Code of Ethics

Responsible

RolePositioName
ResponsibleEthics and Compliance Committee
Responsible for Legal interpretation and updatingEthics and Compliance Committee
Responsible for Compliance

Version Control

VersionDescription of changesRevised byRevision DateApproved byDate of approval
1.0Initial version
2.0Normative and formal update of the documentEthics and Compliance Committee, Roca Junyent y Molins Defesa PenalJanuary 2024

1. Introduction

The aim of this Code of Ethics is to establish a model of conduct and development of the activity of the companies that make up the JULIÀ GROUP (hereinafter the JULIÀ GROUP or the Company, indistinctly) that reflects those principles and values in which we believe and to which we aspire.

With these aims we assume a commitment to Quality, Safety at Work and in Passenger Transport, Respect for the Environment and the general attitude of Social Responsibility manifested in all our actions.

2. Scope of Application

This Code of Ethics is applicable to all members of the JULIÀ GROUP, regardless of our activity. Furthermore, its content is also addressed to those third parties who interact on behalf of the JULIÀ GROUP, as well as to other third parties when so established between the parties.

3. Our Values

Our Code of Ethics is governed by the following values:

  • Trust and experience: The trust of our customers is one of the most important elements of GRUPO JULIÀ. Through more than 80 years of experience, we have become a benchmark in the sector.
  • Safety: The safety of our customers is our greatest concern, which is why our fleet undergoes regular maintenance plans and exhaustive checks that guarantee the safety of both our customers and our drivers.
  • Integrity and Flexibility: Our team always carries out its activity with integrity and respect for others. In addition, we have a team with a great capacity to adapt to different situations.
  • Transparency: Transparency in communications between members of the JULIÀ GROUP is an essential element in creating the good working environment that exists within the Group and which we all have a duty to maintain.
  • Quality: We are demanding in the provision of our services in order to offer the highest quality to our customers.

4. Our Members

Our members are our greatest strength. For this reason, at GRUPO JULIÀ we promote a good, stimulating and motivating working environment that allows the professional and personal development of our members.

4.1 Selection, training, evaluation and promotion

We select our members taking into consideration their individual and collective abilities and their accredited professional experience.

At GRUPO JULIÀ we are concerned about the training of our members, offering them continuous training programmes appropriate to the activity of each one of them, with the aim of helping them in their job and to help them acquire the necessary knowledge to improve the organisation.

For the evaluation and promotion of our members, we take into consideration the professional performance of each one of them and we base ourselves on objective and impartial criteria.

4.2 Equality and non-discrimination

At GRUPO JULIÀ we consider equality and non-discrimination to be an essential element in all relations between people,

both at work and personally, respect.

For this reason, we always respect the rights of expression, opinion and association of workers and reject any conduct that constitutes harassment or discrimination for any reason (sex, race, religion, political orientation, etc.).

In this way, all members must treat each other in an exemplary manner in order to maintain a pleasant and conflict-free working environment.

4.3 Confidential Information

We are all responsible for protecting the confidential information of the JULIÀ GROUP and for ensuring that this information is not used for purposes unrelated to the exercise of the JULIÀ GROUP’s activity. Under no circumstances may we use confidential information for personal gain or that of third parties, even after the employment relationship has been terminated.

In the event of any doubt as to whether or not confidential information may be passed on, we must first consult our immediate superior.

5. Our Assets

All members of the JULIÀ GROUP must protect business assets such as means of transport or vehicles and electronic media, and promote the efficient and legitimate business use of all of them, for which purpose various corporate guides and policies are provided that provide information on the guidelines to be followed in the protection of these business assets.

The good reputation is also one of the JULIÀ GROUP’s most valuable assets, so we must all protect it and avoid actions that could damage it.

6. Our Relationship with Customers, Suppliers and Public Administrations

6.1 Gifts

Members may not give or accept gifts or presents in the course of our professional activity. Exceptionally, however, the giving and acceptance of gifts and presents is permitted in such cases:

  • If they are of negligible economic value.
  • If they are customary business courtesies.
  • If they are not prohibited by law or generally accepted business practices.

The members of the JULIÀ GROUP may not accept hospitality that may influence our decision making.

6.2 Suppliers

When the members of the JULIÀ GROUP contract with suppliers we shall select them on the basis of an objective and impartial evaluation, without incurring in conflicts of interest or favourable treatment, following the following criteria, among others: quality, level of service, competitiveness, low risk and financial solvency.

6.3 Relations with Public Administrations

All relations with the Public Administration shall be carried out with the utmost correctness and transparency.

The members of the JULIÀ GROUP may not offer, grant, request or accept unjustified advantages or benefits that may represent an advantage for themselves, for the JULIÀ GROUP or for a third party.

In particular, we absolutely reject any conduct related to influence peddling, nor may we give or receive any kind of bribe, commission or bonus from any other party involved, such as civil servants or personnel from the public sector or from other companies or political parties, clients, suppliers or shareholders.

7. Conflicts of Interest

All members of the JULIÀ GROUP must avoid taking part in situations that may give rise to conflicts of interest. We understand that a conflict of interest exists when there is a direct or indirect conflict between the personal interests of the members of the JULIÀ GROUP and the interests of the companies that form part of the Group.

Although being in a situation of conflict of interest does not in itself imply committing an act of corruption, members of the JULIÀ GROUP must report such circumstances through the Company’s Ethics and Whistleblowing Channel.

8. Regulatory Compliance and the Ethics and Compliance Committee

All of us to whom the Code of Ethics applies must be aware of and comply with the legislation, regulations and professional codes that apply to us within the scope of our professional activity, and the Ethics and Compliance Committee of the JULIÀ GROUP will be responsible for ensuring this.

The Ethics and Compliance Committee of the JULIÀ GROUP is the body responsible for supervising the implementation of the Criminal and Tax Compliance Management System (SGCPT) of the JULIÀ GROUP, ensuring that its content is adequate and promoting its compliance.

Among others, the members of the JULIÀ GROUP have the following compliance duties

compliance with regulations:

  • We will comply with the tax, financial and labour regulations applicable in each case.
  • The accounting records must be accurate, faithful, complete and allow all the operations of the JULIÀ GROUP to be audited. We must keep the accounting records of the JULIÀ GROUP in accordance with internal rules and applicable regulations. All payments and commitments of the JULIÀ GROUP must be adopted and executed with the prior authorisation granted by the competent level of approval and all accounting records must be drawn up by duly authorised personnel.
  • We do not enter into business relationships with persons or entities that do not comply with regulations relating to the prevention of money laundering and the financing of terrorism or the protection of personal data.
  • We do not perform any act that may result in a corruption or bribery offence, in accordance with the applicable legislation in each case.
  • We comply with competition rules and principles and conduct our business fairly and without violating applicable antitrust laws.
  • We process personal data in such a way as to guarantee their privacy and in accordance with the applicable legislation.
  • As well as other responsibilities that may arise from compliance with the applicable legislation and the SGCPT of GRUPO JULIÀ.

Likewise, at GRUPO JULIÀ we count on the commitment of our members to familiarise themselves with and comply with the rules, policies, protocols and/or procedures, as well as the contractual obligations agreed with third parties.

9. Our Health and Safety and the Environment

9.1 Our Health and Safety

One of the priorities of GRUPO JULIÀ is the health and safety of our members in their jobs. For this reason, we favour the creation of a good working environment, as well as the establishment of the safest measures and working conditions for our members, complying with all the requirements set out in the regulations applicable to the sector.

In order to ensure the health and safety of our members and our clients, it is strictly forbidden to work under the influence of drugs or alcohol.

Furthermore, if any member of staff is involved in or becomes aware of an accident or dangerous situation, we must report it to the management or immediate superior.

9.2 The Environment

At GRUPO JULIÀ we are committed to protecting the environment. In this sense, we carry out studies and evaluations in advance of processes to reduce the environmental impact of our activity. We also aim to reduce polluting emissions and waste production to a minimum.

At GRUPO JULIÀ we encourage the rational use of natural resources and an awareness of the need to favour the environment.

10. Dissemination of the Code of Ethics

We will distribute the Code of Ethics of the JULIÀ GROUP to all its members on paper and will ask them to sign it as a sign of acknowledgement of receipt. The Code of Ethics will also be distributed to third parties who interact in the name and on behalf of the JULIÀ GROUP, as well as to suppliers, commercial representatives and external service agents. For these purposes, this Code of Ethics will be available on the website of the JULIÀ GROUP.

11. Ethical and Complaints Channel

The Ethics and Whistleblowing Channel is the means that the JULIÀ GROUP places at the disposal of its members to communicate to the Ethics and Compliance Committee any relevant fact or infringement of which they are aware, as well as to consult any doubt or query in relation to the Code of Ethics, the Compliance Policy or any other internal policy or regulation of the JULIÀ GROUP.

This is a totally confidential means and it is guaranteed that the person who has reported a violation will not suffer any reprisal, provided that it is used in good faith.

Likewise, the JULIÀ GROUP guarantees that the process of the Ethical and Whistleblowing Channel will comply in all its phases with all the obligations established by the personal data protection regulations, keeping the identity of the communicating party confidential at all stages of the process and, specifically, not disclosing it to third parties or to the person affected by the communication, among others.

Communications will be managed by the Ethics and Compliance Committee.

Queries regarding data protection can be sent to the following address: RGPD@julia.net and will in turn be handled by the GRUPO JULIÀ Data Controller.