Internal information system

The Internal Information System of ILLA D’OR S.A. is the channel to confidentially and effectively report any irregularities committed by the company or its staff that become known within the framework of a professional or employment relationship with our organization, in accordance with the provisions of Law 2/2023, of February 20.

This internal information system is established, in accordance with Article 12 of Law 2/2023, of February 20, as a shared system for the following companies: HOTELERA POLLENSINA S.A. / ILLA D’OR S.A. / ARRENDAMIENTOS Y EXPLOTACIONES POLLENTIA S.L. / HOTEL CALA EN BLANES S.A. / ALOJAMIENTOS TURÍSTICOS VILLA CONCHA S.L., whereby the company HOTELERA POLLENSINA S.A. assumes the management and processing of communications submitted through this internal reporting channel or system.

The organization has set up the Internal Information System through the following channels:

• In writing:
• By email: [email protected]
• By postal mail addressed to the Person Responsible for the Internal Information System of ILLA D’OR S.A., at Calle de la Vela, Nº 8, 07470 Puerto de Pollensa, Balearic Islands.
• Orally:
• At the request of the informant, the report may also be submitted through a face-to-face meeting with the System Manager, within a maximum period of seven days from the date of the request.

 

Independent Whistleblower Protection Authority: Reports can also be made via email to [email protected]. Further information is available at: https://www.proteccioninformante.gob.es/

- Upon receipt of the report, the System Manager will acknowledge receipt to the whistleblower within seven days in the case of identified (non-anonymous) reports. In all cases, the whistleblower will be informed of the rights and obligations established by personal data protection regulations.

-The System Manager will issue a reasoned report, accepting or rejecting the communication and justifying the decision taken in each case. The report will be communicated to both the informant and the affected person within a maximum period of three months from the end of the seven-day period following submission of the report. In complex cases, this deadline may be extended by up to an additional three months.

-During the processing of the report, communication with the informant/whistleblower may be maintained, and if necessary, additional information may be requested.

-Se garantiza que la persona afectada por la información o denuncia tenga noticia de la misma, así como, de los hechos relatados de manera sucinta. Adicionalmente, se le informará del derecho que tiene a presentar alegaciones por escrito y del tratamiento de sus datos personales. No obstante, esta información podrá efectuarse en el trámite de audiencia si se considerara que su aportación con anterioridad pudiera facilitar la ocultación, destrucción o alteración de las pruebas.

-The organization ensures that the person affected by the report is informed of the facts in a summarized form, as well as of their right to submit written arguments and to be informed about the processing of their personal data. However, this notification may be postponed to the hearing stage if earlier notification could facilitate concealment, destruction, or alteration of evidence.

-The Internal Information System Manager guarantees confidentiality for everyone using the reporting channel, including cases where reports are sent through non-official channels or to staff members not responsible for handling them.

-During the investigation, the persons affected by the report are guaranteed the presumption of innocence, the right of defense, and access to the file, as well as the same protection granted to whistleblowers, including preservation of identity and confidentiality of facts and data related to the procedure.

-The processing of personal data arising from this procedure will comply with Regulation (EU) 2016/679 (GDPR), Organic Law 3/2018, of December 5, on Personal Data Protection and Digital Rights, and Organic Law 7/2021, of May 26, on the protection of personal data processed for the purposes of crime prevention, investigation, detection, prosecution, and enforcement of criminal penalties.

-The System Manager will immediately refer any information suggesting the existence of a criminal offense to the Public Prosecutor’s Office, or to the European Public Prosecutor’s Office if the facts affect the financial interests of the European Union.

-The organization guarantees no retaliation against anyone who reports possible illegal conduct, regulatory non-compliance, or who collaborates in its investigation or resolution.

-Persons who report or disclose infringements referred to in Article 2 of Law 2/2023, of February 20, and acts or omissions that may constitute a serious or very serious criminal or administrative offense, will have the right to protective measures, provided the conditions set forth in Article 35 of the same law are met. The protection measures are set out in Article 38 of the law.

-Reports and related information will be securely stored on the organization’s premises, in accordance with its document retention and archiving policy.

-The organization maintains a register of all reports received. Reports will be kept only for the period necessary and proportionate to meet the requirements established by Law 2/2023, of February 20, on the protection of whistleblowers and the fight against corruption, and in accordance with Article 24 and other applicable provisions of Organic Law 3/2018, of December 5, on Personal Data Protection and Digital Rights.