Code of ethics

This Code represents the commitment of MAC Hotels to comply with the law, reflecting the corporate and ethical values, institutional, business and organisational principles that serve as a guide for appropriate conduct, guaranteeing the right thing to do and that, as a logical consequence, no crime is committed in the company. The Code of Conduct offers the guidelines that clarify the basic principles of all management and interpersonal relations with colleagues, collaborators, bosses, suppliers, clients, shareholders and in general any person with a direct or indirect interest in the activity carried out by the company. Our actions are based on respect for our corporate values, and our employees will adapt their actions to principles of behaviour respectful of business ethics and professionalism, with the aim of being a benchmark in these terms and being recognised as such.

We are aware that in our daily activities some of our activities may affect the image and reputation of the company, and that what we do is as important as the way in which we do it, which is why it is essential that all those associated with MAC Hotels act in accordance with our ethical conduct.

1- Scope of application

The Code constitutes a guide for people at all levels of the company, including management bodies, management positions, control bodies and, in general, all MAC Hotels employees, regardless of the type of contract that determines their employment relationship.

It also applies to and extends to all those who, without forming part of the MAC Hotels structure, are related to us as suppliers, distributors or customers, among others. For maximum dissemination and effectiveness, this Code will not only be made known through the corresponding training courses or included in the contracts that we may formalise, but will also be available for consultation on the company’s website https://www.mac-hotels.com/es/

2- MAC HOTELS Values and Commitments

2.1. VALUES

Our values represent our identity as a group and are the core of everything we stand for. We are different because the people who work at MAC Hotels make this company a unique and differentiating project, taking honesty, integrity and exemplarity as the banner of our values. We are fast, we know how to listen not only to the client, but also to the different opinions of those who make up our work group, we respect opinions and turn diversity into an opportunity for growth, we seek innovation and how to make the most of it by focusing on improving the environment and sustainability, we are helpful and we work as a team in a rigorous and transparent way, which allows us to:

– Act quickly and dynamically.

– To propose realistic, quality and viable alternatives to any problem or incident that may arise

– Adapt quickly to the changes and demands of one of the most demanding and competitive sectors.

– To know exactly the needs of the customers of our establishments and to anticipate them.

– To constantly update our technological knowledge in order to be pioneers in innovation.

– To serve our customers efficiently, maintaining at all times an agile and decisive behaviour that enhances the credibility and reputation of the company and its professionals.

– We know how to work in multidisciplinary teams, from different units, companies and countries, generating a climate of trust and mutual respect.

2.2 COMMITMENTS

At MAC Hotels we make commitments to our employees, customers, suppliers, society and the environment in order to live up to our values. These commitments apply to all levels and departments of the company and, therefore, are extensible to all the people who make up the MAC Hotels family.

Together with this Code of Ethical Conduct or Code of Ethics, we have developed, in line with the United Nations Global Compact and contributing to the Sustainable Development Goals, SDGs, which aim to put an end to poverty, protect the planet and guarantee the global well-being of people by 2030, a Corporate Social Responsibility policy focused on three fundamental pillars, such as social, labour and environmental, with the development of strategic objectives for each of these pillars.

Only if everyone in the company assumes the responsibility, in the exercise of our daily activities, to work in accordance with our policies, instructions and internal rules, will we be able to achieve our commitment to:

– Comply with and enforce compliance with applicable laws

– Offer opportunities for professional and personal development while respecting the labour rights of all our employees

– Collaborate in the development of the communities in which we operate

– Contribute to the preservation of the environment by ensuring awareness of the particularities of the territory in which we operate and the resources at our disposal, in order to achieve environmental balance

– Promote free competition and transparency

3- Principles of ethical behaviour

The ethical behaviour that governs MAC Hotels and our relationship with the different stakeholders is based mainly on the following principles:

Good faith. We always act in accordance with the principles of loyalty and good faith. We emphasise the desire to achieve and the spirit of self-improvement, promoting optimistic vs. pessimistic attitudes. We subordinate personal objectives to the general objectives of the Company. We ensure that there is no conflict between the two, and we act giving priority to the interests of the company over personal interests or those of third parties. We do not engage in outside interests that divert our time and attention from our responsibilities at MAC Hotels.

Honesty. All of us at MAC Hotels undertake to declare any personal or professional relationship that could condition the way we act within the company. Furthermore, as employees of MAC Hotels, we do not accept or offer compensation, undue advantages, gifts or promises of favourable treatment, always ensuring that relations with collaborators, suppliers and distributors are governed by the principles of free competition and transparency, avoiding any act that could be considered unfair competition. We instil honesty and professional ethics in our commercial relations with our end customers, offering clear and truthful information in our advertising campaigns, as well as in the professional relations we maintain in the performance of our work.

Respect. We promote work in an atmosphere of cordiality and a friendly environment in which respect and trust between people prevails. We appreciate and conceive diversity in opinions, training and culture as a source of knowledge and competitive advantage. We are careful about the language we use when talking about third parties and we encourage the absence of defamatory comments and patterns within and outside the organisation. We promote respect for real equality of opportunity between men and women, avoiding any scenario of direct or indirect discrimination.

No person employed at MAC Hotels is discriminated against in the professional sphere on the grounds of race, physical disability, religion, age, nationality, sexual orientation, sex, political opinion or social origin, and we demand the same of all those who wish to maintain any kind of professional relationship with us. We maintain a working environment free of any discrimination and of any conduct involving harassment of a personal nature, and we do not accept any form of physical, sexual, psychological or verbal harassment or abuse. We respect the environment and collaborate with the sustainable development of society.

Confidentiality. We comply with the regulations on the protection of personal data in relation to which we have access due to our job. MAC Hotels employees are characterised by a markedly proactive attitude in the treatment of confidential information. Information is the property of the company and must be shared whenever it is beneficial and necessary for the company. In our conduct:

– We provide those in charge with accurate, necessary, complete and timely information about the progress of activities in our area; and to our colleagues, that which is necessary for the proper performance of their duties.

– We obtain information from third parties in an ethical and legitimate manner, rejecting any information obtained inappropriately or in violation of company secrecy or confidentiality.

In the event of any doubts about the appropriate treatment of the information, we request the assessment of our manager about the correct classification of this information. We may not use the programmes, computer systems, manuals, videos, courses, studies, reports, etc., created, developed or perfected at MAC Hotels for our own purposes or those of third parties, nor for profit or gain, given that the company retains the intellectual property of these at all times.

In general, we maintain the strictest confidentiality in the use of internal knowledge outside the company, preserving our know-how. The use of computer equipment is subject to MAC Hotels’ information security policy in order to prevent damage to third parties and/or the company itself.

Responsibility. Each MAC Hotels collaborator and/or employee is responsible for complying with the legal, professional and ethical standards that apply to their job and their level of responsibility. Aware of the importance of the culture of tone at the top, without prejudice to the aforementioned, those who hold a managerial or middle management position have a series of additional responsibilities aimed at leading the team, setting an example of integrity and respect for the rules. They are also responsible for ensuring knowledge and understanding of the Code and the values that govern the company, establishing and developing specific, measurable and achievable goals that promote such ethical behaviour and maximum quality in the provision of customer service.

4- Principles of professional behaviour

Passion for the customer. All employees aspire to offer our customers a product of the highest quality and to provide an excellent level of service. Excellence and quality of service are constant guidelines for action, promoting a healthy concern for continuous improvement. The resources provided by the company seek to promote innovation and the development of customer services, with profitability criteria. All of us, regardless of the functional area in which we work, are committed to customer satisfaction. We promote honest attitudes towards the customer.

Efficient management. At MAC Hotels we work efficiently during the working day, making the most of the time and resources that the company places at our disposal in a rigorous and rational manner. We all give the dedication required by the performance of our duties, aspiring to achieve results in the most optimal and productive way possible.

At MAC Hotels we provide all our employees with all the necessary resources to carry out their work and improve their performance by optimising their time and access to the information they need to fulfil their responsibilities. Therefore, we do not engage in personal activities during working hours that interfere with or prevent you from fulfilling your work responsibilities. We use e-mail, internet access and, in general, the company’s computer systems exclusively for work purposes, and their use for personal use is expressly prohibited, and we expressly authorise MAC Hotels to control the use of these. Unacceptable use of the company’s communications systems includes processing, sending, retrieving, accessing, visualising, storing, printing or in any other way disseminating materials and information that is fraudulent, harassing, threatening, illegal, racial, sexist, obscene, intimidating, defamatory or in any other way incompatible with professional conduct. In terms of occupational health and safety, we will comply with the preventive measures, using the individual and collective means of protection that the company has at its disposal. In the case of having a team in charge, those responsible will ensure that the members of said team carry out their activity in safe conditions.

Team attitude. The employees of the company encourage teamwork and recognise the contribution of others in achieving common results. As members of a team we contribute with equal commitment both inside and outside our area. The teamwork attitude dominates and outshines any performance at the individual level. An outstanding individual is also an outstanding team player, and therefore there is no conflict between this behaviour and individual excellence. Individual interest does not take precedence over team interest. We act in a spirit of cooperation, making available to the other areas and departments of the entity the knowledge and resources that facilitate the achievement of the company’s objectives.

Caring for our reputation. We consider the company’s image and reputation as one of its most valuable assets in order to maintain the trust of our clients. We monitor the respect and correct use of the corporate image and reputation by everyone in the company’s environment. The brand image is visually embodied in our company logo, for which there are rules of use that protect its use and which we must respect. We are especially careful in any public intervention, and must have the necessary authorisation to speak to the media, participate in conferences and in any public media, as long as they appear as MAC Hotels employees. We are all part of the corporate image and therefore we assume an ethical and responsible conduct that allows us to preserve the image and reputation of the company. At no time will we act in a way that could damage the company’s image. The way we communicate, conduct ourselves and our own personal image will be in line with the professional context in which we operate.

Professional development. Our professional growth and that of our teams is our key to being competitive. As employees, we are responsible for our professional growth, and therefore it is our duty to be constantly updated with the knowledge and techniques necessary for the efficient performance of our work. People in charge of teams must pay attention to the motivation and professional development of their collaborators, committing themselves to promote development opportunities based on merit and their professional contribution. To this end, we encourage their continuous learning, recognising their efforts in a specific way and objectively assessing the achievements of all team members, drawing up the necessary action and support plans for their development.

5- Entry into force of the code of conduct, interpretation and monitoring

The Code of Ethical Conduct came into force following its approval by the MAC Hotels governing body on 2 June 2023 and will remain in force until its modification or cancellation is approved, which will be duly communicated. MAC Hotels undertakes to implement and disseminate this Code of Ethics so that it is known to all the company’s stakeholders. It can be consulted on the company’s website. Likewise, periodic awareness-raising and advisory actions are carried out so that any of the aforementioned stakeholders can learn about the values and principles that should govern their daily actions.

Each of us takes it upon ourselves to review and follow this Code, and we comply with all applicable laws, policies and guidelines. This Code attempts to address many of the situations we face on a day-to-day basis, but it cannot address every circumstance. Seek assistance from your line manager and/or your HR Manager.

Procedure for reporting, processing and resolving complaints: MAC Hotels has implemented an internal reporting system through which it is possible to report, in complete confidentiality, behaviour or events that are contrary to ethics, current legislation, this Code of Ethical Conduct or the good corporate governance practices that govern our Company, with special emphasis on those that could have criminal implications. You may access the channel through any of the mechanisms defined in the Internal Reporting System Procedure also published on our corporate website.

We do not discriminate or retaliate against employees for having reported, in good faith, real and proven violations. The Head of the Internal Information System shall ensure compliance with this Code, resolve incidents or doubts about its interpretation and adopt the appropriate measures for its best compliance.

Failure to comply with this code may result in disciplinary action, including the possibility of dismissal and, where appropriate, legal action.