The present Code of Conduct (hereinafter, the “Code”) sets out the catalogue of rules of conduct that must govern the actions of all employees of GRUPO HOTELES PLAYA, SA, (hereinafter “GRUPO HOTELES PLAYA, SA” or the “Company”) and constitutes a key element of the Compliance Program of GRUPO HOTELES PLAYA, SA.
This Code applies to directors, senior management, and employees of GRUPO HOTELES PLAYA, SA including interns and trainees. These individuals are hereinafter referred to as “Subjects” or “Employees”.
In certain specific matters that require detailed regulation, the rules of this Code are complemented by those contained in other codes and manuals of GRUPO HOTELES PLAYA, SA. The sectoral codes and manuals include the Manual for the Prevention of Money Laundering and Terrorism Financing, the Internal Regulations of Conduct in Securities Markets, the Security Document, etc. (hereinafter all referred to as the “Compliance Manuals”) as well as the notes and circulars that develop specific points of these codes and manuals.
The Subjects of the Code are obligated to know and comply with the Code of Conduct and to collaborate to facilitate its implementation at GRUPO HOTELES PLAYA, SA, including reporting to the Monitoring Body any infringement that comes to their attention.
By enforcing the Code, it is intended that individuals who carry out their activities within GRUPO HOTELES PLAYA, SA demonstrate honest and professional behavior at all times and contribute to the good atmosphere and commitment of GRUPO HOTELES PLAYA, SA by reporting any behavior that could harm its image and/or reputation.
The General Principles of the Code of Conduct, together with the Compliance Manuals of the Company and the professional ethics of its staff, constitute the pillars of action of GRUPO HOTELES PLAYA, SA. All actions of the Subjects must be guided by these guidelines and principles.
GRUPO HOTELES PLAYA, SA, within the scope of internal relations, has the following principles:
All Subjects of the Code will promote at all times relationships based on respect for others and mutual collaboration.
GRUPO HOTELES PLAYA, SA undertakes to ensure the existence of a work environment free from any type of violence and/or harassment, with the consequent prohibition of all forms of discrimination, intimidation, offensive or improper behavior, lack of respect, or any type of physical or verbal aggression in professional relationships within the Company.
GRUPO HOTELES PLAYA, SA has as a basic principle to maintain a work environment in which the dignity of all persons is respected and any behavior that violates fundamental rights protected by the Spanish Constitution and the general legal system is avoided.
GRUPO HOTELES PLAYA, SA expresses its firm commitment to promoting equal opportunities in access to work and professional promotion, avoiding at all times situations of discrimination or inequality based on gender, race, social or sexual status, marital status, religion, union affiliation, or any other circumstance.
As a result, the Subjects involved in hiring processes, selection, and/or professional promotion will act objectively in their actions and decisions, with the aim of identifying those individuals who are most suitable for the profile and needs of the position to be filled and especially in the hiring and promotion of managerial personnel and in the appointment of those who make up the management bodies, where high ethical standards must be respected.
The Subjects shall at all times respect the applicable preventive measures in occupational safety and health. To this end, they are obligated to know and use the resources that GRUPO HOTELES PLAYA, SA provides them in terms of safety and prevention of occupational risks and, where applicable, ensure that the members of their teams carry out their activities in safe conditions.
The Subjects will promote a work environment compatible with personal development, facilitating among the members of their teams access to measures that facilitate the reconciliation of professional performance at GRUPO HOTELES PLAYA, SA with the needs of their personal life, in order to improve the quality of life of workers and their families.
The Subjects, within their competencies, must respect the legal requirements and internal procedures established by GRUPO HOTELES PLAYA, SA at all times to reduce or avoid as much as possible the environmental impact of their activities.
The Subjects will conduct themselves in a professional, impartial, and honest manner and refrain from engaging in illegal activities. The Subjects shall comply with both the general provisions (Laws, regulations, and circulars from supervisory bodies) as well as the Compliance Manuals and the internal procedures of GRUPO HOTELES PLAYA, SA that are applicable to them.
Any Subject who is indicted or accused in a legal proceeding that may affect their activity at GRUPO HOTELES PLAYA, SA or that originates from it, must inform Human Resources as soon as possible. Similarly, Human Resources must be informed of the existence of administrative records that affect them, whether as a presumed responsible person, witness, or in another capacity, which are processed by the authorities or supervisory bodies of the activity of GRUPO HOTELES PLAYA, SA.
The Subjects must prioritize the performance of their duties at GRUPO HOTELES PLAYA, SA and may not provide professional services to other competing entities, whether remunerated or not, regardless of the relationship on which they are based, unless expressly authorized by Human Resources with the prior favorable opinion of Compliance.
Subjects who engage in another professional activity must report this to Human Resources as soon as it arises.
The Subjects will use their technical and professional skills and appropriate diligence in the performance of their activities in the Company. In particular:
Subjects will always act in a way that their individual interests, those of their family members, or of other related persons do not take precedence over those of GRUPO HOTELES PLAYA, SA or its customers. This code of conduct will apply both in relationships with GRUPO HOTELES PLAYA, SA and its customers, customers of the same, supplier companies, or any other third party.
Subjects will identify and report situations of conflict of interest, both potential and real, including those arising from relationships of kinship or otherwise. They will refrain from participating (in decision-making or in the representation of GRUPO HOTELES PLAYA, SA in transactions of any kind in which there is a personal interest or that of any related person). Consequently, and without prejudice to the aforementioned general rule:
Subjects who have access to privileged information will not carry out operations for their own account or that of others, directly or indirectly, on securities or instruments affected by it. Nor will they promote, endorse, or recommend that others do so.
Privileged information is considered to be any specific information that has not been made public and that, if made public, could significantly influence the price of a market or organized trading system.
Subjects must maintain professional secrecy regarding any data or information they become aware of as a result of their professional activity, whether originating from or related to GRUPO HOTELES PLAYA, SA, its customers and supplier companies, other Subjects, or any other third party. Therefore, and without prejudice to the above:
Subjects must comply with the obligation of secrecy even after their relationship with GRUPO HOTELES PLAYA, SA has ended.
The selection processes of supplier companies must be characterized by the search for competitiveness and quality, ensuring equal opportunities among all of them.
Subjects, and especially those involved in decisions regarding the hiring of supplies or services or in setting their economic conditions, will avoid any interference that may affect their impartiality or objectivity in this regard.
Whenever possible, exclusive relationships will be avoided.
The hiring of external supplies and services must be carried out through transparent procedures and in accordance with criteria of publicity and concurrence, avoiding forms of dependence.
Employees are prohibited from accepting any kind of personal benefit, gifts (unless their value does not exceed one hundred fifty euros (€150) as indicated in the “Acceptance of Gifts” section), invitations, favors, or any other form of compensation from supplier companies. Attendance at social events, invitations to professional lunches, seminars, and other types of training activities, which have been previously authorized by the department head, will not be considered a personal benefit.
Likewise, the receipt of any form of remuneration or funding from supplier companies is prohibited, as well as, in general, the acceptance of any external remuneration for services derived from the employee’s professional activity.
An exclusive relationship with customers that could lead to excessive personal connection or restrict their access to other employees or channels of GRUPO HOTELES PLAYA, SA should be avoided.
Customers should be informed of any economic or other relationship that could constitute a conflict of interest with them, taking necessary measures to prevent it from interfering with the customer’s relationship with GRUPO HOTELES PLAYA, SA.
Employees are prohibited from accepting any kind of personal benefit, gifts (unless their value does not exceed one hundred fifty euros (€150) as indicated in the “Acceptance of Gifts” section), invitations, favors, or any other form of compensation from customers. Attendance at social events, invitations to professional lunches, seminars, and other types of training activities, which have been previously authorized by the department head, will not be considered a personal benefit.
Likewise, the receipt of any form of remuneration or funding from customers is prohibited, as well as, in general, the acceptance of any external remuneration for services derived from the employee’s or staff’s activity.
Subjects are obligated to respect the right to data protection, the right to honor and personal privacy of all individuals whose data they have access to as a result of their activities within GRUPO HOTELES PLAYA, SA. This respect must apply to any information concerning a person: identifying data, affiliation, family, economic, audiovisual, or of any other nature that allows their identification.
Personal data will be processed in accordance with the principles established in the data protection regulations, ensuring that:
It is prohibited for Subjects to accept any form of income or commissions for operations carried out by the Company, or to otherwise benefit from the position held in the Company for personal gain.
Therefore, any invitation, gift, or attention that, due to its nature, frequency, characteristics, or circumstances, could be interpreted as an attempt to influence the objectivity of the recipient, will be rejected and reported to the area director or Human Resources.
Consequently, no Subject may accept gifts, invitations, favors, or any other type of compensation related to their professional activity in the Company and coming from customers, supplier companies, intermediaries, counterparts, or any other third party.
The following are not included in this limitation:
In any case, Subjects will request authorization from the area responsible for any gift, invitation, or attention whose value exceeds one hundred fifty euros (€150).
The Subjects will ensure that the assets of the Company are not damaged.
To this end, they will respect the following rules in their use:
The Subjects will strictly comply with the rules established by GRUPO HOTELES PLAYA, SA at all times regarding computer security, and in particular:
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