Legal
General Data Protection Regulations
To ensure compliance with General Data Protection Regulations, taking effect as from 25th May 2018. To establish the following:
· Who is the Data Controller?
· What data do we receive?
· What data is stored?
· Where data stored?
· Who has access?
· For what purpose is data stored?
· For how long is data stored?
· How is consent to use data obtained?
· How is request for information handled?
· How is data deleted?
· What control measures are in place?
· What is procedure to report potential breach?
The document is deemed correct at the date of production, and will be reviewed when changes in legislation, procedures, and/or suppliers may so require. For the purpose of accuracy, the document will only be considered implemented when clearly marked as such.
The post of Data Protection Officer (DPO, is responsible for the day-to-day management of Data Protection, ensuring compliance to this document. The CEO is ultimately responsible to ensure that the Company is compliant with legislation as appropriate.
The DPO is: Erika Vinsentin-Bonomo, Erika@sphg.co.uk
The CEO is: Antonio Megaro, antonio@sphg.co.uk
GUESTS
1. Name
2. Address
3. Email
4. Telephone number
5. Passport details (if non-UK resident)
6. Credit Card details (tokenized details ONLY)
TEAM MEMBERS
1. Name
2. Address
3. Email
4. Telephone number
5. Passport/ID card details
6. Bank Details
7. Next of Kin Name
8. Next of Kin Telephone number
KX CLUB
1. Name
2. Address
3. Email
GUESTS
1. Name
2. Address
3. Email
4. Telephone number
5. Passport details (non-UK residents only)
TEAM MEMBERS
1. Name
2. Address
3. Email
4. Telephone number
5. Passport/ID card details
6. Bank Details
7. Next of Kin Name
8. Next of Kin Telephone number
KX CLUB
1. Name
2. Address
3. Email
GUESTS
· Property Management System - Guestline
· Revinate Marketing Tool
· Open Table
TEAM MEMBERS
· Sage Payroll
· Corporate Server located In Derbyshire House Server Room
KX CLUB
· Revinate Marketing Tool
GUESTS
· Employees of Guestline and Online Travel Agents*
· Current team members of St Pancras Hotels Group Ltd, restricted to;
- Front Office Team
- Housekeeping Manager/Supervisor
- Events Coordinator/s
- HR Business Partner
- Group Marketing Executive
- Group Revenue Manager
- Group Accounts Manager
- Chief Executive Officer
- Bar & Restaurant Staff (name and email ONLY)
· Employees of Revinate (name and email ONLY)
· Employees of DigiNow (name and email ONLY)
· Employees of Formula (name and email ONLY)
· Employees of Open Table (name and email ONLY) *
NOTE – No other organisations or people have access to Credit Card details than Elavon and Windcave. This includes team members of SPHG.
* Details are provided to SPHG Ltd via the supplier, who is collecting the data and store the data outside of our control.
TEAM MEMBERS
Current team members of St Pancras Hotels Group Ltd, restricted to.
· Group Finance Director
· Director of Operations
· SAGE
KX CLUB
· Revinate
· DPO
· Group Sales Manager
· Group Marketing Executive
· DigiNow
GUESTS
· To ensure reservations of facilities can be made
· Pre-arrival confirmation of reservations
· Compliance with legislation
· Marketing purpose to drive guest loyalty
TEAM MEMBERS
· To ensure compliance with legislation
· To ensure payments can be made to employee
KX CLUB
· Marketing purpose to drive guest loyalty
GUESTS
· Indefinite, until such date guest requests to remove their details, unless in contradiction with legislation.
TEAM MEMBERS
· Throughout employment with SPHG Ltd and associated companies, and until such date so required by legislation.
KX CLUB
· Indefinite, until such date guest requests to remove their details, unless in contradiction with legislation.
GUESTS – HOTEL/RESTAURANT/EVENTS
· Via reservation systems such as Guestline, and/or Online Travel Agents. Details are entered by the guest themselves.
· When arriving at property, without reservation. Details provided by guests and entered by SPHG Ltd team members into approved reservation system ONLY.
TEAM MEMBERS
· Through application process for employment with SPHG Ltd and associated companies.
KX CLUB
· By application to membership via website hosted by SPHG Ltd.
· Through manual application on our premises, using approved forms which include name, email, and company ONLY.
· All requests for information are addressed to the DPO.
· Only requests provided in writing will be considered.
· All requests will be responded to within relevant timeframe, as stipulated by legislation in force at the time of request.
· In the unlikely event that a DPO is not available to respond within the timeframe as stipulated by current legislation, the Chief Executive Officer will appoint a suitable interim DPO, whom will act within directive as stipulated in this document.
· Request for data will only be accepted by the person whom the data will relate to, unless specifically instructed by a responsible authority, supported by legally binding instructions in writing.
Data is deleted by the DPO, who will have full access to all Data Bases stored at premises controlled by St Pancras Hotels Group Ltd. All requests for data deletion will happen within a reasonable timeframe, and it is endeavoured that this time frame will not exceed 30 days from request. However, should the request to have data deleted contradict legislation of England and Wales, or instructions by responsible authorities, data will remain on files until instructed by aforementioned.
All data access is controlled by the following tangible measures.
· Data access is restricted to positions, as defined in this document.
· On-site servers are kept in access-controlled areas.
· Remote access to servers is restricted to appointed IT consultants only.
· All on-site storage of data is kept on the servers, and not on individual workstations.
· Ability to copy data base files is restricted to DPO only.
· User Passwords are programmed to change every 90 days.
· All third-party business partners who keep data of guests and/or associates, are requested to provide GDPR Policies and confirmation of GDPR Compliance prior to engagement. This data is reviewed annually, or when legislative changes so require.
If a suspected breach takes place, all individuals who have been identified to may have been affected by a breach, will be contacted within 24 hours of SPHG Ltd, DPO and/or Third-Party Business Partner has been made aware that a potential breach has/may have taken place.
This communication will be done via email as far as reasonably possible. SPHG Ltd reserves the right to issue a formal statement using other channels, should the Company deem that being a better or swifter option.
Details listed below are correct as when this document was created. Any changes will be recorded on this document but will not stipulate the requirement of a revision to be issued.
o NETTEAM IT CONSULTANTS
o REVINATE
o GUESTLINE
o HRS
o BOOKING.COM
o OPEN TABLE
o EXPEDIA
o LASTMINUTE.COM
o LATEROOMS.COM
o MAILCHIMP
o SAGE
o DIGINOW
o HOTEL BEDS
o JAC TRAVEL
o CTRIP
o FORMULA
This document took effect 22nd May 2018 and will be reviewed when legislation so require. Responsible person to undertake reviews is the DPO, or suitably appointed person and/or organisation. The ownership of this document is restricted to St Pancras Hotels Group Ltd, and any associated organisation owned or operated by St Pancras Hotels Group Ltd.
Version 1 5th May 2018.
Christian Kaberg, Group Operations Director
For and on behalf of SPHG Ltd
Version 2 13TH July 2019.
Christian Kaberg, Group Operations Director
For and on behalf of SPHG Ltd
Version 3 28th Dec 2021
Christian Kaberg, Managing Director
For and on behalf of SPHG Ltd
Version 4 2nd Aug 2022
Christian Kaberg, Managing Director
For and on behalf of SPHG Ltd
Version 5 24th July 2025
Erika Visentin Bonomo, Director of Operations
For and on behalf of SPHG Ltd
Version 6 13th March 2026
Erika Visentin Bonomo, Director of Operations
For and on behalf of SPHG Ltd
Environmental Policy
St Pancras Hotels Group Ltd and all its operating subsidies (hereafter referred to as The Company) are actively seeking ways to reduce any negative impact we have on our planet. The Company will not only comply with all European law applicable to environmental legislation, regulations, approved codes of practice and other external requirements applicable to our business but more importantly actively improve and exceed on this legislation and recommendations. Looking after our legacy is one of our core values as individuals, and as a company.
Additionally, but not restricted to, the Company ensures that our environmental ethos is widely communicated and reinforced throughout any business we operate and/or are associated with. As such, the actions we will take to make this policy work include:
· disposing of any waste produced in an environmentally responsible manner wherever reasonably practicable
· ensuring wherever possible that all products purchased that are derived from natural resources are from sustainable sources
· setting and reviewing annual objectives and establishing, implementing, and maintaining programmes to achieve these objectives
· ensuring that all decisions regarding working practices and purchasing take relevant environmental considerations into account
· where possible reducing the use of company vehicles during working hours and regularly monitoring the condition of such vehicles with a view to reducing harmful emissions
· training and encouraging all staff to work in an environmentally responsible manner and ensuring our communications raise awareness and keep all staff and interested parties informed
· endeavouring where possible to ensure that clients, suppliers, and contractors with whom we have dealings are likewise environmentally minded in their approach to business
· conducting audits of procedures and practices and responding to deficiencies through a planned programme of remedial action
The Chief Executive Officer is ultimately responsible for overseeing environmental issues and ensuring we remain compliant with changing legislation. All managers are responsible for ensuring this policy's successful implementation within their own departments. All employees have a responsibility to adhere to this policy.
The points outlined below are the minimum environmental standards which we require and will endeavour to achieve. As this policy develops, we expect our standards to continually improve.
We will investigate and utilise, wherever possible, environmentally sound waste disposal methods for all waste materials. Any product discharged by us into the drainage system or into the air will comply with any legislative requirements.
All bottles, jars, tins, unusable scrap paper, reports, newspapers, magazines, CD ROMs, batteries, toners etc. will be recycled. Employees are therefore requested to dispose of such materials in the receptacles provided. Old company uniforms, protective clothing, mobile phones and other equipment, fluorescent tubes, exhausted batteries, printer cartridges etc. will be sent to the appropriate recycling centre. When replacing items of equipment or furniture we will aim to recycle or resell the obsolete models.
Plastic packaging materials that cannot be re-used will be returned and we will place the supplier at risk of losing their business with the Company.
We utilise electronic means of working and to cut down on waste we discourage the keeping of hard copies. Recycled paper will be used whenever suitable. All reports, papers and company documents should be printed on double-sided paper to decrease paper usage. All staff are requested not to discard paper which can be reused as scrap, but to put this in the receptacles provided. Separate bins are provided for coloured and white paper. Internal mail should be sent using reusable envelopes and files.
We will always aim to buy products containing/produced with recycled materials where these are suitable for the job, including refillable pens, re-manufactured printer and toner cartridges, folders, toilet rolls, kitchen towels and long-life products. Wherever possible, biodegradable and phosphate-free detergents will be used in sinks, toilets etc.
Within the parameters of health and safety, we will minimise the use of energy. Long-life low-energy light bulbs and other energy saving devices will be used in all areas. All employees are requested to turn off the lights and/or any fans when leaving their offices unattended, and to turn off the lights and fans in the toilets and other rooms when not in use. Electrical equipment including computers, photocopiers and printers should not be left turned on and running when not in use, unless there is reason (i.e., terminals left on following request by the IT department to undertake essential maintenance outside of normal working hours).
We will establish environmentally sensitive purchasing policies and monitor the environmental awareness of our suppliers, ideally setting a standard with which they must comply.
This policy will be made readily available to all employees, suppliers and customers and we will ensure awareness of environmental issues throughout all areas of the business through staff training and development. In addition, signs reminding staff to recycle waste materials and to economise on electricity will be posted in appropriate places around our premises.
This policy took effect on 1st September 2016. The Chief Executive Officer has overall responsibility for implementing and monitoring this policy, which will be reviewed on a regular basis following its implementation whenever there are relevant changes in legislation or to our working practices.
Any queries or comments about this policy should be addressed to the Chief Executive Officer, Antonio Megaro via email at antonio@sphg.co.uk.
15/3/2021 by Christian Kaberg, MD
Change of Titles, Removal of RDM as responsible.
22/03/2025 by Erika Visentin Bonomo
Director of Operations
13/03/2026 by Erika Visentin Bonom
Director of Operations
Anti-Bribery & Corruption Policy
This Policy exists to set out the responsibilities of St Pancras Hotels Group Ltd, and its operating subsides (hereafter referred to as the Company), and those who work for us regarding observing and upholding our zero-tolerance position on bribery and corruption. It also exists as a source of information and guidance for those working for the Company. It helps them recognise and deal with bribery and corruption issues, as well as understand their responsibilities.
The Chief Executive Officer is ultimately responsible for implementing, enforcing, and reviewing this policy. This policy is subject to regular reviews as and when legislation or changes in working practices requires amendments.
The Company is committed to conducting business in an ethical and honest manner and is committed to implementing and enforcing systems that ensure bribery is prevented. The Company has zero-tolerance for bribery and corrupt activities. We are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever we operate.
The Company will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which we operate. We are bound by the laws of the UK, including the Bribery Act 2010, regarding our conduct both at home and abroad.
The Company recognizes that bribery and corruption are punishable by up to ten years of imprisonment and a fine. If our company is discovered to have taken part in corrupt activities, we may be subjected to an unlimited fine and face serious damage to our reputation. It is with this in mind that we commit to preventing bribery and corruption in our business and take our legal responsibilities seriously.
This anti-bribery and corruption policy applies to all employees, (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside of the UK). The policy also applies to Officers, Trustees, Board, and/or Committee members at any level.
In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties.
Any arrangements our company makes with a third party is subject to clear contractual terms, including specific provisions that require the third party to comply with minimum the standards as set out in this policy.
Bribery refers to the act of offering, giving, promising, asking, agreeing, receiving, accepting, or soliciting something of value or of an advantage so to induce or influence an action or decision.
A bribe refers to any inducement, reward, or object/item of value offered to another individual to gain commercial, contractual, regulatory, or personal advantage.
Bribery is not limited to the act of offering a bribe. If an individual is on the receiving end of a bribe and they accept it, they are also breaking the law.
Bribery is illegal. Employees must not engage in any form of bribery, whether it be directly, passively (as described above), or through a third party (such as an agent or distributor). They must not bribe a foreign public official anywhere in the world. They must not accept bribes in any degree and if they are uncertain about whether something is a bribe or a gift or act of hospitality, they must seek further advice from the company’s compliance manager.
This section of the policy refers to 4 areas:
· Gifts and hospitality.
· Facilitation payments.
· Political contributions.
· Charitable contributions.
Gifts and hospitality
The Company accepts normal and appropriate gestures of hospitality and goodwill (whether given to/received from third parties) so long as the giving or receiving of gifts meets the following requirements:
· It is not made with the intention of influencing the party to whom it is being given, to obtain or reward the retention of a business or a business advantage, or as an explicit or implicit exchange for favors or benefits.
· It is not made with the suggestion that a return favor is expected.
· It is in compliance with local law.
· It is given in the name of the company, not in an individual’s name.
· It does not include cash or a cash equivalent (e.g., a voucher or gift certificate).
· It is appropriate for the circumstances (e.g., giving small gifts around Christmas or as a small thank you to a company for helping with a large project upon completion).
· It is of an appropriate type and value and given at an appropriate time, considering the reason for the gift.
· It is given/received openly, not secretly.
· It is not selectively given to a key, influential person, clearly with the intention of directly influencing them.
· It is not above a certain excessive value, as pre-determined by the company’s Chief Executive Officer or appointed person (usually more than £100).
· It is not offer to, or accepted from, a government official or representative or politician or political party, without the prior approval of the company’s Chief Executive Officer or formally appointed person.
Where it is inappropriate to decline the offer of a gift (i.e., when meeting with an individual of a certain religion/culture who may take offence), the gift may be accepted so long as it is declared to the compliance manager, who will assess the circumstances.
The Company recognises that the practice of giving and receiving business gifts varies between countries, regions, cultures, and religions, so definitions of what is acceptable and not acceptable will inevitably differ for each.
As good practice, gifts given and received should always be disclosed to the compliance manager. Gifts from suppliers should always be disclosed.
The intention behind a gift being given/received should always be considered. If there is any uncertainty, the advice of the Chief Executive Officer or formally appointed person should be sought.
The Company does not accept and will not make any form of facilitation payments of any nature. We recognise that facilitation payments are a form of bribery that involves expediting or facilitating the performance of a public official for a routine governmental action. We recognise that they tend to be made by low level officials with the intention of securing or speeding up the performance of a certain duty or action.
The Company does not allow kickbacks to be made or accepted. We recognise that kickbacks are typically made in exchange for a business favour or advantage.
The Company recognises that, despite our strict policy on facilitation payments and kickbacks, employees may face a situation where avoiding a facilitation payment or kickback may put their/their family’s personal security at risk. Under these circumstances, the following steps must be taken:
· Keep any amount to the minimum.
· Ask for a receipt detailing the amount and reason for the payment.
· Create a record concerning the payment.
· Report this incident to your line manager.
The Company will not make donations, whether in cash, kind, or by any other means, to support any political parties or candidates. We recognise this may be perceived as an attempt to gain an improper business advantage.
The Company accepts (and indeed encourages) the act of donating to charities whether through services, knowledge, time, or direct financial contributions (cash or otherwise) – and agrees to disclose all charitable contributions it makes.
Employees must be careful to ensure that charitable contributions are not used to facilitate and conceal acts of bribery.
We will ensure that all charitable donations made are legal and ethical under local laws and practices, and that donations are not offered/made without the approval of the compliance manager.
As an employee of the Company, you must ensure that you read, understand, and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information you are given.
All employees and those under our control are equally responsible for the prevention, detection, and reporting of bribery and other forms of corruption. They are required to avoid any activities that could lead to, or imply, a breach of this anti-bribery policy.
If you have reason to believe or suspect that an instance of bribery or corruption has occurred or will occur in the future that breaches this policy, you must notify the Chief Executive Officer or formally appointed person.
If any employee breaches this policy, they will face disciplinary action and could face dismissal for gross misconduct. Further information is readily available in the Company Employee Guidebook.
This section of the policy covers 3 areas:
· How to raise concern.
· What to do if you are a victim of bribery or corruption.
· Protection.
If you suspect that there is an instance of bribery or corrupt activities occurring in relation to the Company, you are encouraged to raise your concerns at as early a stage as possible. If you’re uncertain about whether a certain action or behaviour can be considered bribery or corruption, you should speak to your line manager, or the Chief Executive Officer. The Company will familiarise all its employees with its whistleblowing procedures so employees can vocalise their concerns swiftly and confidentially.
You must tell your line manager as soon as possible if you are offered a bribe by anyone, if you are asked to make one, if you suspect that you may be bribed or asked to make a bribe in the near future, or if you have reason to believe that you are a victim of another corrupt activity.
If you refuse to accept or offer a bribe or report a concern relating to potential act(s) of bribery or corruption, the Company understands that you may feel worried about potential repercussions. The Company will support anyone who raises concerns in good faith under this policy, even if investigation finds that they were mistaken.
The Company will ensure that no one suffers any detrimental treatment a result of refusing to accept or offer a bribe or other corrupt activities or because they reported a concern relating to potential act(s) of bribery or corruption.
Detrimental treatment refers to dismissal, disciplinary action, treats, or unfavourable treatment in relation to the concern the individual raised.
If you have reason to believe you’ve been subjected to unjust treatment because of a concern or refusal to accept a bribe, you should inform your line manager or the Chief Executive Officer immediately.
The Company will provide training on this policy as part of the induction process for all new employees. Employees will also receive regular, relevant training on how to adhere to this policy, and will be asked annually to formally accept that they will comply with this policy.
The Company’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners, and any third parties at the outset of business relations, and as appropriate thereafter.
The Company will provide relevant anti-bribery and corruption training to employees etc. where we feel their knowledge of how to comply with the Bribery Act needs to be enhanced. As good practice, all businesses should provide their employees with anti- bribery training where there is a potential risk of facing bribery or corruption during work activities.
The Company will keep detailed and accurate financial records and will have appropriate internal controls in place to act as evidence for all payments made. We will declare and keep a written record of the amount and reason for hospitality or gifts accepted and given and understand that gifts and acts of hospitality are subject to managerial review.
The Company’s Chief Executive Officer is responsible for monitoring the effectiveness of this policy and will review the implementation of it on a regular basis. They will assess its suitability, adequacy, and effectiveness.
Internal control systems and procedures designed to prevent bribery and corruption are subject to regular audits to ensure that they are effective in practice.
Any need for improvements will be applied as soon as possible. Employees are encouraged to offer their feedback on this policy if they have any suggestions for how it may be improved. Feedback of this nature should be addressed to the Chief Executive Officer and/or formally appointed person.
This policy does not form part of an employee’s contract of employment, and the Company may amend it at any time so to improve its effectiveness at combatting bribery and corruption.
This Policy is effective as from the 3rd of August 2022.
15/3/2021 by Christian Kaberg, MD
Change of Titles, Removal of RDM as responsible.
22/07/2025 by Erika Visentin Bonomo
Director of Operations
13/03/2026 by Erika Visentin Bonom
Director of Operations
Anti-Slavery Policy
St Pancras Hotels Group Ltd and all its operating subsidies (here within referred to as The Company) is committed to eliminating modern slavery, human trafficking, forced labour, and similar human rights abuses.
The Company is committed to ensuring that its staff and any workers it supplies (directly or indirectly) are not subject to behaviour or threats that may amount to modern slavery, human trafficking, forced labour, and similar human rights abuses.
The Company provides appropriate training and awareness information for all its staff. In particular:
· All of our staff receive awareness-raising information around issues involving modern slavery and human trafficking, so that they can bring any concerns they have to the attention of management.
Any staff, workers or other parties are strongly encouraged to report any concerns or suspicions that they might have to company CEO, Antonio Megaro.
Reports surrounding these issues are taken extremely seriously by the company CEO who is committed to ensuring that all investigations shall be prompt and effective. If our investigations reveal any issues, we are committed to taking appropriate action, including but not limited to:
· Working with the appropriate organisations to improve standards,
· Removing that organisation from our preferred supplier list,
· Passing details to appropriate law enforcement bodies.
We regularly monitor our risks in this area through the use of relevant key performance indicators, including:
· The effectiveness of enforcement against suppliers who breach policies,
· The amount of time spent on audits, re-audits, spot checks, and related due diligence, and
· The level of modern slavery training and awareness amongst our staff.
As part of our efforts in this area, we will monitor and review our statement on a regular basis.
This statement is made as part of The Company’s commitment to eliminating the exploitation of people under the Modern Slavery Act 2015 (the Act). It summarises how The Company operates, the policies and processes in place to minimise the possibility of any problems, any risks we have identified and how we monitor them, and how we train our staff.
This statement is published in accordance with section 54 of the Act and will be reviewed by The Company whenever legally so obliged, or as a direct finding of common practices.
Corporate Social Responsibility Policy
This Policy forms an integral part of our business strategy.
This Policy forms an integral part of our business strategy. The fact that our activities, and those of our employees, may influence the environment is of great consequence to us. St Pancras Hotels Group Ltd and all its operating subsidies (hereafter referred to as the Company) endeavour to operate in a socially responsible manner, with particular emphasis on the following areas:
· Human Rights: To ensure that all our employees are treated fairly without breaching their human rights
· Labour Standards: To ensure that we have a safe working environment and encourage the furthering of our employees’ careers through education
· Anti-Corruption: To ensure that no illicit activities occur within our company
· Sourcing Materials: To utilise raw materials and processes which make minimum demands on the environment, and which produce minimum waste
· Production: To carry out our service using environmentally friendly materials and equipment, which are energy efficient and produce minimal harmful waste upon disposal
· Waste & Recycling; To minimise waste produced through the business activities and look for innovative ways to recycle waste material
· Energy; To reduce the demand on energy resources from our activities
· Transport & Distribution; To utilise, where applicable, efficient distribution and transport systems for goods and personnel
· Consumers: To provide all the information necessary to enable products to be properly used, stored and disposed of to avoid damage to the environment
· Employment & Training; To ensure that all employees can improve environmental performance by providing appropriate information, training, and consultation procedures. To ensure that our Environmental Policy promotes action rather than words, it is the responsibility of the Executive Team to ensure that all employees understand and carry out this policy to the best of their ability
· Community Work To ensure that we continue to pay attention to, and work with the local community in which it operates
This policy took effect on 1st September 2018. The Chief Executive Officer has overall responsibility for implementing and monitoring this policy, which will be reviewed on a regular basis following its implementation whenever there are relevant changes in legislation or to our working practices.
Any queries or comments about this policy should be addressed to the Chief Executive Officer, Antonio Megaro at Antonio@sphg.co.uk
15/3/2021 by Christian Kaberg, MD
Change of Titles, Removal of RDM as responsible.
22/07/2025 by Erika Visentin Bonomo
Director of Operations
13/03/2026 by Erika Visentin Bonomo
Director of Operations
COMPLAINTS MANAGEMENT POLICY AND PROCEDURE
Complaints Procedure/Lodging a Complaint
St Pancras Hotels Group Ltd and all its subsidiaries aim (hereafter referred to as the Company) to continuously improve the services provided to its guests, suppliers, and team members. Effective complaints management is fundamental to the provision of quality services and provides a platform for obtaining feedback from its clients with the purpose of resolving disputes and reforming policies and procedures.
For this purpose, the Company has developed and established a Complaints Management Policy, which is designed to provide guidance on the way in which the Company receives and manages complaints. The application of this policy will ensure that complaints received are dealt with fairly, promptly and in an efficient and confidential manner.
The Company through this policy is committed to effectively managing complaints promptly and fairly, ensuring that:
· Your complaints will be investigated in depth, will be handled in an efficient and effective manner and you will be treated courteously.
· We will be fair both to you and any employee for whom a complaint may refer to.
· We will not charge you for making a complaint.
· Our Complaints Management Policy will always be available on our website www.themegarocollection.co.uk.
· We will always observe privacy and confidentiality of any personal data, in line with the European Union directives and the “Processing of Personal data (Protection of Individuals) Law of 2001”.
· We will record and analyze complaints on a regular basis for the identification and rectification of erroneous procedures and practices as well as for the avoidance of recurring omissions.
· Any individual involved in the complaint or responsible for the management of the complaint will not participate in the investigation process should there be conflict of interest.
· Our employees will undergo continuous training on the Complaint Management Policy and will have direct access to related documentation to facilitate the effective handling of complaints.
· Our Owners, Executive Team, Management and Employees acknowledge your right to file a complaint and are committed to the efficient and fair resolution of complaints or problems that may arise from the services we provide.
The complaint management system included in this Policy and internal procedures will be reviewed periodically by the Managing Director or appointed suitable Executive Team Member, aiming to enhance the transparency, efficiency and the greatest possible satisfaction of the guests.
Any complaint can be submitted by a guest of the hotel, a supplier to the Company, or a team member.
Should you worry about any aspect of the services we offer, your first point of contact should be the hotel’s reception. Our aim is to promptly resolve any possible issue you might have, prior to your departure, to ensure a perfect experience of our hotels.
If you find it necessary to pursue the matter further, you should submit a formal complaint letter (by electronic mail) addressed to erika@sphg.co.uk to investigate the matter independently.
We strongly recommend that you make any formal complaint in writing to protect your interests. This will support our objective of ensuring any complaints received are dealt with fairly, promptly, efficiently and in confidence.
We expect from you:
· To indicate information about your reservation (or booking agent) as well as your full contact details
· To describe your complaint clearly and accurately
· To be specific with respect to the reasons for which you are filing a complaint
· To mention your expectations clearly, regarding the resolution of the issue
If your complaint cannot be resolved immediately, its investigation will go through the following timeframes:
· Acknowledgement of your complaint within two (2) working days of receipt.
· Your complaint will be addressed within 15 working days. A relevant response will be sent immediately.
· On rare occasions where more time is required for the proper and detailed investigation of your complaint, an extension period will be requested in writing. In our letter, besides any additional information that we may request, we will inform you of our actions taken so far and any further actions required for the completion of the investigation.
· Our aim is to ensure that you receive our final response within ten (10) working days from the time of the extension notification or the receipt of any extra information requested from you.
Should you wish to request an update at any stage of the complaint investigation, you can do so by contacting the Company via erika@sphg.co.uk.
Pet Policy
We are delighted to welcome well-behaved canine companions to stay with us.
At The Megaro Collection, we understand that dogs are part of the family and we are delighted to welcome well-behaved canine companions to stay with us. To ensure a comfortable and enjoyable experience for all of our guests, both two-legged and four-legged, we kindly ask that owners review and adhere to the guidelines below when travelling with their dog. These policies help us maintain the highest standards of comfort, cleanliness, and safety throughout the hotel.
While The Megaro Collection is a dog-friendly hotel, this should not be interpreted as a general pet-friendly policy. If you are travelling with a pet that is not a dog, we kindly ask that you contact our reception team prior to arrival so we can review the request and confirm whether we are able to accommodate your companion.
• Owners/guests must advise the hotel before arrival if they wish to bring a dog (using the “comment” section when booking the room/calling the hotel).
• Dogs are permitted in specific room categories, which may vary depending on the property you are staying at.
• The breed and weight of the dog to be advised in advance – please email the hotel reception.
• Maximum permitted weight is 12kg (except for assistance dogs).
• Guests are only permitted to have one dog in any room at any given time.
• Dogs receive a sumptuous bed, water and food bowls.
• Dogs must be kept on a leash when in public areas.
• An anti-allergy deep cleaning fee of £50 per stay is included in the defined Dog package or will be added to the guest bill when booked via any other source.
• Any stains or damages must be paid for according to the cost of replacement or repair.
• Owners/guests are asked to control any noise made by their dog to ensure they do not disturb other guests. Dogs should not be left alone in the room in case of disturbance or damage occurs.
• Dogs are not allowed in Hokus Pokus and in Voyage, apart from assistance dogs. Spagnoletti allows dogs.
• Dogs should be well trained, and owners must pick up any “excrements” left by their dogs.
• A refundable deposit may be required upon check-in for stays with dogs.
Health & Safety General Statement
Our duty to take all reasonable care regarding the safety of our guests, team members, contractors, and visitors
Under health and safety legislation it is our duty to take all reasonable care regarding the safety of our guests, team members, contractors, and visitors. We will always:
· Take reasonable care for the health and safety of ourselves and any of the persons who may be affected by our acts or omissions at work.
· Co-operate with St Pancras Hotels Group Ltd and all its operating subsidies (hereafter referred to as ‘The Company’) so far as necessary to enable the Company to conform to or comply with any duty or requirements imposed on the Company under such legislation.
· Comply with any rules or regulations made by the Company for the health, safety, and welfare of every team member.
It is the policy of the Company to comply with all relevant legislation and Codes of Practice regarding Health & Safety and Food Hygiene throughout its operation. To achieve the objectives of compliance the Company and its team members will abide by the following statement:
· The Company will provide a clear definition of responsibilities for its team members.
· Individual team members are responsible for complying with the relative sections of the Company Policy on Health & Safety at Work, Food Hygiene and supporting Codes of Practice.
· The company will provide and up-date as necessary an Operations Manual covering all relevant areas of Health and Safety and Food Hygiene.
· The company will train team members to a level commensurate with their responsibilities.
· Where training is provided team members are to work in the manner taught and not to deviate from the stated standards.
· At all times when at work team members are expected to have high regard for the health and safety of themselves and others and are responsible for taking common sense measures for avoidance of hazards in their working practices whether stipulated or not. Where protective clothing or items of protective equipment are provided, they must use these on all occasions when exposed to the risk involved.
· The Company will undertake routine internal and/or external audits of hotel operating procedures to ensure that the arrangements detailed in this Operations Manual are implemented in a consistent manner.
· Team members are required to report immediately to the designated person any defects in materials, equipment or working practices which appear to warrant attention.
· The company will carry out annual inspections of high-risk areas, where so indicated through appropriate risk assessments.
· The Company will maintain appropriate training records.
Date: 13th of March 2026
Erika Visentin Bonomo
Director of Operations
Health & Safety
Responsibilities under the Health and Safety at Work Act 1974
The Company acknowledges its responsibilities under the Health and Safety at Work Act 1974 and as far as reasonably practicable takes every possible step to ensure the health and safety of all team members, contractors, and visitors to its premises.
With the corporation of all concerned the Company seeks the highest standards of health and safety at work. So, while overall policy and responsibility rests at the highest management level, everyone throughout the Company must accept a degree of responsibility for carrying out the policy.
Team Members are expected to follow Company procedures in the matter of Health and Safety to report any incidents which have or may have led to injury or damage.
Team Members must ensure that they use any equipment provided in accordance with the training provided, inform Management about any danger, and report any shortcomings seen in a protective environment. If Management is not available work must stop immediately to avoid being exposed to serious imminent and unavoidable danger. If there is a conflict between the demands of safety and task, Management must be informed.
Team Members are expected to ensure that good housekeeping standards are applied.
Team Members must act in a manner to avoid hazards and contribute positively to a safe working environment.
Wilful breaches of the health and safety policy and procedures will be dealt with through the Company's disciplinary procedures.
Team members meeting external contractor on Company premises are required to explain the health and safety rules politely but firmly and to ensure that such visitors comply with these procedures.
The health and safety policy are actively communicated and promoted within the Company.
Chief Executive Officer
Operations Director
Group Accounts Manager
Maintenance Manager
Group Head Housekeeper
Executive Chef
Restaurant General Manager
Hotel Manager- Megaro, Gyle, California
Revenue Director
Marketing Manager
HR Executive