Internal Reporting Channel Invisa Hotels

Internal Reporting Channel 

Commitment to ethical behaviour, integrity, and regulatory compliance

At HOTELES TRINIDAD, S.L., integrity, transparency, and compliance with the law are fundamental principles that guide the course of our business activities and our relationships with clients, employees, suppliers, partners, and other stakeholders.

In order to reinforce these principles and foster a culture of compliance and responsibility, the Company has implemented an Internal Information System  in accordance with Law 2/2023, of 20 February regulating the protection of persons who report regulatory infringements and the fight against corruption.

The Internal Information System is the preferred channel for securely and confidentially communicating acts or omissions which may constitute breaches of applicable regulations, the Code of Conduct, or internal policies. It is designed to facilitate the appropriate handling and investigation of such matters and to guarantee full respect for the rights of all parties involved at all times.

Access to the Internal Information Channel

If you wish to report a possible breach falling within the scope of the Internal Information System, please email cdih@invisahoteles.com.

Whistleblowers may submit their report anonymously or provide their contact details, at their discretion. Whistleblowers should, however, include a sufficient description of the facts, along with any relevant documentation or information to facilitate their subsequent assessment.

Scope of use of the Channel

The Internal Reporting Channel is intended for those who have obtained information regarding potential breaches within the context of an employment or professional relationship with HOTELES TRINIDAD, S.L.

It is not intended for the management of commercial complaints, bookings, general enquiries, routine HR requests, or service-related incidents, which should be directed through the dedicated channels in place for such matters.

Principles and guarantees

The Internal Information System of HOTELES TRINIDAD, S.L. is managed with independence, objectivity, impartiality, confidentiality, and full respect for the law, ensuring that all disclosures are handled with the utmost diligence and due regard for the rights of all parties involved. In particular, the Company guarantees:

• ­                The confidentiality of the identity of the whistleblower, the individuals affected, and any third party mentioned in the disclosure. 
• ­                Protection against any form of retaliation for individuals reporting information in good faith under the terms set out in current legislation. 
• ­                Respect for the rights of affected individuals, in particular their right of defence, their right to be heard, and the presumption of innocence. 
• ­                The protection of personal data in accordance with EU Regulation 2016/679, Organic Law 3/2018, and Law 2/2023. 

Disclosures will be managed by the Head of the Internal Information System, appointed by the Company’s Board of Directors, who shall act with complete independence in the performance of their duties.

Management of disclosures

Disclosures will be handled in an objective, diligent, and confidential manner, in accordance with the established procedure and with due regard for the rights of all parties involved. When appropriate, an acknowledgement of receipt will be issued and the whistleblower will be kept informed within the legally prescribed timeframes.

Personal data protection

Personal data provided through the Internal Reporting Channel will be processed by HOTELES TRINIDAD, S.L., as Data Controller, for the purpose of receiving, managing, and investigating disclosures submitted and, where applicable, taking such measures as may be necessary, in accordance with current personal data protection legislation and Law 2/2023

For further information regarding the processing of your personal data, please refer to the Internal Information System Data Protection Policy.

External information channels

The use of the Internal Reporting Channel does not preclude whistleblowers from making use of external channels made available by the competent authorities, including, where applicable, the Independent Authority for Whistleblower Protection (A.A.I., for its Spanish initials), under the terms set out in Law 2/2023.

Confidentiality of information

All information received through the Internal Information System will be treated with strict confidentiality. Only individuals authorised to manage disclosures, under the terms set out in Law 2/2023 and current personal data protection legislation, shall have access to such information.