This Internal Information System is established, in accordance with Article 12 of Law 2/2023, of February 20, as a shared system for the following companies: HOTELERA POLLENSINA S.A. / ARRENDAMIENTOS Y EXPLOTACIONES POLLENTIA S.L. / HOTEL CALA EN BLANES S.A. / ALOJAMIENTOS TURÍSTICOS VILLA CONCHA S.L. Accordingly, HOTELERA POLLENSINA S.A. assumes the management and processing of communications submitted through this internal reporting channel or system. The Internal Information System serves as the channel to confidentially and effectively report any irregularities committed by the company or its staff that become known within the framework of a professional or employment relationship with our organization, in accordance with the provisions of Law 2/2023, of February 20.
- The organization has set up the Internal Information System through the following channels
- By email denuncia@hoposa.es
- By postal mail, addressed to the Person Responsible for the Internal Information System of the organization to which the report is being submitted, namely: HOTELERA POLLENSINA S.A. / ARRENDAMIENTOS Y EXPLOTACIONES POLLENTIA S.L. / HOTEL CALA EN BLANES S.A. / ALOJAMIENTOS TURÍSTICOS VILLA CONCHA S.L., Calle de la Vela Nº 8, 07470 Puerto de Pollensa, Balearic Islands.
- Orally:
- At the request of the informant, the information may also be presented through a face-to-face meeting with the System Manager within seven days from the date of the request.At the request of the informant, the information may also be presented through a face-to-face meeting with the System Manager within seven days from the date of the request.
In addition to these channels, communications may also be made through external reporting channels of the competent authorities, such as the Independent Whistleblower Protection Authority, via email at canal.externo@proteccioninformante.es.More information is available at: https://www.proteccioninformante.gob.es/
Upon receipt of a report, the System Manager will acknowledge receipt to the whistleblower within seven days in the case of identified (non-anonymous) reports. In all cases, the whistleblower will be informed of their rights and obligations established by data protection regulations.
The System Manager will issue a reasoned report, either accepting or rejecting the communication and justifying the decision in each case. The report will be notified to both the informant and the affected person within a maximum of three months from the end of the seven-day period following the submission of the report. In complex cases, this deadline may be extended by an additional three months.
During the handling of the report, communication with the whistleblower may be maintained, and if necessary, additional information may be requested.
-Durante la tramitación de la denuncia, se puede mantener la comunicación y contacto con el informante/denunciante y, si se considera necesario, solicitar a la persona informante información adicional.
The organization guarantees that the person affected by the report is informed of the facts in summary form, and is also informed of their right to submit written arguments and of the processing of their personal data. However, this notification may take place during the hearing stage if earlier communication could facilitate concealment, destruction, or alteration of evidence.
The Internal Information System Manager guarantees confidentiality for all who use the reporting channel, including when reports are submitted through unofficial channels or to personnel not responsible for their processing.
During the process, those affected by the report are guaranteed the presumption of innocence, the right of defense, and access to the case file, as well as the same protection established for informants, preserving their identity and guaranteeing confidentiality of facts and data.
The processing of personal data arising from this procedure will be governed by the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 (GDPR), Organic Law 3/2018 of December 5 on Personal Data Protection and Guarantee of Digital Rights, and Organic Law 7/2021 of May 26 on the protection of personal data processed for purposes of crime prevention, detection, investigation, prosecution, and enforcement of criminal penalties.
The System Manager will immediately refer any information to the Public Prosecutor’s Office when the facts could constitute a criminal offense, or to the European Public Prosecutor’s Office if the facts affect the financial interests of the European Union.
The organization guarantees the absence of reprisals against anyone who reports possible unlawful conduct, regulatory breaches, or who collaborates in the investigation or resolution of such matters.
Persons who report or disclose violations referred to in Article 2 of Law 2/2023, of February 20, and actions or omissions that may constitute serious or very serious criminal or administrative offenses, shall have the right to protection measures, provided that the conditions established in Article 35 of the aforementioned Law are met. These protection measures are detailed in Article 38 of the Law.
Reports or information will be stored on the organization’s premises in accordance with its document archiving and retention policy.
The organization maintains a register of all reports received. Reports will be kept only for the time necessary and proportionate to meet the requirements set by Law 2/2023, of February 20, on the protection of persons reporting regulatory violations and on the fight against corruption, and in accordance with Article 24 and other applicable provisions of Organic Law 3/2018 of December 5 on Personal Data Protection and Guarantee of Digital Rights.