In 2014 NH Hotel Group promoted the creation of a Compliance
function covering the following key areas:
Internal Code of Conduct in the Stock Exchange:
It
establishes the minimum standards that apply to the purchase
and sale of securities, as well as to privileged and confidential
information, and how such information must be handled.
Procedure on Conflict of Interest:
It establishes the rules
that apply to conflicts arising between the interests of the
Company, or any company within its Group, and the direct or
indirect personal interests of the Directors or a person subject
to the rules governing conflicts of interest.
Code of Conduct
: It determines the main values and rules that
must govern the conduct and behaviour of the employees,
senior officials, and members of the governing bodies of the
Group.
Criminal Risk Prevention Model:
It describes the principles
applicable to the management and prevention of crimes
within NH Group. It also defines the structure and operation
of the control and oversight bodies established within the
Company, systematizing existing controls for the purposes of
preventing and mitigating the risk of crime at the different
areas of the Company.
COMPLIANCE COMMITTEE
NH Hotel Group set up a Compliance Committee in 2014,
composed of members of the Management Committee and
Senior Management. It is responsible for overseeing compliance
with the Internal Code of Conduct in the Stock Exchange, the
Procedure on Conflict of Interest, the Code of Conduct and the
Criminal Risk Prevention Model.
The Compliance Committee submits detailed reports on its
activities to the Audit and Control Commission and can take
disciplinary measures against employees in relation to matters
falling within its scope of competence.
OUR NEW
COMPLIANCE SYSTEM
COMPLIANCE OFFICE
The Compliance Office is responsible for
disseminating and overseeing compliance with the
Code of Conduct and preparing the Criminal Risk
Prevention Model. The Compliance Office reports
directly to the Compliance Committee and is also
responsible for managing the Complaints Channel.
The Code of Conduct explains how complaints
received through the Complaints Channel must be
handled. Transparency, confidentiality and respect
are guaranteed at all stages. In 2014 the Office
investigated 28 alleged breaches of the Code of
Conduct and the relevant sanctions were imposed.
TRAINING ON THE
CODE OF CONDUCT
In 2014 the Company continued to implement and
disseminate the Code of Conduct with an online
training course that helps to increase understanding
of the Code amongst employees. A total of 1,696
employees completed the training course in 2014
(2,689 since it was launched in 2012).
Relationship with
Governments
The Company manages its business in accordance
with its corporate values and its ethical and
conduct framework. It also ensures strict
compliance with the domestic legislation in
force. At the local level, the Company always acts
independently of any political party, ensuring
transparency in its dealings with public and
administrative institutions.
corporate governance
Our new Compliance system
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Compliance Committee:
Scope and Key Activities
Internal Code of Conduct
in the Stock Exchange
Procedure on Conflict
of Interest
Oversee compliance with the
Internal Code of Conduct in
the Stock Exchange
Verify fulfilment of the
Procedure on Conflict of
Interest
Code of Conduct
Criminal Risk
Prevention Model
Ensure that all members of
the organization are familiar
with the Code of Conduct
Take decisions on penalties
arising from breaches of the
Code of Conduct
Answer questions related to
the Code
Ensure that training on the
Code is provided
Oversee the handling of
complaints submitted
through the Complaints
Channel
Regularly monitor and
supervise the Criminal Risk
Prevention Model
Take all such complementary
measures as may be deemed
appropriate to ensure that
the organization properly
complies with the Criminal
Risk Prevention Manual
and generally, that it meets
the goals contained in the
Manual
Implement planned review
schemes and conduct ad
hoc reviews requested
by the Audit and Control
Committee
Propose improvements
where breaches or poor
control are observed
Report on its activities to
control officials and the
Compliance Committee
