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Whistleblowing policy

Danubius Hotels Zrt. (registered office: 1051 Budapest, Szent István tér 11., Cg.: 01-10-041669) (hereinafter referred to as the "Company" or "Danubius") shall establish an abuse reporting system (hereinafter referred to as the "Whistleblowing System") pursuant to Chapter II of Act XXV of 2023 on Complaints, Public Interest Reports and Rules for Reporting Abuse (hereinafter referred to as the "Complaints Act"). This policy (hereinafter referred to as the Policy) sets out the rules for the operation of the reporting system established and operated by the Company and the procedures to be followed when a report is made.

II. Scope of present whistleblowing policy

1. Material scope

This Whistleblowing Policy covers all reporting by or against employees of the Company of any act committed by or against any person described in section VIII of the Policy;

2. Personal scope

This Policy applies to all persons who are entitled to make a report as set out in section VIII of this Policy.

III. Definitions

„person concerned in whistleblowing”: any natural person in respect of whose alleged or actual conduct the whistleblower has made the report;

„whistleblower”: any natural person who is associated with our Company as set out in point VIII of this Policy and who has made the report;

whistleblowing system”:is the set of whistleblowing channels as set out in point V of this Policy.

IV. Subject of the notification

Any information concerning any unlawful act or negligence or other misconduct which the whistleblower suspects to be unlawful may be reported to the Company'swhistleblowing system.

V. Method of whistleblowing

V.1. Reports may be made to the Company in writing and orally as set out in this clause:

1.1. in writing

1.1.1. at (hereafter as report online)

1.1.2. at and e-mails (hereafter as: report by e-mail)

1.1.3. by letter sent to the following address of the Company seat (hereafter as: report by post):

Danubius Hotels Zrt.

Compliance officer

1051 Budapest, Szent István tér 11.

1.2. orally

1.2.1. by appointment at a personally agreed place or at the registered office of the Company at 1051 Budapest, Szent István tér 11. (hereafter as, report personally)

1.2.2. by using Microsoft Teams, for which you can make an appointment in advance by emailing or (hereafter as report by Teams);

1.2.2. by voice message to an answering machine at 06-1/8894040. (hereafter as, report by voice mail).

VI. Rules of investigating reports

VI.1. The reports are investigated by an independent compliance officer in the Company, under the direction of the Director of Audit, with the involvement of impartial employees who are also experienced in the areas covered by the report.

VI.2. The whistleblower may, if the platform chosen to make the report allows, report anonymously or by indicating his name. The identity of the whistleblower will be kept strictly confidential by our Company and will not be disclosed to any person other than those directly involved in the investigation.

In accordance with the legal provisions in force, our Company will not send an acknowledgement of anonymous reports in the absence of contact details, may refrain from investigating the report and will not inform the whistleblower of the conclusion of the investigation and the measures taken.

VI.3. When making a report, the whistleblower is required to declare that the report is made in good faith concerning circumstances of which he is aware or has reason to believe to be true.

VI. 4. Reports made indicating the name of the whistleblower will be acknowledged by our Company within 7 working days as set out in section VI, and the whistleblower will be informed of the procedural and data processing rules.

VI.5. Our Company shall investigate the report within the shortest time possible under the circumstances, but no later than thirty days from the receipt of the report and shall inform the whistleblower in writing of the investigation or non-investigation of the report and the reasons for the non-investigation, the result of the investigation, and the measures taken or planned.

VI. 6. The Company may extend the investigation period for a maximum of 3 months in particularly justified cases, after informing the whistleblower. The Company will inform the whistleblower of the extension of the investigation period, the expected date of completion of the investigation and the reasons for the extension, in compliance with its legal obligation.

VI. 7. In the course of the investigation, the Compliance officer shall maintain contact with the whistleblower, given that his name has been indicated and may invite the whistleblower to comment on or clarify the report, to explain the facts and to provide further information, or, if deemed necessary, to hear the whistleblower in person.

VI.8. The Company may, either to record the whistleblowing or to complement the whistleblowing, hold a personal interview with the whistleblower after prior consultation with the whistleblower, either at one of its hotels, at its headquarters or at any other external location. In cases of offence against human dignity or gender identity or harassment, the whistleblower may request to have the interview conducted by a man or a woman or, if the whistleblower is or was an employee of our Company, by a named employee in the HR department.

A record of the hearing will be taken, after providing the opportunity for verification, correction and acceptance by signature, a copy of the record will be made available to the whistleblower.

VI. 9. The Company may refrain from investigating the report if

a) the report was made anonymously by the reporting party,

b) the report was not made by an authorised person as detailed in section VIII,

c) the report was made by the same whistleblower with the same content as the previous report; or

(d) the harm done to the public interest or to an overriding private interest would not be proportionate to the restriction of the rights of the natural person concerned by the report or of our Company (hereinafter together referred to as the "person concerned by the report") resulting from the investigation of the report.

VI.10. During the investigation of the report, the compliance officer assesses if the circumstances set out in the report are appropriate and, after consultation with the relevant internal departments, proposes measures to remedy the wrongdoing.

VI.11. If the investigation determines that criminal prosecution is justified on the basis of the allegation, the Compliance officer will arrange for a criminal complaint to be filed, with the involvement of the Legal Director, while informing the CEO of the Company.

VI.12. The Company will only process personal data that are strictly necessary for the investigation of:

- the whistleblower,

- the person whose conduct or wrongdoing gave rise to the report, and

- who has material information relating to the matter complained of,

and will not disclose personal data to unauthorised persons. Details of our data processing in relation to whistleblowing are available in our Privacy Policy at

VI.13. Under the whistleblowing system, the identity of the non-anonymous whistleblower will not be disclosed to anyone other than the investigators of the report. The persons investigating the whistleblowing shall keep confidential information about the content of the whistleblowing and the persons involved in the whistleblowing report until the investigation is closed or formal prosecution is initiated as a result of the investigation and shall not share it with any other department or employee of the Company, except for the purpose of informing the person involved in the whistleblowing.

VI.14. The Company will provide the person concerned with detailed information about the report, his rights regarding the protection of his personal data and the rules on the processing of his data at the start of the investigation. In accordance with the requirement of due process, the Company will ensure that the person concerned may express his views on the report also through his legal representative and provide evidence to support them. Exceptionally, and in justified cases, the person concerned may be informed at a later stage if immediate information would prevent the investigation of the report.

VII. Rules of reporting

VII.1. Online reporting

Any person as described in Section VIII of this Policy may submit a report through the Company's reporting platform at,

either anonymously or by providing his or her name, at his or her option.

In case of a non-anonymous online reporting, the whistleblower may view or complement his previously submitted report after logging in by entering his username and password set in the e-mail message sent upon receipt of the report.

Reports will in all cases be reviewed according to content.

In case of anonymous reporting, the IT system does not store any personal data about the whistleblower, so the person cannot be identified by any means. Please note the username and password on the closing screen after submitting your report in this case, because you will be able to view or complement your report later on by entering the username and password, and our Company will be able to contact you via this platform, failing which we will no longer be able to provide access to your report. In case of reports submitted by entering the name of the whistleblower, our Company will keep in contact with the whistleblower via e-mail messages sent through the system.

VII.2. Reporting by e-mail

We also accept reports via the email addresses or Please note that if, for any reason, you wish to make your report anonymously, you should send your report from an email address from which your identity cannot be confirmed.

In case of reports made by providing the name of the whistleblower, our Company will continue to contact the whistleblower via the email channel.

VII.3. Reporting by post

If you wish to make an anonymous report by post, please do not indicate the sender and do not sign the letter.

In case of reports made with the name of the whistleblower, our Company will contact the whistleblower by post in the absence of electronic or telephone contact.

VII.4. Personal reporting

Our Company will provide the possibility of non-anonymous reporting at a pre-arranged

time and location, either at one of our hotels or at the Company's headquarters, or at any

other pre-arranged location.

VII.5. Reporting by Teams

If the whistleblower wishes to make the report anonymously using the Microsoft Teams application, please send the request to or using an email address that does not identify the whistleblower. An e-mail sent to one of the above addresses must specify, within 7 working days of sending the e-mail, at least 3 specific dates and times that are convenient for the whistleblower to make the report. Within two working days of receipt of the request, the Compliance Officer will send the link for the online consultation.

If you wish to make an anonymous report using Teams, please connect to the online platform without your camera on.

Please note that the conversation recorded using Teams will be recorded in a durable and retrievable form after you have been informed in accordance with the provisions on the protection of personal data, and will be made available to you upon request, please only choose this reporting channel if you consent to the recording of the report.

VII.6. Reporting by voice mail

The Company also accepts reports on an answering machine using the number
06-1/8894040. If you wish to make an anonymous report this way, please disable your caller ID before making the call.

The report made to the answering machine will be recorded in a durable and retrievable form after the whistleblower has been informed in accordance with the provisions on the protection of personal data and the recording will be made available to him upon request, please choose this reporting channel only if you agree to the recording of your report.

Non-anonymous reports made by the means set out in VII.2 to VII.6 shall be recorded

by the Compliance officer in the online reporting system. The rules described for online

reporting shall apply to the reports so recorded.

VIII. Reporting entitlement

The following persons can make a report in the reporting system operated by the Company:

a) employees and former employees

b) persons with whom we are in discussions to enter into an employment relationship,

c) members of the administrative or supervisory body or board of directors of the organisation,

d) trainees and volunteers working for our Company,

e) a person with an ownership interest in the Company,

f) individual entrepreneurs, individual companies, if they have a contractual relationship with the organisation,

g) contractors, subcontractors or persons under the supervision and control of a supplier who has initiated a procedure for establishing a contractual relationship with the organisation, or who is or has been in a contractual relationship with the Company,

h) any person who wishes to enter into a legal relationship or contractual relationship with our company as described in points (e) to (g) above, and the procedure for the establishment of such legal relationship or contractual relationship has been initiated, and any person whose legal relationship or contractual relationship with our Company as described in points (e) to (g) above has ceased.

IX. Protection of whistleblowers

IX.1. The whistleblower and the person (co-worker or family member) who assists the whistleblower in making a lawful report and who assists the whistleblower in making a lawful report shall not suffer any prejudice on account of making a lawful report in good faith.

IX.2. The submission of a report is legitimate if:

a) the whistleblower has submitted his report through one of the systems provided for in this Policy,

b) the whistleblower's reported information on the circumstances covered by the report was

- obtained in connection with the employment, including information obtained in the course of establishing an employment relationship; or

- obtained by a contractor, subcontractor, supplier or delegate or persons under their supervision and control who are negotiating, contracting or have contracted with our Company to enter into a contractual relationship,


c) the whistleblower had reasonable grounds to believe that the information reported concerning the circumstances covered by the report was true at the time of submitting the report.

IX.3. The report is also lawful if the whistleblower makes his report public in compliance with the conditions set out in 2(b) to (c) above, provided that the

a. the whistleblower used the whistleblowing system provided by our Company as set out in this Policy and then the reporting system provided for in Item 7 of Chapter II of the Complaints Act and our Company or the body entitled to proceed has not taken the necessary measures within the time limit;

b. the whistleblower has reason to believe that the concern to which the report relates presents a clear risk of harm to the public interest, in particular, where there is a risk of irreparable harm - or

c) the whistleblower assumed with good reason that in the case of using the whistleblowing system set out in item 7 of Chapter II of the Complaints Act, due to the specific characteristics of the circumstances affected by the report, there is an obvious possibility that

ca) an adverse measure as defined in the Complaints Act will be taken against the whistleblower; or

cb) the contents of the report will not be dealt with in substance.

IX.4. If it has become apparent that the whistleblower has provided materially false information in bad faith and

a) there is evidence that a crime or offence has been committed, the Company will disclose the personal data of the whistleblower to the authority or person entitled to conduct the procedure,

b) if there are reasonable grounds to believe that he has caused unlawful damage or other legal harm to another person, his personal data must be disclosed upon request to the body or person entitled to initiate or conduct the proceedings.

IX.5. If the report is lawfully made, the whistleblower is exempted from liability for breach of confidentiality if he had reasonable grounds to believe that the disclosure of a business secret in the report was necessary to disclose the circumstances covered by the report.

IX.6. Where a report has been lawfully made, the whistleblower shall not be liable for obtaining or having access to the information contained in the report, unless the whistleblower has committed a criminal offence by obtaining or having access to the information.

IX.7. The whistleblower shall not be held liable for lawfully making the report if the whistleblower had reasonable grounds to believe that the report was necessary to disclose the circumstances of the matter to which it relates.

X. Register of reports

X.1. A record is kept of all reports and the measures taken to resolve them.

X.2. The record shows:

a) the description of the report, the event or fact which is the subject of the report,

b) the date of the submission of the report,

c) the description of the action taken to settle or resolve the report, or the reasons for refusal,

d) the deadline for taking the measure and the name of the person responsible for implementation,

e) the date and means of sending the reply to the report.

X.3. Data relating to third parties not involved in the reporting, which are not necessary for the investigation related to the report and which cannot be processed under the Complaints Act, must be deleted from the reporting system without delay.

Present policy enters into effect on 24 July 2023. To issues not covered by this Policy, the Complaints Act and the legislation on the processing of personal data shall apply.

Budapest, 24 July 2023

Whistleblowing privacy

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