Who can report?
Any person who maintains or has maintained any kind of link with Golden Hotels.
Thus, they can be informants": the workers of any of our companies, freelancers, professional collaborators, partners, executives, dependents of our contractors or suppliers, ex-employees, ex-partners, ex-administrators or proxies; interns; applicants in training or selection processes.
Do I have to give my details?
Although in order to verify the facts and request additional information or keep you up to date on the course of the investigations it is advisable that you provide us with your contact email, you have the right to submit your complaint of anonymous way. We will also investigate it.
What facts can be reported?
Our complaints channel is NOT a place to make complaints or claims. If you do, your communications will be archived.
This is a RESTRICTED CHANNEL, designed to report particularly serious events, because they may mean the commission of a crime or an administrative infraction, serious or very serious, and about which the informant must have the absolute conviction that they are true.
In addition, the facts must have occurred in the labor or professional field of our activity. If it is about events beyond our control, they must be reported to the police, administrative or judicial authorities that are competent.
If the complainant acts despite knowing that his information is implausible or manifestly false, or if the reason for his complaint is to defame the person or entity reported, he will not have any right of protection and Golden Hotels may report him and demand responsibilities.
How will complaints be processed?
Golden Hotels & Experiences has designated a Responsible for the Internal Information System. He will be the only person who will have access to the complaint and who will be in charge of investigating it.
The processing of the investigation will be done with the utmost reserve and with full guarantees of confidentiality. The accused and the rest of the people affected by the complaint will not have access to the identity of the complainant.
If the complainant designates an email to receive communications, he will be informed of the admission or non-admission of his complaint and of the decision taken at the end of the investigation.
If the investigation shows the commission of a crime, the facts must be transferred to the Prosecutor's Office or the judicial authority. If it is a serious or very serious administrative violation, the competent authorities will be informed.
Regardless of the fact that he can use our internal channels of information, the complainant can always also choose to use, jointly or alternatively, the external channels enabled by the Administration of Justice or the competent administrative authorities.
What protection will the complainant have?
All people who use our internal reporting channels in good faith will have the right to be protected, as long as the facts reported are not implausible or notoriously false.
The protection of whistleblowers will include, in any case, their right not to reveal their identity to the whistleblowers or to others affected by their complaint.
Golden Hotels & Experciens guarantees that no complainant will suffer reprisals due to acts of communication or complaints made through our internal channels or that, where appropriate, they have made before the Independent Authority for the Protection of the Informant (AAI) or that have been the subject of public disclosure under the terms of Law 2/2023. This right of protection will extend to his family members and close relatives, and to those entities with which the complainant maintains some kind of connection.
The data treatments carried out in compliance with Law 2/2023 are covered by the fulfillment of this legal obligation, where they have their basis of legitimacy. Additionally, the rule establishes a presumption of legality for the treatment of special categories on the basis of the essential public interest.
In compliance with data protection legislation, all interested parties are also informed that their identity will be reserved and that it will not be communicated to the persons to whom the disclosed facts refer or to third parties, unless legally required.
The complainant and any interested party can exercise their right of access, rectification, limitation, deletion and portability of their personal data in accordance with current regulations. In consideration of the reservation obligation mentioned in the previous paragraph, some of these rights may be fulfilled with certain limitations, for example, regarding the right of access or opposition.
Also, only the people of the company designated for this purpose will be able to access the data that are deposited in the Internal Information System. In the same way, the communications of this data to third parties will be limited in accordance with what is established by law.
The data may only be kept for the time that is essential to decide whether or not to initiate an investigation. In any case, once three months have passed since the receipt of the communication without investigative actions having been initiated, the personal data will be deleted, unless the purpose of keeping them is to leave evidence of the functioning of the Internal System of Information, in which case the data will be anonymized.