risk factors.
GRUPO HOTELES PLAYA, S.A. ensures the competence of the compliance staff, based on appropriate education, training, or experience.
Performance objectives are periodically reviewed to ensure that there are reasonable safeguards in place to prevent incentivizing criminal risks or promoting inappropriate conduct regarding criminal compliance.
GRUPO HOTELES PLAYA, SA has implemented an effective reporting system through which employees and third parties can communicate any information about an alleged non-compliance to the company’s Compliance Officer.
If necessary, employees submitting a complaint can do so anonymously, unless prohibited by law.
The Whistleblowing Channel is implemented on the organization’s website.
Violations require an appropriate sanction regardless of the employee’s status (including, for example, non-payment of bonuses, legal action, or dismissal).
In cases where the Management of GRUPO HOTELES PLAYA, SA delegates decision-making in areas where there is a higher-than-average criminal risk, GRUPO HOTELES PLAYA, SA will establish and apply a procedure and a system of controls to ensure that the decision-making process and the level of authority of decision-makers are appropriate and free from actual or potential conflicts of interest.
The criminal compliance objectives are consistent with what is established in this Policy and with the results of the identification and evaluation of criminal risks, are monitored according to the established planning once the process of evaluating criminal risks has been completed, communicated, measurable (if possible), and updated as necessary.
The Governing Body promotes and approves this Criminal Compliance Policy, which:
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