Compliance and Anti-bribery Policy:

HIP carries out its activity concerned with regulatory compliance in the business services sector and, on this basis, has taken the decision to implement a Criminal Compliance and Anti-bribery Management System in accordance with the requirements established in the UNE 19601 and UNE-ISO 37001 standards, respectively.

For all these reasons, HIP requires all its collaborators to comply with the legal system and the prohibition of committing criminal acts, with special reference to the prohibition of bribery.

Code of Conduct:

At HIP we are committed to the principles of business ethics and transparency in our daily professional development. Respecting and enforcing the principles and standards of conduct that make up our Code of Conduct is crucial to HIP's growth and success.

We pursue long-term value creation and our consolidation in the industry, while maintaining a firm and constant commitment to the well-being and development of our staff and to society in general.

For this reason, all collaborators of HIP are obliged to comply with the principles set out in this Code and to use HIP’s Communications Channel to report any irregularities or inappropriate behavior that they observe.

Anti-corruption Policy:

For greater security and legal protection of HIP and their collaborators, it is necessary that we all act in accordance with ethical and law-based criteria. We have developed an Anti-corruption Policy as a further manifestation of our compliance culture, promoted by both HIP’s Board of Directors and Executive Committee.

This Policy should be understood as a fundamental rule that demonstrates HIP's zero tolerance towards corrupt practices and aims to establish and make known the essential principles established therein, as well as a series of guidelines for specific situations in order to avoid any risk of corruption in the public and/or private sector.

Communication and Whistleblowing Procedure:

Within the Criminal and Anti-bribery Compliance Management System and in accordance with the provisions of the Criminal Code, HIP has established a double communication channel for its professionals, clients and suppliers:

 

a) On the one hand, the communication of Incidents can be made directly to the Chief Compliance Officer (CCO) verbally or in writing, via the following e-mail address: andrea.schroder@hipartners.com;

 

b) On the other hand, through an external and confidential communication channel for notifying any indication or suspicion of non-compliance with the law, via the following e-mail address: canalhipartners@cuatrecasas.com.

Corporate Guidelines for Hotel Managers:

Given the special and close relationship between HIP, its subsidiaries and managed companies, and their hotel managers, HIP has decided to develop a guide to ensure that hotel managers are committed to putting in place sufficient measures to prevent crimes being committed in the hotels.

The Manual is intended to be a compendium of minimum control guidelines that hotel managers contracted by HIP, its subsidiaries, or its managed companies, must implement in the hotel establishments they are entrusted to manage.

Thus, HIP has proceeded to identify those criminal risks inherent to its activity and, in order to mitigate them to a reasonable level, has designed a set of control measures to be implemented.

That said, the guidelines set out in the Manual are sufficiently generic to serve any of the hotel establishments owned by HIP, its subsidiaries, or its managed companies, and it is therefore the responsibility of the hotel manager to adapt the implementation of these guidelines to the resources available to it and to the circumstances that arise,  and to deploy control measures that are at least equivalent in effectiveness to those contained in this Manual.