Complaint channel policy

The CETT launches its complaints channel adapted to the new regulations.

Opening this path, we maintain our commitment not only to compliance with current legislation, but also to the promotion of a true ethical culture and corporate integrity in our daily activities.

You can access from the following link:

General Policy of the Internal Information System of ESTUDIS D'HOTELERIA I TURISME CETT, S.A.

1. Purpose

The purpose of this Policy is to establish the general principles of the Internal Information System, by the provisions of Law 2/2023, of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption.

Likewise, this Policy demonstrates the commitment of Estudis d'Hoteleria i Turisme CETT, SA (from now on CETT) to regulatory compliance, ensuring protection against possible retaliation of those who report regulatory violations in an employment or professional relationship.

2. Scope of application

This Policy applies to all persons referred to in Article 3 of Law 2/2023, of February 20, regulating the protection of persons who report regulatory violations and the fight against corruption.

Through the internal information system (whistleblower channel), the following actions or omissions may be reported, as provided for in Article 2 of Law 2/2023:

(a) Infringements of European Union (EU) law provided they fall within the scope of the EU acts listed in the Annex to Directive 2019/1937 of the European Parliament and of the Council of 23 October 2019 and that affect the financial interests of the EU or have an impact on the internal market.

b) Within the scope of the Spanish legal system, severe criminal or administrative offenses. In any case, all those criminal or administrative offenses that involve economic loss for the Public Treasury and Social Security shall be included.

3. Responsibility for the Internal Reporting System

CETT Board of Directors is responsible for implementing the Internal Information System and has appointed a person responsible for the “complaints channel”, who will carry out these functions independently and autonomously.

4. General principles of the Internal Reporting System

The basic principles on which this Policy is based are those detailed below:

• Legality: Communications will be processed in compliance with current legislation, especially with the provisions of Law 2/2023, of February 20, and with the applicable legislation on personal data protection.
• Protection of the informant: This is the guiding principle of this Policy, as evidenced by the existence of a specific system of protection against possible reprisals that may be suffered by persons who report regulatory violations.
• Protection of persons affected by the communication: The Internal Reporting System shall provide the same protection to the persons affected by the communication as for whistleblowers.
• Respect for fundamental rights: In the communication management process, all fundamental rights of the persons involved in the communication shall be safeguarded, especially the right to the presumption of innocence, the right to honor, and the right to defense.
• Confidentiality: The Internal Reporting System shall guarantee maximum confidentiality regarding the identity of the informant, the persons mentioned in the communication, the information communicated, and the actions carried out as a result of processing communication.
• Anonymity: The Internal Reporting System shall allow for anonymous reporting. Appropriate technical and organizational measures shall be adopted to guarantee anonymity when the informant opts for this mode of communication.
• Autonomy and independence: The Head of the Internal Reporting System shall enjoy autonomy and independence from any other body of the organization, so that he/she shall manage communications with the utmost impartiality.
• Diligence: The System Manager will be responsible for efficiently processing the communications received.
• Transparency: Information on the Internal Information System will be available on the CETT website and corporate intranet and will be transmitted clearly and understandably.
• Good faith: The System Manager will ensure that the information communicated is honest, complete, and truthful, rejecting those communications that lack all truthfulness.

5. Ways to report regulatory violations

A link called “complaint channel policy” is available on CETT's corporate website and will allow access to a specialized platform. This platform has adequate technical measures to guarantee the confidentiality and security of the information, as well as anonymity when opting for this method of communication.

At the informant's request, it may also be submitted through a face-to-face meeting within a maximum of seven days. This meeting may be held via videoconference or other telematic means available at any given time depending on the available technology.

6. Approval, entry into force and dissemination

CETT's Board of Directors is the competent body for the approval of this Policy. It will be published on CETT's corporate website. The person in charge of the Internal Reporting System shall agree with the person in charge of CETT's Team Management and Development Service, on the necessary training actions for the correct dissemination of the Internal Information System and the culture of compliance and the purposes of Law 2/2023.

This Policy will be reviewed and updated whenever necessary.

Barcelona, July 17th 2024

Board of Directors