SHAREHOLDER STRUCTURE
At the end of 2020, the share capital of NH Hotel Group, S.A. totals € 784,360,486 and was represented by 392,180,243 bearer shares with a par value of 2€ each, fully subscribed and paid.
According to the latest notifications received by the Company and the communications sent to the Spanish National Securities Market Commission (Comisión Nacional del
Mercado de Valores – CNMV) before the year end, the most significant shareholders at the end of the year were as follows:
* MINT is the indirect shareholder through MHG Continental Holding (Singapore) Pte Ltd.
Capitalization at the end of each year
(in million euros)
Relations with shareholders and investors
Throughout 2020, NH Hotel Group has been in permanent contact with the Company’s analysts and investors in order to satisfy their needs concerning the Group’s general evolution. Due to the health situation, this contact with the market has taken place mainly through virtual meetings on a one-to-one basis, through our participation in investors’ conferences organized by various financial institutions and individual call requests.
The Company produces consistent and transparent financial information on a regular basis, with the aim of permitting monitoring for the analysis and valuation of the Group.
As a listed company, NH Hotel Group publishes quarterly results for the market. In addition, every six months and coinciding with the publication of half-yearly and annual results, a call/conference with the market is held with an average attendance of 25 participants, including investors and analysts.
The quarterly results published detail the following:
• KPIs and drivers of results.
• Evolution by geographical areas.
• Evolution of costs.
• Breakdown of cashflow and financial debt position.
In addition, the Investor Relations department is in permanent contact with the market through calls, trips,
investors’ conferences … in order to keep the investment community informed of the Company’s evolution.
CORPORATE GOVERNANCE
The Corporate Governance system of NH Hotel Group is made up of the Bylaws, the Board of Directors’ Regulations, the General Shareholders’ Meeting Regulations and the Internal Regulations for Conduct on Securities Markets, as well as the other rules, codes, internal procedures and corporate policies approved by the competent bodies of the Company.
This System has been formalised in line with the highest standards of compliance with good practice in corporate governance, as defined by, among others, the Good Governance Code for listed companies (the “Good Governance Code”), approved by a Resolution of the Board of the CNMV on February 18th, 2015 and revised in June 2020, which is aligned with the recommendations on good governance of international markets.
Board of Directors of
NH Hotel Group
The Board of Directors is the Company’s senior management and representation body. It is empowered, within the scope of the corporate object defined in the Bylaws, to carry out any acts of administration or disposal, under any legal title, except those reserved by law or by the Company’s Bylaws to the exclusive competence of the General Shareholders’ Meeting.
Consequently, the Board of Directors is conceived as a supervisory and control body, while the ordinary management of the Company’s business is entrusted to the executive bodies and the management team. The functions of the Board of Directors and its Committees (Audit and Control Committee and Nominations, Remuneration and Corporate Governance Committee) are expressly reflected in articles 33 and 47 of the Bylaws and articles 5 and 25 of the Board Regulations. The Board of Directors will develop its duties in line with the corporate interest, which is understood to be the Company’s interest; and in this regard it will act to safeguard the Company’s long-term viability and to maximize its value, also weighing the many legitimate public or private interests involved in relation to any business activity.
BOARD CONTROL COMMITTEES
During 2020, the Board of Directors of NH Hotel Group had the following control commissions and committees:
Audit and Control Committee. Focused among other matters, on supervising the effectiveness of the Company’s internal control and the process of drawing up and presenting statutory financial information, ensuring the independence and effectiveness of the internal audit function and of the external auditor.
Composition of the Audit and Control Committee
As of December 31st, 2020
Nominations, Remuneration and Corporate Governance Committee. Focused on proposing the appointment of Independent Directors or reporting on the suitability of other directors to be appointed, as well as analysing and evaluating everything related to remuneration of both Board members and Senior Management, drawing up the corresponding policies. It is also responsible for supervising and controlling compliance with corporate governance rules and the Corporate Social Responsibility Plan, proposing the necessary Reports to the Board.
Composition of the Nominations, Remuneration and Corporate Governance Committee
As of December 31st, 2020
Composition of the Board Of Directors
As of December 31st, 2020
Certain changes in the composition of the Board took place in 2020. The current composition is the result of the resignation of the Executive Director Ms. Beatriz Puente Ferreras, presented on September 28th due to the end of her professional relationship with the Company and the appointment by co-optation of Mr. Rufino Pérez Fernández as Executive Director, following a favourable report by the Nominations, Remuneration and Corporate Governance Committee.
Between December 31st, 2020 and the date of drawing up this Report, there have been no changes in the composition of the Board.
The complete profile of all members of the Board of NH Hotel Group and its committees is public and can be consulted at the Corporate Governance section of the Company’s corporate website.
SELECTION POLICY FOR DIRECTOR CANDIDATES
Candidate Selection Objectives and Process
On December 22nd, 2020, following a favourable report issued by the Nominations, Remuneration and Corporate Governance Committee, the Board of Directors approved modifications to the Director Selection Policy in line with the Good Governance Code, which ensures that proposed appointments of directors of the Company are based on a prior analysis of the Board’s needs. To evaluate the candidates who participate in the selection process, the procedure considers the skills, experience, professionalism, suitability, gender, independence, knowledge, qualities, capacities and availability of members of the Board of Directors from time to time. The Nominations, Remuneration and Corporate Governance Committee plays a relevant role in this process.
This Policy seeks to avoid discrimination and ensure that merit is the governing selection principle in finding the best candidates for the Company.
Conditions that candidates must fulfill
Candidates for the post of Director of the Company must meet requisites of qualification and professional and personal honourability. In particular, they must be suitable and prestigious individuals, of recognized professional capability, competence and experience, with sufficient qualifications, training and availability for the position. Candidates must show a commitment to their role, with a personal and professional history of respect for the law and commercial good practice, and they must comply with the obligations established by law at all times in order to be part of the Board of Directors. Furthermore, they must be professionals of integrity, whose conduct and career are aligned with the ethical principles and duties established in the Company’s internal regulations, and they must share the Group’s vision and values.
Promotion of Diversity
NH Hotel Group is convinced that diversity in all its facets, at all levels of its professional team, is an essential factor to ensure the Company’s competitiveness and a key element of its corporate governance strategy. In the candidate selection process, discrimination is avoided, and merit is the principal selection criterion, in the corporate interest, and the process is designed to seek the most qualified candidates.
However, and notwithstanding the above, every time a vacancy arises on the Board of Directors, and the corresponding selection process starts, at least one woman must participate as a candidate, until the target of 40% by 2022 is achieved.
To reach this target, the Nominations, Remuneration and Corporate Governance Committee will ensure that the selection process does not suffer from any implicit bias that impedes the selection of female Directors and that the potential candidates include women who match the required professional profile.
MANAGEMENT COMMITTEE
The NH Hotel Group Management Committee is conceived as a body that guarantees the viability of the business, seeking growth and establishing the Company’s strategic framework, developing talent and leadership.
The Management Committee meets on a weekly basis and is made up of the Chief Officers of the different areas:
Composition of the Management Committee
As of December 31st, 2020
BOARD AND SENIOR MANAGEMENT REMUNERATION
Average Remuneration of the Board Of Directors and Management Committee of NH Hotel Group (Euro)
* In 2020, as there were momentarily no women, there is no data comparability for the Board of Directors.
Furthermore, there are no male directors who are not proprietary directors (proprietary directors of NH Hotel Group have waived their fixed remuneration and their expenses
llowance as Board members) or chair a committee. It should be noted that the 2 Committee chairs and the Chair of the Board are held by male Directors. These are positions that receive remuneration of 200,000 euros in the case of the Chairman of the Board and 90,000 euros in the case of the Chairs of the Committees. This year, due to the crisis deriving from Covid-19, the directors have agreed to reduce their remuneration by 50%.
**Includes: Fixed salary, vehicle, medical insurance, life insurance and accident insurance. All amounts accrued in 2020 (gross amounts) of committee members who were on the committee during 2020. The figures for incoming and outgoing members during 2020 have been annualized.
All the members of the Management Committee have reduced their remuneration in 2020 by more than 50%.
The remuneration of Executive Directors is included in the figures shown for the Management Committee as their duties as members of the Board are not remunerated.
Further information on the remunerations policies for the Board of Directors is available in the Annual Corporate Governance Report 2020.
COMPLIANCE SYSTEM
NH Hotel Group continues to promote the compliance functions, focusing on the following key areas:
Code of Conduct
Its purpose is to determine the principles, values and rules that are to govern the conduct and behaviour of each of the professionals and executives of the Group, as well as members of the governing bodies of Group companies and stakeholders working with NH Hotel Group. More information on the Code of Conduct can be found in the “Ethics and Conduct” section of this Report.
Criminal Risk Prevention Model
It describes the principles applicable to the management and prevention of crimes within NH Hotel Group and defines the structure and operation of the control and oversight bodies established within the Company, systematising existing controls for the purpose of preventing and mitigating the risk of crime in the different areas of the Company.
Internal Rules of Conduct
These rules establish 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 for Conflicts of Interest
It establishes the rules to be followed in situations in which the interest of the Company or any of the Group companies comes into conflict with the direct or indirect personal interest of the directors or of persons subject to rules governing conflicts of interest.
COMPLIANCE COMMITTEE
Established in 2014, the Compliance Committee is made up of members of the Management Committee and presided over by the Chief Legal and Compliance Officer. It is responsible for overseeing compliance with the key areas of the Compliance System: the Internal Rules of Conduct, the Procedure for Conflicts of Interest, the Code of Conduct and the Criminal Risk Prevention Model, among others.
The Compliance Committee oversees the activity carried out by the Compliance Office and has the authority to take disciplinary measures against employees in relation to matters falling within its scope of competence.
Three meetings of the Compliance Committee were held in 2020.
COMPLIANCE COMMITTEE
The Compliance Office, under the leadership of the Compliance Officer, reports directly to the Compliance Committee and is responsible for spreading awareness of and monitoring compliance with the Code of Conduct and for preparing the Criminal Risk Prevention Model, as well as handling queries regarding the Code of Conduct.
In turn, the Head of Internal Audit is responsible for managing the confidential Whistleblowing Channel, which guarantees confidentiality and respect throughout all the phases of the procedure, as well as the absence of reprisals. The procedure is specified in detail in the Code of Conduct.
In 2020 a total of 38 alleged breaches of the Code of Conduct were reported, a decrease of 16% compared to 2019, and the pertinent disciplinary measures were applied, and a response was given to all 30 queries received.
After analysing the queries and alleged breaches reported through the whistleblowing channel or other formal mechanisms of the compliance office, none of them has resulted in a breach under any of the following categories:
In relation to these breach categories, the Company currently has no ongoing investigations initiated in 2020 or prior years and has not had to take any disciplinary action against any employee. Furthermore, it has not had to terminate any contract with any commercial partners due to incidents of corruption or any other type of incident included in the categories mentioned above.
NEW POLICIES APPROVED IN 2020
In 2020, following a favourable report by the Nominations, Remuneration and Corporate Governance Committee, the Board of Directors of NH Hotel Group has approved the updating of the Group’s Energy and Environment Policy, as well as the Human Rights Policy.
The approval of these Policies has been duly communicated to all employees, to ensure they are understood and observed.
Energy and Environment Policy
The updated Energy and Environment Policy was approved at the Board meeting held in July 2020. This Policy was updated to reinforce NH’s commitment to the wellbeing of its guests and efficient management of available resources in the environment where the Group’s hotels are located, in line with the main applicable international frameworks.
Human Rights Policy
Also, in July 2020, the Board of Directors approved the NH Hotel Group’s Human Rights Policy. The Policy establishes our commitment to respect Human Rights in accordance with the highest international standards and works to PROTECT, RESPECT AND REMEDY (prevent and manage) the risks associated to the breach of such rights.
The approval of these two policies is a milestone set in the context of the Company’s commitment to improve its performance in sustainability and the latest Corporate Governance recommendations that emphasize the need to promote policies such as Corporate Responsibility, Human Rights, Environment, etc. These policies also define the area of application and the promotion of the NH Hotel Group’s guiding principles among customers, suppliers and partners.
ETHICS AND CONDUCT
The framework for ethics in NH Hotel Group is based on its Code of Conduct. Responsibility for approving the Code of Conduct lies with the Board of Directors. The most recent update of the Code was in 2015.
The Code affects all the people who work at NH Hotel Group, and is applicable not only to employees, executives and members of the Board of Directors, but also to other stakeholders such as customers, suppliers, competitors or shareholders, as well to the communities where NH Hotel Group operates its hotels.
The Code of Conduct summarises the professional conduct that is expected of NH Hotel Group employees, who are committed to acting with integrity, honesty, respect and professionalism in carrying out their activities.
NH Hotel Group is committed to complying with laws and regulations in the countries and jurisdictions where it does business. This includes, among other matters, laws and regulations on health and safety, discrimination, tax, data privacy, competition, anti-corruption, prevention of money laundering and an environmental commitment. The key areas covered by the Code include:
to people
to customers
by suppliers
to competitors
to shareholders
to communities and society
to the group’s assets, knowledge and resources in relation to the securities market
in relation to fraudulent or unethical practices
The Code of Conduct is published in 6 different languages on the official website of NH Hotel Group and is available to all stakeholders. Furthermore, with effect from 2017, NH employees can access the code of conduct from their mobile devices using the “My NH” app. Employees at workplaces operating under NH Hotel Group brands have also been provided with a practical Guide and a FAQ document.
NH Hotel Group has set up a whistleblowing channel that allows employees, executives, members of the management bodies, suppliers, customers or any stakeholder to report confidentially and without fear of reprisals any breach of the Code of Conduct. The email address of the whistleblowing channel is available on the NH Hotel Group website and on the intranet and is managed by the Senior Vice President of Internal Audit.
There is currently no external investigation in progress against NH Hotel Group relating to the Code of Conduct or matters related to corruption.
AWARENESS OF AND TRAINING ON ETHICS AND CONDUCT
The Company has an online training tool for all NH Hotel Group employees with personalized mail through which they are provided with online courses on different matters, including the following courses relating to ethics and conduct:
• Code of Conduct
• Crime Prevention
• General Data Protection Regulation
• Prevention of money laundering and terrorist financing
• Antifraud and corruption
All courses on the above matters include an exam that measures employees’ level of comprehension. NH Hotel Group also has a supervision and control system for both the preparation of financial information (ICFR) and for criminal risks (Crime Prevention Model).
Compliance training 2020
ZERO TOLERANCE OF CORRUPTION
NH Hotel Group dispone de una Política de Antifraude y Corrupción, así como NH Hotel Group has an Anti-Fraud and Corruption Policy, as well as its Policy for the prevention of Money Laundering and Terrorist Financing, applicable to all employees, executives and members of the Board of Directors of NH Hotel Group.
In addition, NH has other internal procedures, such as the Gift Policy, that act as prevention measures and tools for massive data analysis that help detect suspicious transactions.
The Company carries out continuous monitoring and control of the policies and internal procedures. The Crime Prevention Model sets out explicitly the due diligence measures established by the Company, as well as the investigation procedure and response in the event of breach, in accordance with the law concerning the criminal responsibility of legal persons.
As indicated above, the Compliance Committee is responsible for managing crime prevention and, therefore, for the definition, implementation and supervision of the Crime Prevention Model.
CYBERSECURITY
At present, information security incidents are one of the main risks to which businesses are exposed. Accordingly, at NH Hotel Group we focus on strengthening computer security mechanisms and protocols, through polices, rules, procedures and employee training.
Accordingly, cybersecurity and GDPR training is aimed at fostering a culture of information security in the Company that will serve to establish the basis for the protection of both our confidential information and that of our customers, suppliers and other stakeholders.
NH Hotel Group’s strategy in relation to cybersecurity is under constant review in the committees of the Executive Management team that oversees the cybersecurity strategy. To achieve the goals that have been set, a range of initiative and measures are identified, planned and implemented to improve NH Hotel Group’s security capabilities and to prevent and/or mitigate any risk that may arise.
Remote working has increased due to the pandemic and also the use of devices outside the secured enterprise network. NH Hotel Group has increased the control of all the network with the implementation of tools that allow to prevent potential doubtful access, and has increased the awareness of this risks on his employees and stakeholders, aiming to minimize cyberattacks, an event that has increased during the crisis.
DATA PRIVACY AND PROTECTION
In a sector as competitive as the hotel business, the customer experience is a critical differential factor to ensure the satisfaction and loyalty of our customers. Aware that this is a key aspect in generating trust, NH Hotel Group has mechanisms in place to protect data privacy.
With the entry into force of the new data protection regulations in 2018, NH Hotel Group has continued to adapt its personal data management and control systems to EU Regulation 679/2016 (GDPR) and Spanish Act 3/2018 (LOPDGDD). NH Hotel Group’s intention is to process the personal data of its customers, employees and suppliers with the utmost guarantees of respect for their privacy and complying at all times with the applicable legal obligations.
Accordingly, the data protection sections of legal disclaimers, both on websites and on documents provided to customers, have been updated. The Company has also implemented measures to make these privacy policies and legal disclaimers accessible to customers at all times.
In the framework of this adaptation, the Company has implemented an additional information system that is available to end customers, so that they can discover each of the types of processing carried out by NH Hotel Group. All of this is set out in the NH Hotel Group privacy policy which can be accessed using the following link: https://www.nh-hotels.com/privacypolicy
Security is integrated comprehensively across all areas of the Company, covering profiles from different areas of operation to guarantee effective risk management, with due regard to the sensitive and critical nature of each environment. There are also risk indicators on the main matters of interest regarding security, that serve to define and implement action plans aimed at reducing or eliminating the threats identified.
In addition, NH Hotel Group has established several e-mail boxes for managing the data protection rights that are raised when personal data is collected, whether from customers, employees and/or suppliers, as well as to notify any type of incident and/or complaint related to data protection matters. Specifically, this last e-mail inbox is the one created for the Data Protection Officer. When a security matter is reported to the Data Protection Officer’s email, a process of evaluation of the notification starts in order to determine whether it is of relevant scope for protection purposes. If so, the incident is forwarded to the Departments of NH Hotel Group that could be involved, to assess the need for any communication to a Data Protection Supervisory Authority and/or to any data subjects that may have been involved in the incident. A written record is kept of this entire process.
As a Spanish company, the Supervisory Authority in relation to data protection for NH Hotel Group is the Spanish Data Protection Agency, with which it has regular relations through the agency’s online site.
As far as the Company’s employees are concerned, in their capacity as users of confidential data, they undergo mandatory training on data protection to ensure that they know how to process this information in compliance with the regulations. This training is provided when they join the Company and is noted and supervised by the Human Resources Department.
As mentioned above, NH Hotel Group has a Data Protection Officer, the duties of which are not just to comply with the requirements of the new regulations, but also to ensure, among other functions, that customers’ rights in relation to data protection are always handled by the organization in accordance with the principles established in the new regulations, and to act as a point of contact throughout the Company to clear up any doubts that may arise in relation to data protection. Finally, NH Hotel Group has continued in 2020 with the improvement project in relation to the quality of data within the organization.
NH Hotel Group has integrated the controls related to compliance with these regulations in its compliance model. Consequently, the risk management and IT departments are ultimately responsible for overseeing these controls, receiving any communication related to information privacy and reporting on a regular basis to the Audit and Compliance Committee and to the Board of Directors.
The Group’s compliance is supervised through periodic audits that ensure that NH Hotel Group complies in full with the requisites defined in the legislation on privacy, paying particular attention to the General Data Protection Regulation (GDPR).
The NH Hotel Group risk map contains a pillar called “compliance” linked to data privacy (GDPR) and information security with different management and control measures are in place such as:
• Periodic review and update of the risk matrix.
• “Privacy by Design” procedures.
• Creation of the Data Protection Office with the support of specialised advisors.
• GDPR training for employees.
• Existence of a whistleblowing channel to report possible security breaches related to data protection.
• Existence of a disaster recovery plan.
In the event of incidents in the information systems, NH Hotel Group also has a response procedure which includes roles and responsibilities, steps to follow in order to restore operation of equipment and systems, recovery times, etc.
1,602 hours of training in data privacy
and protection
To date no procedures have been initiated that could derive in a fine for the Company on account of a security breach affecting data protection.
RELATIONS WITH GOVERNMENTS AND POLICY INFLUENCE
The Company manages its business in accordance with its corporate values and its ethical and conduct framework. It also ensures strict compliance with ruling legislation in each country.
In relation to local governments, the Company always acts independently of any political power, maintaining transparency in its dealings with public and administrative institutions.
During 2020, NH Hotel Group has received various subsidies from governments to compensate the restrictive measures taken to mitigate the effects of COVID-19. The total amount of subsidies recorded in the year amounted to €58.8 million, which corresponds to personnel expenses of €36.9 million, social security of €15.8 million and other items of €6 million.
NH Hotel Group is characterized by absolute political neutrality. The Company does not make economic or other type of contributions to political parties or candidates in elections.
NH Hotel Group is, however, part of sectorial organizations or foundations linked to its activity or to the geographical area where it operates. Through its presence in these organizations, the Company aspires to contribute to the progress and development of the places where it is present. More information is available in the Chapter NH ROOM4 Responsible Shared Success: Sustainable Alliances.
PROTECTION OF HUMAN RIGHTS
The principle of respect for and protection of Human Rights is integrated into the culture of NH Hotel Group and is applied to the activities carried on through its professionals, independently of the country or region where the activity is carried out. The Company is committed to complying with Human Rights and works to prevent and manage the risks associated to the breach of such rights. NH Hotel Group’s international presence in countries where the defence of human rights needs to be boosted leads us to be transmitters of the concept and to ensure that frameworks of relations and management are in place through which the defence of these rights is assured.
INITIATIVES FOR THE PROTECTION OF HUMAN RIGHTS
NH Hotel Group carries out its activity in a framework of commitment to the society and environment wherever it operates, and therefore accepts the contents of national and international agreements and treaties, committing to promote and comply with them. These commitments will avoid or, as the case may be, mitigate any negative consequences that its activities might cause to Human Rights.
The commitments acquired upon subscribing to these international agreements guide the conduct of all the employees in the Company.
Notable among these codes voluntarily accepted by the Company are the UN Global Compact, support and contribution to the Sustainable Development Goals (SDG) and the Global Code of Ethics for Tourism, approved in 1999 by the Assembly of the UN World Tourism Organization (UNWTO). This code comprises 10 principles designed to guide key players in tourism development, aspiring to help to maximise the sector’s benefits while minimising its impact on the environment, cultural heritage and local communities.
Until 2020, the Group has also been part of the Sustainable Hospitality Alliance, formerly International Tourism Partnership (ITP), a global platform for leading companies in the hotel sector that share a common commitment to social responsibility and sustainability. This organization establishes four main goals which include the protection and promotion of Human Rights, a goal that NH Hotel Group subscribes to and supports.
The Company rejects any touristic activity that might constitute an attack on human rights or human dignity, placing special attention to children. Accordingly, in September 2012 NH Hotel Group joined ECPAT (End Child Prostitution, Child Pornography and Trafficking of Children for Sexual Purposes) for the protection of boys, girls and adolescents against sexual exploitation in tourism, also promoted by UNWTO and UNICEF.
HUMAN RIGHTS POLICY OF NH HOTEL GROUP
As a sign of this commitment, on July 29th, 2020, the Board of Directors approved the NH Hotel Group Human Rights Policy, a document that sets out all the principles and commitments undertaken by the Company in this regard.
The policy reinforces a sound and responsible governance model, that fosters transparent and responsible management on the basis of a single corporate document with global scope that, among other aspects, will make it possible not only to manage better the risks wherever NH Hotel Group is present, but also ensure knowledge and integration of the policy in the value chain. Through this Policy, the Company commits to play an active role in the promotion of Human Rights and to work proactively to this end. The Policy reflects the commitments already undertaken in this regard and guarantees respect for the labour rights of all employees and contractors, in all the countries where the Company is present, in accordance with ruling law in each region.
Relations with all stakeholders the Code applies to, should always be based on respect for human dignity and non-discrimination. The Company rejects all conduct, behaviour or action likely to foster, promote or incite, directly or indirectly, hatred, hostility, discrimination or violence against a group for racist reasons or other reasons referring to the ideology, religion or beliefs, family situation, membership of an ethnicity, race or nation, national origin, gender, sexual orientation or identity, illness or disability.
NH Hotel Group emphatically prohibits any kind of hostile or humiliating actions against people, the abuse of authority and any type of harassment, whether physical or psychological, as well as any other conduct that could generate an intimidating, offensive or hostile working environment. Furthermore, no child labour or forced labour is tolerated.
The Company also recognizes that the principle of equality of treatment and opportunities for addressees of the Code of Conduct is a value that inspires its Human Resources policies and is applicable both to the hiring of employees and to training, career opportunities or salary levels, as well as all other aspects of labour relations with employees.
The Code of Conduct also prohibits the imposition on employees of health and safety conditions at work that damage, suppress or restrict their rights as recognized by legal provisions, collective agreements or individual contracts. No form of illegal traffic of labour or fraudulent emigration is permitted, and applicable legislation will be respected at all times with regard to the entry and transit of foreign nationals.
The Code also explicitly states that the exercise of the rights of protest, association, organisation and collective bargaining in the framework of the rules regulating each of these fundamental rights and in accordance with international law and practice, in particular, the United Nations Universal Declaration of Human Rights and the principles proclaimed by the International Labour Organization, will not be unduly limited.
COMPLIANCE IN RELATION TO HUMAN RIGHTS
As described above, in order to guarantee compliance with the Human Rights Policy, the Internal Audit department supervises the principles and rules reflected in the Policy and, therefore, is responsible for analysing any irregularity related to it.
NH Hotel Group has a whistleblowing channel, in order to make it easy to report any possible irregularity, breach or behaviour contrary to ethics, law and the rules that govern the Company.
Possible breaches of Human Rights are handled through the Internal Audit department, which is responsible for managing the Group’s Whistleblowing Channel (codeofconduct@nh-hotels.com).
The Company has also put in place a specific external communication channel to report, process and manage incidents reported by suppliers (codeofconduct@coperama.com).
The procedure for reporting and dealing with possible breaches of the Code of Conduct will be managed by the Group’s Senior Vice President of Internal Audit.
As was the case in 2019, in 2020 there were no reports relating to a possible breach of human rights.
HUMAN RIGHTS DUE DILIGENCE
In the first half of 2020, as part of the corporate strategy, NH Hotel Group initiated a Human Rights Risk Management project which has been implemented in different phases:
• In the first phase, a process was carried out to identify the inherent human rights risks of the Company’s global operations with the subsequent publication of the policy that includes the commitment to respect and protect the rights identified in the business.
• In the second phase, a corporate Due Diligence Guide for Human Rights has been drawn up, as a support tool in applying the Protocol to all the Company’s operations. This Guide will serve as an instrument to increase control and efficiency of processes, mitigate the risk of damaging the reputation and favour the correct public positioning of the Company.
• Next steps for the protection of Human Rights: In 2021, NH Hotel Group will work on the Group’s due diligence process, to identify potential impacts on Human Rights in the value chain.
As a result of this commitment, Human Rights risks will be identified and monitored on the Company’s risk map in order to traction the pertinent mitigation or resolution processes. With this initiative, situations and activities with the highest (direct or indirect) risk of having a negative impact on these rights will be identified and assessed.