The Internal Information System of HELIOPAL S.A. is the channel to communicate, confidentially and effectively, any information about irregular facts committed by HELIOPAL S.A. or its personnel, which have been known within the framework of a work or professional relationship maintained with our organization in accordance with the provisions of Law 2/2023, of February 20.

This Information System can be used to communicate infractions produced in a work or professional context and may be used, in any case, by the following informants:

• a) people who have the status of employees or employed workers;
• b) self-employed workers;
• c) shareholders, participants, and people belonging to the administrative, management, or supervisory body of a company, including non-executive members;
• d) any person working for or under the supervision and direction of contractors, subcontractors, or suppliers.

Likewise, this system may be used by informants who communicate or publicly disclose information on infractions obtained within the framework of an already terminated employment or statutory relationship, as well as volunteers, interns, and workers in training periods, regardless of whether or not they receive remuneration. It may also be used by those persons whose employment relationship has not yet begun, when the information on the infractions has been obtained during the selection process or in the pre-contractual negotiation phase.

The organization has configured the Internal Information System through the following channels:

In writing:

• Through the following link to the complaint form: https://portaldenuncias.online/protecmir-hotel_son_caliu-0e17daca5
• Through postal mail: addressed to the Person Responsible for the Internal Information System of the organization HELIOPAL S.A. at Avenida Son Caliu nº 8, 07181 Palmanova (Calvià), Baleares..

Verbally:

• At the request of the informant, the information may be presented through a face-to-face meeting with the Person Responsible for the System, within a maximum period of seven days from the submission of the request.

Aside from these channels, communications can be filed before the external information channels of the competent authorities:

• Independent Authority for Informant Protection: via email at canal.externo@proteccioninformante.es
• You can find more information on the website: https://www.proteccioninformante.gob.es/

Procedure and conditions:

• Upon receipt of the complaint, the person responsible for the Internal Information System will communicate the acknowledgment of receipt of the complaint to the complainant within a period of less than 7 days, in cases of nominal complaints. In any case, the complainant will be informed of the rights and obligations established by the regulations on the protection of personal data.
• The person responsible for the Internal Information System will issue a reasoned report that will accept or dismiss the filed communication, justifying, in any case, the decision adopted. The report will be notified to the informant and to the affected person within a maximum period of 3 months from the expiration of the seven-day period after the communication is made, except in cases of special complexity that require an extension of the period, in which case it may be extended up to a maximum of another three additional months.
• During the processing of the complaint, communication and contact with the informant/complainant can be maintained and, if considered necessary, additional information may be requested from the informing person.
• It is guaranteed that the person affected by the information or complaint has notice of it, as well as of the facts related in a succinct manner. Additionally, they will be informed of their right to submit written allegations and of the processing of their personal data. However, this information may be provided during the hearing procedure if it is considered that providing it earlier could facilitate the concealment, destruction, or alteration of evidence.
• The person responsible for the Internal Information System/complaint channel guarantees confidentiality to all those who use the Internal Information System/complaint channel. Furthermore, confidentiality is guaranteed when the communication is sent through complaint channels other than those established or to members of the staff who are not responsible for its processing.
• During the processing of the file, the persons affected by the communication will have the right to the presumption of innocence, the right of defense, and the right of access to the file, as well as to the same protection established for informants, preserving their identity and guaranteeing the confidentiality of the facts and data of the procedure.
• The processing of personal data derived from the application of this procedure will be governed by the provisions of Regulation (UE) 2016/679 of the European Parliament and of the Council, of April 27, 2016, in Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights, and in Organic Law 7/2021, of May 26, on the protection of personal data processed for the purposes of prevention, detection, investigation, and prosecution of criminal offenses and the execution of criminal penalties.
• The person responsible for the Internal Information System/complaint channel will immediately forward the information to the Public Prosecutor’s Office when the facts could circumstantially constitute a crime, or to the European Public Prosecutor’s Office in the event that the facts affect the financial interests of the European Union.
• The organization guarantees the absence of retaliation against anyone who brings a possible unlawful conduct to its attention, has communicated a regulatory breach, collaborates in its investigation, or helps to resolve it.
• Persons who communicate or disclose infractions included in Art. 2 of Law 2/2023, of February 20, and actions or omissions that may constitute a serious or very serious criminal or administrative infraction, will be entitled to protection measures provided that the conditions included in article 35 of the aforementioned regulation are met. The protection measures are set forth in article 38 of Law 2/2023, of February 20.
• The complaint or information will be safeguarded in the facilities of the organization in accordance with its document archiving and conservation policy.
• The organization has a registry of all complaints received. The complaints will be kept only for the period that is necessary and proportionate in order to comply with the requirements imposed by Law 2/2023, of February 20, regulating the protection of persons who report on regulatory infractions and the fight against corruption, and in accordance with the provisions of article 24 and other applicable articles of Organic Law 3/2018, of December 5, on the Protection of Personal Data and guarantee of digital rights.

LINK TO THE COMPLAINT FORM: https://portaldenuncias.online/protecmir-hotel_son_caliu-0e17daca5