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Code d'éthique juridique

Majestic Hotel Group para MIM Hotels

Barcelona, May 3, 2019

Dear friends, clients, and team members,

The administrative body of the different companies that make up the "Majestic Hotel Group"“ would like to firmly and clearly express their sincerest commitment to honest, ethical, and transparent conduct, in full compliance with the current regulations that are applicable to our business at all times.

At the Majestic Hotel Group (hereinafter "the Majestic Group"), since our beginnings in 1918, we have worked with passion, respect, and transparency, always focused on our obligations as well as on continuous innovation in order to offer experiences and services that meet our criteria of excellence, responsibility, and sustainability, creating operational standards, quality targets, and strategies aimed at customer satisfaction. We have done all of this while respecting our firm commitment to ethical and responsible management and while engaging with people and their surroundings through different environmental policies and ongoing projects in the social sphere.

Defining ourselves as a responsible hotel group is not only a big commitment, it is also a stimulating challenge that is achieved through daily effort. To that end, the Majestic Group's management board has approved and implemented various agreements with internal legal ramifications as part of the Ethics and Compliance policy of the entire group. Among these, the backbone is the Code of Conduct, which is compulsory for all members of our group and which defines the objectives, principles, and values that we observe and that we want our stakeholders to observe when it comes to their commercial relationship with our organization.

Through this document, the Majestic Group wishes to deliver a message of ZERO TOLERANCE in regards to any action that is illegal, criminal, or contrary to the tenets set out in the Code of Conduct. We will, therefore, distribute the content of this Code and actively promote adherence to the same by anyone who intends to establish a professional and/or commercial relationship with the Majestic Group. For this reason, following this cover letter, you will find our “Code of Conduct” as well as our “Anti-Corruption Policy” and our “Policy on Gifts, Invitations, and Hospitality”.

We have also created a criminal compliance body, which will be the point of reference within the Majestic Group for any questions, doubts, suggestions, or possible breaches of the Code of Conduct.

To communicate with the criminal compliance body, we have opened a number of communication channels: (i) The complaint channel is accessible at compliance.majestichotelgroup.com, (ii) the query channel is accessible via the email at [email protected], ; or (iii) by postal mail addressed to The Criminal Compliance Body, Ref. The Complaint Channel, Calle Ausiàs March, 48, Bajos, 08010, Barcelona.

Thank you very much for your cooperation,