The Whistleblowing Channel is exclusively for reporting violations/infractions specifically related to those described in: “What violations can I report?”.
If the reason for your report or complaint is not connected with the type of infractions foreseen in that point, we kindly ask you to direct your denouncement or complaint to the proper channels.
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
Right to identity confidentiality / Protection of Personal Data
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:
Right to Add new elements or clarifications to the Complaint
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;
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
