It´s a secure mechanism that can be used to report any infringement or violation that has been committed, is being committed or whose commitment can reasonably be foreseen, in the scope of action of Real Hotels Group (RHG).

You can also communicate any attempt to conceal infringements or violations that Real Hotels Group should be aware of.

The Whistleblowing Channel is a self-regulation and self-control instrument that will allow the RHG, in front of facts known and reported in good faith, to act and correct any deviant and unlawful actions, in order to prevent their future occurrence, guaranteeing scrupulous compliance with the law, regulations and procedures in force, both internal and external.

Acts or omissions contrary to nation or community rules, including those that provide for crimes or administrative offenses relating to public procurement, financial markets and prevention of money laundering, product safety and compliance, transport safety, environmental protection, radiation protection and nuclear safety, food and animal food safety, animal health and welfare, public health, consumer protection, privacy and personal data protection and network and information systems security.

You can also report any act of corruption or related infringement, committed, being committed or whose commitment is reasonably foreseen, contrary to and harmful to the European Union financial interests, or contrary to the internal market rules, including competition rules and state aids rules, and even violent criminal acts, especially violent or highly organized.

Corruption is defined by the practice of an act or omission, whether lawful or unlawful, against the receipt or promise of receipt of a consideration that is not due to a person or to a third party.

The crimes of corruption (active and passive), undue receipt and offer of advantage, embezzlement, economic participation in business, concussion, abuse of power, prevarication, influence peddling, money laundering or fraud in obtaining or diverting subsidy, grants or credits, all provided for in the Portuguese Criminal Code.

The report must be as detailed as possible, objectively transmitting the facts that you are aware of and documents or other evidence that you have, requesting you to fill the form available on the page for this purpose.

The report must always be submitted through the “Whistleblowing Channel”, but if you do so by other written means (postal letter), the complaint will be immediately transmitted, without any modification, to the team or person dedicated to receiving and handling complaints, for their registration and treatment.

You may also request, via e-mail to: canaldedenuncia@realhotelsgroup.com, a face-to-face meeting, to be scheduled, to report the complaint. In this case, the employee assigned to the registration and treatment of complaints will proceed with the written report, whose content will be confirmed and validated by the person who made the claim, by means of affixing a signature.

The report must be as detailed as possible, objectively transmitting the facts that you are aware of and documents or other evidence that you have, requesting you to fill the form available on the page for this purpose.

The report must always be submitted through the “Whistleblowing Channel”, but if you do so by other written means (postal letter), the complaint will be immediately transmitted, without any modification, to the team or person dedicated to receiving and handling complaints, for their registration and treatment.

You may also request, via e-mail to: canaldedenuncia@realhotelsgroup.com, a face-to-face meeting, to be scheduled, to report the complaint. In this case, the employee assigned to the registration and treatment of complaints will proceed with the written report, whose content will be confirmed and validated by the person who made the claim, by means of affixing a signature.

After submitting the complaint on the RHG Whistleblowing Channel, the whistleblower is notified within 7 days of receipt of the complaint and other information.

The person in charge processes with the verification of the allegations, asking the whistleblower, if necessary, for additional clarifications that can validate and complete the veracity of the facts that were transmitted and adopt the procedural steps that are most appropriate, including communication to the competent authority to investigate the infringement, if necessary.

The RHG communicates to the whistleblower, within a maximum period of three months from the receipt of the complaint, the measures programmed or adopted to follow up on the complaint and the respective grounds.

Right to Anonymity

• To benefit from anonymity, you must select this option when filling out the form.
• Please bear in mind, however, that anonymity will not allow, at this stage, to be notified, nor to be asked for additional clarifications regarding the reported facts.
• It is also warned that the presentation of a complaint by email or in a face-to-face meeting guarantees the confidentiality of the whistleblower’s identity, but not his or her anonymity.

Right to identity confidentiality / Protection of Personal Data

• The identity confidentiality is always guaranteed, except in situations of compliance with a legal obligation or court decisions;;
• The Whistleblowing Channel is operated by employees dedicated to receive, process and follow up on complaints, ensuring their independence, impartiality, secrecy, absence of conflict of interests and respect for data protection in the exercise of these functions.
• The Whistleblowing Channel is only operated by employees specifically designated for this purpose, whose access to unauthorized persons is prohibited.
• The processing of personal data collected through the complaint form complies with the provisions of the RHG Data Protection and Privacy Policy.

Right to Whistleblower Protection, conferred by Law no. 93/2021, of December 20

The reporting of an infraction or violation, made in good faith and having a serious basis for believing that the information, at the time of the reporting, is true, grants the whistleblower the conditions of protection contained in Law no. 93/2021, of 12.20, of which the following stand out:

_Right to non-retaliation:

The whistleblower is especially protected against possible acts of retaliation, acts or omissions or attempts that, directly or silently, occurring in a professional context and motivated by an internal complaint, cause or may cause the whistleblower, in an unjustified way, property damages or non-property damages.

_Support measures:

The whistleblower is entitled, in general terms, to legal protection and may benefit, in general terms, from measures of witness protection in criminal proceedings.

The reporting of an infraction, carried out in accordance with the requirements of Law no. 93/2021, of 20.12, does not constitute grounds for disciplinary, civil, misdemeanor or criminal liability of the complainant.

Right to follow the Complaint:

• The whistleblower will be notified, within seven days, of receipt of the complaint;
• The whistleblower will be notified, within a maximum period of three months from receipt of the complaint, in accordance with the measures planned or adopted, to follow up on the complaint and the respective grounds.
• The whistleblower may request, at any time (once 15 days have elapsed after processing the complaint), to be notified of the result of the analysis carried out on the complaint.

Right to Add new elements or clarifications to the Complaint

• After submitting the form, you will be given the “Complaint Reference” number, as well as the “Data”, which you should keep for future submissions.

• The use of the Whistleblowing Channel is an exercise of citizenship, so its misuse and/or the conscious provision of false statements may compromise it’s purpose.
• It is the duty of the whistleblower to report in good faith, presenting substantiated and detailed evidence/facts and, as much as possible, accompanied by proofs and documents.

It is clarified that the protection of the whistleblower does not remove the rights or procedural guarantees recognized, in general terms, to the persons targeted in the complaint, who, if the complaints directed against them are not proven, have the right to take legal action, namely, under the provisions of article 365 of the Portuguese Criminal Code, according to which «Whoever, by any means, in front of authority or publicly, with the awareness of the falsehood of the imputation, denounces or casts on a certain person the suspicion of the committing of a crime, with intent that criminal proceedings are instituted against it, shall be punished with imprisonment for up to 3 years or with a fine. If the conduct consists of falsely imputing an administrative offense or disciplinary misconduct, the agent is punished with a prison sentence of up to 1 year or a fine of up to 120 days.»

Brevemente disponível.

RHG guarantees the safeguarding of the right to protection of all Personal Data, in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council, of April 27, 2016, as amended, regarding the protection of natural persons with regard to the processing of personal data and the free movement of such data and which repeals Directive 95/46/CE (General Regulation on Data Protection), which are provided by the holder, through this form and whose treatment is carried out confidentially, and RHG employees are bound by the duty of secrecy.

Definitions:

«Personal Data», means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

«Processing», means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

The consent of the data subject must be given through a positive and clear act that indicates a free, specific, informed and unequivocal expression of will that the data subject consents to the processing of data concerning him for the purposes of processing this request, namely special categories of data, pursuant to article 9, paragraph 1 and/or article 10, both of the RGPD.

The personal data collected will be subject to computer processing within the exclusive scope of this Whistleblowing Channel.

Direito à Informação

Responsible for treatment → Coming soon;

Data Protection Officer → epd@rhg.pt;

• Eventually and under his own free initiative, the Holder of personal data may transmit sensitive personal data to RHG, under art. 9, no. 2, of the RGPD, so that RHG can process them in accordance with the strict purposes.
• The Data subject to treatment are intended solely for the processing of the Complaint;
• The Data made available can be accessed and changed by its Holder, including rectification, erasure or limitation in its treatment;
• The Holder of the personal data has the right to object to its treatment;
• Personal Data that is clearly not considered relevant for the processing of the Complaint will be immediately deleted;
• The personal data collected is not subject to automated decisions, including profiling;
• The Data Subject has the right to file a Complaint with the control authority – National Data Protection Commission;
• Within the scope of this Whistleblowing Channel, the processing of personal data does not constitute any legal or contractual obligation;
• The data subject may withdraw his consent for the processing of personal data, whenever this treatment depends on it.

The complainant, the data subject, declares that he is aware of the Data Protection and Privacy Policy and clearly and expressly consents that he AUTHORIZES this Entity to process the data made available, for the purposes of the Whistleblowing Channel – Form.

Clink: RHG Privacy Policy