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The key activities of the Compliance Committee regarding the Code of Conduct include:
• Ensuring that the Code of Conduct is acted on throughout the organisation
• Making decisions on the penalties to be applied for breaches of the code of conduct
• Managing any queries about the code.
• Supervising all training activities stemming from the implementation of the code.
The Code of Conduct is available for employees on the company intranet, and for third parties on the company website.
Through the Human Resources departments of each business unit, the company has put in place a procedure for requesting all employees to
adhere to the code. Learning courses have been done to the employees in relation to the Code of Conduct.
Any modification of the Code of Conduct must be previously approved by the Board of Directors, and employees and any other people affected
must be notified.
The Code of Conduct contains the following points specifically relating to financial reports and the recording of transactions:
- “NH Hotel Group shall ensure that all records of financial and accounting activity are prepared in an accurate and reliable manner, cooperating
with and facilitating the work of the internal audit, inspection and intervention units and other internal control units, as well as that of external
auditors and competent authorities, in all cases collaborating with the Justice department”.
- “Transparency of information is a fundamental principle of the conduct of the Group, being a commitment to giving reliable information to
markets, whether financial or of any other kind. Therefore,
the company’s internal and external financial reporting shall faithfully reflect its economic, financial and equity position in accordance with
generally accepted accounting standards.”
The aforesaid section stresses that “the individuals responsible must transmit truthful, complete and comprehensible financial reports. In no case
will they knowingly provide incorrect, imprecise or inaccurate information. Employees will refrain from:
- keeping a record of transactions in non-accounting media not recorded in official books;
- recording non-existent expenses, revenue, assets or liabilities;
- booking entries in accounting books with an incorrect indication as to their purpose;
- using false documents;
- deliberately destroying documents before the end of the legally-required time limit for retaining them.”
Reporting channel for informing the Audit Committee of financial and accounting irregularities, as well as any breaches of the Code of Conduct
and irregular activities in the organisation, noting if this is confidential.
A procedure has been established for lodging complaints about breaches of the principles enshrined in the Code of Conduct, and this enables
employees to provide confidential information about any non-compliance with the principles set out in the Code of Conduct.The procedure
for reporting and dealing with possible non-compliance and reports relating to the Code of Conduct is administered by the SVP of the Group’s
Internal Audit Department, who acts independently, giving an account of the most significant incidents over the course the year to the
Company’s Audit and Control Committee.Breaches should preferably be reported using a channel expressly set up for the purpose on the NH
intranet (
), through which they are forwarded to the SVP of the Internal Audit Department, thereby ensuring
that they remain confidential. In addition, they may be sent by post for the attention of the SVP of NH Hoteles, S.A., Internal Audit Department
at Santa Engracia 120, 28003 Madrid, Spain.The SVP of the Internal Audit Department is responsible for analysing the information presented
and requesting the corresponding evidence and reports. All significant complaints are presented to the Compliance Committee and the Audit
and Control Committee.
Regular training and refresher courses on, at least, accounting standards, audits, internal control and risk management for staff involved in
preparing and reviewing financial reports and evaluating the reporting system.
Through the Internal Audit Department, the company has carried out the following training activities in relation to the Financial Reporting and
Control system:
Workshops for staff from the Shared Services Centre and remaining department personnel: on the aims and characteristics of the Financial
Reporting and Control System, and the risks and controls matrix. The aim is to provide information on the most important aspects of the
Financial Reporting generation process: the Company’s operating processes that make up the Control System, bodies responsible for maintaining
the defined controls within each process, reporting improvements or changes, understanding the established supervision system, etc., and
confirming that each body responsible for controls understands both the controls and the type of evidence they need to provide.
Alongside this, the Financial Department occasionally attends training courses or conferences on updated accounting standards, consolidation
standards and the specific financial reporting applicable to the sector, which are considered especially relevant to its work.
F.2 Financial reporting risk assessment Report at least:
F.2.1 Which are the main characteristics of the risk identification process, including error and fraud, regarding:
Whether the process exists and is documented.
ANNUAL CORPORATE GOVERNANCE REPORT
