WhistleBlowing Policy
1. Purpose
The purpose of this document is to present the Web Policy of the Internal Information System in order to comply with Article 25 of Law 2/2023, of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption, as well as to comply with the rest of the national regulations that transpose the aforementioned directive in the countries in which MIRAI GROUP operates.
The aforementioned article establishes that:
“Entities falling within the scope of application of this law shall provide adequate information in a clear and easily accessible manner regarding the use of any internal reporting channel they have implemented, as well as the essential principles of the management procedure. If they have a website, such information must be included on the homepage, in a separate and easily identifiable section.”
Accordingly, this document and access to the whistleblowing form can be found on the following websites:
2. Web Policy of the Internal Information System
Internal Information System Policy
In compliance with Law 2/2023 of February 20, regulating the protection of persons who report regulatory infringements and the fight against corruption, which transposes into Spanish law Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019—commonly known as the Whistleblowing Directive—as well as in compliance with the national regulations that transpose this directive in the countries in which we operate, MIRAI GROUP has implemented a single Internal Information System common to all the entities that form the group.
The purpose of this system is to establish a reporting channel through which individuals can communicate information regarding irregularities and cases of workplace harassment.
MIRAI GROUP is made up of the following entities:
“Entities falling within the scope of application of this law shall provide adequate information in a clear and easily accessible manner regarding the use of any internal reporting channel they have implemented, as well as the essential principles of the management procedure. If they have a website, such information must be included on the homepage, in a separate and easily identifiable section.”
Accordingly, this document and access to the whistleblowing form can be found on the following websites:
- MIRAI ESPAÑA, S.L.
- MIRAI USA LLC
- MIRAIFUTURE PORTUGAL, LDA
- MIRAI FRANCE, SARL
- MÉXICO MIRAI HOTELIER S. DE R.L. DE C.V.
- HERATON SYSTEMS, S.L.
- NEXIA SOLUTIONS S.L.
The Board of Directors of MIRAI ESPAÑA, S.L. has appointed a Responsible Officer for the Internal Information System, who will be responsible for receiving and processing all communications submitted through the reporting channel.
How can I submit a report?
If you are aware of the commission of any infringement by personnel of MIRAI GROUP, or have reasonable grounds to believe that one is occurring, you must report this in writing through the web portal:
https://demo-4c19318e0bf80d55f2de.factorialhr.es/complaints
Additionally, if you wish to report the matter in person to the Responsible Officer of the Internal Information System of MIRAI GROUP, you must indicate this in the description section of the communication form mentioned above.
Please note that you have the right to submit reports anonymously if you consider it appropriate.
In the case of reports received by MIRAI ESPAÑA, S.L. that are related to workplace harassment, the reporting person must identify themselves in order to ensure their protection as a victim of harassment.
Who is protected against retaliation for submitting a report?
MIRAI GROUP is fully committed to compliance with the applicable legal framework and maintains a zero-tolerance policy toward irregularities. Any person may submit a report to MIRAI GROUP if they are aware of an infringement committed by MIRAI GROUP personnel or have reasonable grounds to believe that one is occurring.
MIRAI GROUP formally commits to prohibiting any type of retaliation against whistleblowers acting in good faith.
Under no circumstances will the personal data of the whistleblower be disclosed to the reported party.
What matters can be reported?
Whistleblowers will benefit from all protection mechanisms when reporting in good faith matters related to:
- Public procurement
- Financial services, products, and markets
- Prevention of money laundering and terrorist financing
- Product safety and compliance
- Transport safety
- Environmental protection
- Radiation protection and nuclear safety
- Food and feed safety, animal health, and animal welfare
- Public health
- Consumer protection
- Protection of privacy and personal data
- Security of networks and information systems
- Infringements affecting the financial interests of the EU
- Infringements related to the internal market, including competition and state aid rules, as well as infringements related to corporate tax or practices aimed at obtaining an improper tax advantage that undermines the purpose of applicable corporate tax legislation
In addition to the specific matters listed above, whistleblowers will also be protected when reporting any action or omission that may constitute a criminal offense or a serious or very serious administrative infringement, particularly those related to financial damage to the Public Treasury or Social Security, in accordance with Spanish law and the national regulations applicable in the countries where MIRAI GROUP operates.
If a report is related to potential sexual harassment or harassment based on sex at MIRAI ESPAÑA, S.L., the facts will be referred to the Investigating Committee of the Harassment Protocol in order to process the complaint in accordance with the “Protocol for the Prevention of and Response to Sexual Harassment and Harassment Based on Sex.”
In the remaining entities of MIRAI GROUP, cases of workplace harassment, sexual harassment, or harassment based on sex will be governed by this procedure where no specific protocol exists.
How will MIRAI handle the reports it receives?
As a general rule, MIRAI GROUP will acknowledge receipt of the submitted report within a maximum period of seven days from its receipt and will process it in accordance with MIRAI GROUP’s internal report management procedure.
The maximum period for processing reports will be three months, except in cases of special complexity, in which case the period may be extended by an additional three months.
The report management procedure is governed by the following principles:
- Zero tolerance for irregularities
- Effective and diligent handling of received reports
- Objective and impartial processing of reports
- Implementation of a secure channel for reporting and managing information
- Guarantee of confidentiality of the whistleblower’s identity and of any third parties mentioned, as well as of the actions carried out during the process
- Access limited to the minimum personnel strictly necessary
- Protection of whistleblowers acting in good faith, preventing any form of retaliation, threat, or attempt of retaliation
- Protection of affected persons, ensuring they are informed of the actions or omissions attributed to them, while respecting their right of defense, right to be heard, presumption of innocence, and right to honor
- Immediate communication and cooperation with competent authorities when the reported facts may constitute a criminal offense
Reports related to workplace harassment at MIRAI ESPAÑA, S.L. will follow their own specific procedure, of which MIRAI ESPAÑA, S.L. staff have been duly informed.
How can I clarify questions related to MIRAI GROUP’s internal reporting channel?
We are available to answer any questions you may have regarding MIRAI GROUP’s internal reporting channel.
You may contact the Responsible Officer of the Internal Information System at:
https://demo-4c19318e0bf80d55f2de.factorialhr.es/complaints
Data Protection Information Notice
Please be advised that the personal data provided through submission of this form will be processed by Mirai España, S.L. for the purpose of managing the report.
You may exercise your data protection rights by contacting: protecciondatos@mirai.com.
Additional information on the processing of your data can be found in our Whistleblowing Policy.
