Europamundo Compliance Programme

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Europamundo Compliance Programme

Europamundo conducts its activities and operations in compliance with applicable laws and regulations, and implements internal guidelines, policies and procedures to ensure that these laws and regulations are complied with.

Europamundo identifies, manages and informs its Board of Directors and Management of any risk of criminal non-compliance that must be prevented.

Inappropriate behavior by a single individual in managerial position, employee or personnel performing functions for the Company can potentially damage our image and reputation in a very short space of time. We must therefore actively prevent and avoid this possibility. The purpose of this Policy is to send a strong message of opposition to the commission of any unlawful, criminal or otherwise reprehensible act to Europamundo Personnel, as well as to other interested parties who have dealings with the Company.

The purpose of this Policy is to send a strong message of opposition to the commission of any unlawful, criminal or otherwise reprehensible act to Europamundo Personnel, as well as to other interested parties who have dealings with the Company. Under no circumstances shall the commission of a criminal offence by Staff be justified, even if such action would appear to be of any benefit to Europamundo. Europamundo is also prepared to combat such acts and to prevent any damage to its image and reputation.

This Compliance Policy constitutes the reference framework of the Compliance Model in place at Europamundo, which is known by all Staff and promoted by its Board of Directors.

The main reasons for implementing an effective and efficient Compliance Management System or Programme are:

Strong business ethics culture: guidance on appropriate and correct behaviour for management and staff.
Liability and fines: to avoid criminal/civil liabilities and the imposition of penalties and fines on Europamundo.
Legal claims: to avoid third party claims against Europamundo.
Reputational risk: to prevent Europamundo's reputation from being damaged, guaranteeing its value.
Customers: to maintain and secure business with major customers, who require that their suppliers' activities comply with all applicable laws and regulations.
Supply chain management: to ensure supply chain risk reduction by ensuring responsible and ethical business practices are applied in global supply chains.

A Compliance Management System therefore contributes to guaranteeing and enhancing the value of Europamundo and protecting the management against potential personal liabilities.

The Compliance Management System is developed through:

Head of the Compliance Function (Chief Compliance Officer or CCO) The CCO is the single-person body in charge of supervising the operation and compliance of the Criminal Compliance Management System or Compliance Program.

The Chief Compliance Officer or CCO shall be the person appointed by the Board of Directors. The candidate must have the necessary technical, professional and personal qualifications.

The Compliance Committee is the collegiate body of an executive nature and oriented to decision making, which has the task of advising the Compliance Officer in all aspects it deems relevant in the development of its functions and shall also be appointed by the Board of Directors.

WHAT ARE THE INTERNAL REGULATIONS ON COMPLIANCE?

Europamundo has a Code of Ethics and a Manual of Good Practices that includes the behavior guidelines expected from all members of Europamundo and its stakeholders. In this sense, all workers, managers and people linked to Europamundo are expected to comply with the aforementioned Code, as well as with the rest of the regulations that develop the compliance management model.

Europamundo has a Criminal Compliance Management System for the purpose of organizing a means of prevention, detection and early management of criminal compliance and anti-bribery risks, as well as reducing their undesired effects in the event that they materialize, creating a culture of social and ethical responsibility, and respect for local, autonomous community, national and international laws among all Europamundo interest groups in everything that may be applied to them.

COMPLIANCE POLICIES AND PROCEDURES

Criminal Compliance Policy (link)
Code of Ethics (link)
Prevention of money laundering.
Gift Policy (link)
Disciplinary regime
Whistleblowing Channel Regulations (link).

In addition, Europamundo has a series of internal protocols or procedures that complement the Compliance Management System, such as the Compliance Management Manual, a special part with all the possible crimes that may affect the company, personnel selection protocol and remuneration policies, Data Protection Protocol, Corporate Image and Reputation Protocol, Supplier Selection and Approval and IT Security Policies.

WHISTLEBLOWING CHANNEL

Europamundo has a leading position as the main ground travel operator in the world, a reputation and prestige for its more than 25 years of history that are the result of the work and effort of all its staff. Therefore, it is necessary to manage the possible inappropriate behavior of a single employee or related person of the company, which may damage the image and reputation of the company.

Europamundo's whistleblower channel is the internal communication channel through which the company receives and manages reports made by the company's own personnel, or by other persons linked to the company, on possible irregular or illicit conduct that they may have witnessed or have knowledge of, and which are contrary to the company's rules, both internal and external.

The whistleblowing channel in Spain is regulated by Law 2/2023, of February 20, Regulating the Protection of Persons Reporting Regulatory Infringements and Combating Corruption, which transposes Directive (EU) 2019/1937 (Whistleblowers Directive), approved in 2019 by the European Commission and the European Parliament, and whose objective is to regulate the protection of persons reporting infringements of Union Law.

Both Directive (EU) 2019/1937 and Law 2/2023, of February 20, provide for the implementation of a mandatory whistleblowing channel for companies with more than 50 employees, the possibility to process anonymous reports and, especially, to protect the identity of the informants (whistleblowers), maintaining their anonymity and guaranteeing their protection against possible retaliation by the organization.

In case of any irregularity, you can contact or send the complaint form through the following means:

E-mail: canaldedenuncias@europamundo.com
Phone: 673463531 (Pedro Damián Cano Borrego as Compliance Office)
Physical mailbox of the Whistleblowing Channel: Located in the kitchen area.
Mailing Address:

EUROPA MUNDO VACACIONES S.L.U.
Whistleblowing Channel
C/ GARCIA DE PAREDES, 55
28010 – MADRID

COMMITTEES AT EUROPAMUNDO

As a complement to the entire compliance management system, we have several committees at Europamundo that ensure compliance and the proper functioning of the company's activities, following national and international laws, and the protocols and codes established within the company.