NH Hotel Group is committed to working against corruption in all forms through policies and mechanisms that ensure the prevention of possible cases of corruption, bribery and money laundering within the organization.

Anti-Corruption Policy

The Company has an Anti-Corruption Policy, approved in January 2018 by the Board of Directors, the purpose of which is to protect the Company and all its representatives against criminal liability in the event of any crime of corruption being committed within the Group. This is an additional element to the Criminal Offence Prevention Model, and is encompassed in the Code of Conduct.

 

In December 2018, the Compliance Committee updated the policy in order to specifically include the principles of fight against fraud. The new document will be submitted to the Board of Directors for validation during the first quarter of 2019.

 

Procurement Policy

The Procurement Policy pays particular attention and diligence to the supplier assessment and selection processes, in order to avoid any type of business relationship with natural or legal persons that might be involved in conduct or behaviour that is unethical or lacking integrity, especially in activities related to prostitution, child corruption, fraud, public and private corruption, money laundering and the financing of criminal organizations or terrorists.

The “Commitment to Suppliers” section of this report provides more information on the NH Hotel Group Suppliers Code of Conduct, as well as the Coperama Code.

 

Measures against money laundering

The NH Hotel Group Code of Conduct reflects a commitment to respecting applicable money-laundering legislation, with particular attention to supplier assessment and selection processes, and to cash payments.

Furthermore, the Group is reinforcing the application of the policies approved in the areas of the fight against corruption and money laundering through compulsory training courses for employees. In the first quarter of 2019, two online courses on the prevention of money laundering and the fight against fraud will be available in 6 languages on the Company’s e-learning platform.

At the meeting of the Compliance Committee held in December 2018, a policy reinforcing NH Hotel Group’s commitment to the prevention of money laundering and financing of terrorism was approved. The aim of this measure is to prevent the possibility of having the Company and its subsidiariesbe used in money-laundering operations or in the financing of terrorism. This Policy will be submitted to the Board of Directors for approval in the first quarter of 2019. Once approved, it will be communicated to employees and specific training will be offered.