The Miramar Group is committed to ensuring the protection of individuals who wish to internally report a violation or possible irregularity, in accordance with the General Regime for the Protection of Whistleblowers (Law No. 93/2021, of December 20) and the General Regime for the Prevention of Corruption and Related Offenses (Decree-Law No. 109-E/2021, of December 8). The Miramar Group prohibits retaliation against any individual who, based on reasonable grounds to believe that there is a violation or suspicion of irregularity, reports it and provides information obtained in a professional context.
This Whistleblower Protection Policy applies to the Miramar Group, consisting of Serafim Silva Actividades Hoteleiras SA, headquartered at Rua Abel da Silva No. 36, 2450-060 Nazaré, and all hotels belonging to the group, namely:
Whistleblowers may report information, obtained in a professional context, relating to suspicions of irregularities or violations – current or potential – of:
A violation or suspicion of irregularity must be based on reasonable grounds. This means that the whistleblower does not need to prove the violation or irregularity, but must be able to substantiate their suspicions based on observations, documents, emails, reports, or photos. A rumor is not a sufficient or reasonable reason to make a report.
Information can be reported by all workers who have performed or are currently performing work with the Miramar Group, including temporary workers, independent contractors, interns, volunteers, or job applicants.
Violations or suspicions of irregularities can be reported by filling out the form on this page.
At the time of the report, the author can remain anonymous or give permission for their identity to be revealed, but must always provide the necessary information to allow the situation to be properly investigated and the consequences of the report to be communicated. Reports that are insufficiently substantiated, lack reasonableness, or factual information will not be investigated.
After the report, a receipt will be issued to the author within a maximum of 7 days.
Miramar Group will manage reports confidentially, and may, if deemed appropriate and necessary, report the violation or suspicion of irregularity to third parties, including regulatory, governmental, or law enforcement agencies.
Within a maximum of 12 weeks after the report, the author will be informed about the process and must maintain confidentiality regarding all information received.
Whistleblowers who believe they are subject to retaliation for reporting a possible violation or suspicion of irregularity should immediately contact Human Resources.
Whistleblowers benefit from the legal protection provided for in Directive 2019/1937, when, first of all, they report internally information about violations. If the whistleblower, after reporting internally, does not receive a response or considers that the matter was not properly investigated, they may choose to report the violation or suspicion of irregularity to the competent public authority.
The Miramar Group, responsible for the treatment, uses the gathered information to conduct investigations, to carry out the necessary communications for the progress of the process, and to comply with legal obligations. The legitimacy basis that allows the Miramar Group to process the data are, the consent of the complainant and compliance with legal obligations.
The Miramar Group transfers, internally and internationally, the collected personal data, within the scope of its organization, in order to better manage any processes considered necessary. The Miramar Group has taken the appropriate safeguards for the international transmission of personal data through a legal procedure called “standard data protection clauses”, which is recommended and adopted by the European Commission and the National Data Protection Authority.
Data subjects can review, update, and decide what type of data they want to have stored, being guaranteed the right to confirmation of the existence of processing, access to the data, and correction of incomplete, inaccurate, or outdated data, the right to anonymization, blocking or deletion of unnecessary, excessive, or processed data in non-compliance with the law, the right to portability of data to another service provider or product, upon express request, in accordance with national authority regulations, observing trade secrets and industrial secrets, the right to delete personal data processed with the consent of the data subject, except in the cases provided for by law, the right to information from public and private entities with which the controller has shared data, the right to information about the possibility of not giving consent and its consequences, and the right to revoke consent.
The Data Protection Officer can be contacted directly through the email dpo@grupomiramar.pt, to whom you can request the exercise of applicable rights at any time.
The personal data of the complainant are kept until the purpose for which they are intended is exhausted, being deleted at most 2 years from the end of the process.
Call to national landline network
Call to national landline network
