2016 PRIOR CLIENT · PENAL-ROUTE NOTICE · AC CONTACT · LATER PROFESSIONAL CONVERGENCE

PwC and Carlos Saavedra are invited to answer the documentary conflict question publicly.

The question is now chronological and finite. In 2016 PwC/Carlos were deeply inside the Sun Park legal and strategic response. The client then expressly told PwC that it regarded the conduct as potentially criminal and wanted the penal route. PwC later developed documented professional relationships inside the RICPE / Grupo Acosta Matos ecosystem. What conflict, confidentiality, former-client and information-barrier analysis permitted that later work?

Not an accusation of guilt. This page distinguishes contemporaneous notice, later professional convergence and unresolved conflict questions. It does not state that PwC or Carlos committed a crime, breached professional rules, misused confidential information or accepted an adverse Sun Park mandate unless and until the underlying records prove those propositions.

The 2016 sequence

12 June 2016 · direct notice to Carlos + Miguel

Serious alleged conduct was put directly before PwC.

Patricia wrote directly to Carlos Saavedra and Miguel Hernández after the 11 June meeting. She said that, after considering what Carlos, Jonathan and Cristo had explained, the client believed the Molina/Aizpurúa side, together with the property administrator, lawyer and insolvency administrator, was seeking control through liquidation or an allegedly unlawful arrangement. The email repeatedly asks for formal action, including a possible complaint and criminal route.

Evidence meaning: this is contemporaneous notice to PwC of the client's allegations and perceived seriousness. It is not a judicial finding that those allegations were true.

19–20 July 2016 · legal response + penal instruction

PwC was not merely observing a Community dispute.

PwC was finalising a court challenge to the 26 April Community resolutions. Patricia then reiterated that the client wanted “la vía penal contra esta gente” rather than continuing only through the civil Community challenge. Miguel Hernández/PwC replied, with Carlos copied, “Tomamos nota de vuestra decisión.”

Evidence meaning: PwC was already participating in the legal response and received an express instruction that the client regarded the matter as potentially criminal.

12 September 2016 · AC contact

PwC confirms it had spoken directly with the Administrador Concursal.

Patricia asked Carlos and Miguel for PwC's report and any emails concerning their conversation with the AC about the proposed tour-operator/new exploitation-contract route. Miguel confirmed PwC had spoken with the AC, while stating that it had been a general telephone conversation, without contract detail, and that no report or emails had been produced. Patricia immediately asked for a written account of what PwC had said, what the AC had answered and what had been agreed.

Evidence meaning: direct AC contact is confirmed; the scope and content remain an evidential question.

The later convergence

From 2019/2020 onward, PwC/Carlos appear within the RICPE / Acosta Matos professional ecosystem.

Period	Documented public/repository layer	Question created
2019	PricewaterhouseCoopers Auditores, S.L. appears in RICPE's audit history.	What connected-party/conflict search identified the earlier Sun Park relationship?
2020	RICPE investor material carrying the Sun Park / Acosta Matos project identifies PwC Auditores as RICPE's auditor; public events place PwC Canary Islands leadership in the RICPE ecosystem.	Did any PwC team consider the same-asset or former-client implications?
2021	PwC Network/PwC Spain Legal and General Counsel channels received the Sun Park/RICPE complaint.	What internal conflict/risk review followed once the overlap was expressly notified?
2022+	Public material places Carlos in later PwC/RICPE/MYND and Grupo Acosta Matos-related professional environments, including other hotel/investment contexts.	Were later mandates accepted, and if so on what documented independence/conflict basis?

Precision rule: “later professional convergence” is documented. “Switched allegiance” remains a conclusion that requires proof of the later mandate, client, adverse interest, relevant former-client duties and conflict analysis.

Questions requiring public answers

These are document-answerable questions, not rhetorical accusations.

1 · What did the 12 June 2016 email trigger internally?

What file note, risk escalation, specialist referral, criminal-law assessment or partner review followed the direct email to Carlos and Miguel alleging serious misconduct and asking for stronger action?

2 · What happened to the July penal-route instruction?

Once PwC noted the client's decision to pursue the penal route, who assessed it, what advice was given, what was declined or referred, and where is that decision recorded?

3 · What exactly was said to the Administrador Concursal?

Who at PwC spoke with the AC, when, about which proposed operator/exploitation arrangement, what did PwC communicate, what did the AC answer and what follow-up was agreed?

4 · Which 2016 Sun Park files remained accessible?

Which documents, emails, meeting notes, billing entries, title/deed material, Community information, strategy records and insolvency materials remained within PwC systems?

5 · What conflict search was run before later RICPE/Acosta work?

Which PwC legal entity accepted each later mandate, which connected parties were searched, and did the search identify Aweswell, LPB, Matkator, Sun Park, the Community, the AC or the named 2016 individuals?

6 · What information barriers or recusals existed?

Was Carlos or any member of the 2016 Sun Park team screened from later RICPE/Acosta matters? Were DMS permissions, email workspaces or matter teams restricted?

7 · Was informed consent or waiver obtained?

If PwC considered later work materially connected to the former-client matter, what consent/waiver analysis was performed and from whom was consent sought?

8 · Was any later work specific to Sun Park/MYND Yaiza?

Did PwC or Carlos perform legal, tax, audit, assurance, financing, governance, transaction, RIC, regional-incentive, FEDER or other advisory work specifically connected with the Sun Park/MYND Yaiza project? If not, PwC can answer that directly.

RIGHT OF REPLY · CORRECTION · DOCUMENTARY ANSWER

PwC and Carlos Saavedra are expressly invited to answer.

Por Derecho will publish documentary corrections, mandate clarifications, conflict analyses, information-barrier explanations and innocent accounts with equivalent prominence. Silence will be recorded only as silence and will not be treated as an admission.

The public objective is simple: reconcile what PwC knew in 2016, what the client expressly asked PwC to do, what PwC did with the AC, what later RICPE/Acosta work existed, and what professional safeguards governed the transition.

Return to the full PwC/Carlos record →