Compliance Policy

Role	Position	Name
Responsible	Ethics and Compliance Committee	Various
Responsible for legal interpretation and updates	Ethics and Compliance Committee	Various
Compliance officer	Ethics and Compliance Committee	Various

Version	Description of Changes	Reviewed by	Review date	Approved by	Approval date
1	Initial version	Ethics and Compliance Committee	January 2024	Board of Directors	18-01-24
2	Review detailing the Group companies included in the PCCTMS	Ethics and Compliance Committee	12 December 2024	Board of Directors	31-01 2025

Introduction

GRUPO JULIÀ (hereinafter GRUPO JULIÀ or the Company, interchangeably) could be
held criminally liable if an offence is committed and it does not have the necessary means
to prevent it. In this context, in accordance with current criminal law, the criminal liability
of GRUPO JULIÀ may be avoided or mitigated if, prior to the commission of the offence, a
Criminal and Tax Compliance Management System (hereinafter, PCCTMS) has been
adopted and effectively implemented in accordance with the requirements of article 31 bis 5 of the Spanish Criminal Code.
For this reason, at GRUPO JULIÀ we have a PCCTMS in place to highlight our commitment to
ethical and regulatory compliance, as well as to minimise the commission of criminal acts and
tax infringements.
Specifically, the PCCTMS is a set of internal regulations that clearly reflects the ethical
and compliance position maintained by GRUPO JULIÀ in the performance of its activities and
complies with the provisions of the Criminal Code, UNE 19601 on Criminal Compliance
Management Systems (hereinafter, UNE 19601) and UNE 19602 on Tax Compliance
Management Systems (hereinafter, UNE 19602). In this way, the PCCTMS establishes a
series of principles and guidelines for action that we must respect and comply with at all times.
Finally, it should be noted that the objective of GRUPO JULIÀ’s PCCTMS, in addition to promoting
a genuine corporate culture and respect for the law, is none other than to ensure
compliance with the criminal regulations applicable to the Company.

2. Objectives of the Criminal and Tax Compliance Management System

In addition to the principles and objectives established in the Code of Ethics, which we must know and
apply in our day to day work, the main objectives of the PCCTMS are as follows:

To inform all members of the Company and its stakeholders about the
importance of compliance with the PCCTMS and raise awareness about the importance of
regulatory compliance, and especially about the prevention of criminal risks.
To convey the firm commitment to all members of the Company and its stakeholders
that GRUPO JULIÀ ensures that all actions carried out
are always respectful of the current legal system, of the principles
established in the Code of Ethics, and in strict compliance in criminal matters,
promoting an appropriate compliance culture and
firmly condemning any criminal conduct.
To ensure that GRUPO JULIÀ complies with the duties of control and supervision of its
activity, establishing appropriate measures to prevent or reduce the risk of
the commission of offences, exercising the legally required due control over its
members and third parties.
To establish a general framework for the Company’s PCCTMS, which includes
measures for the assessment, prevention, and detection of criminal risks.

3. Scope of the Criminal and Tax Compliance Management System and the Compliance Policy
The objective scope of the PCCTMS is the performance of the ordinary activities of the GRUPO JULIÀ
companies that will be detailed below.
With regard to the subjective scope of GRUPO JULIÀ’s PCCTMS, it is mandatory for
all members, regardless of their role or position, as well as, where appropriate,
for any other stakeholder of the Company.
In this regard, this Compliance Policy is configured as a public document,
which may be accessed by any member of GRUPO JULIÀ, as well as its stakeholders,
where appropriate.
Therefore, said compliance is not the exclusive responsibility of those who have
control and supervision functions, but rather affects all members of the Company at
all levels (as well as, where appropriate, its stakeholders), who must assume individual
responsibilities for regulatory and ethical compliance within the scope of their
functions in relation to GRUPO JULIÀ.
The GRUPO JULIÀ companies to which the PCCTMS applies and, consequently, this
Compliance Policy, are: EUROWAYS, S.L.; JULIÀ INTERNACIONAL, S.L.; INMOBILIARIA DUCH
S.L.; CAMPANEVADO, S.L.; KAUTRAS, S.L.; JULIA TRAVEL, S.L.; AUTOCARES JULIÀ, S.L. and MED
TRAVEL VENTURE, S.L.
In those investee companies in which the Company does not have control, its
representatives on the management bodies shall promote, whenever possible, the
adoption of PCCTMS or equivalent control measures to those implemented at GRUPO JULIÀ.
The companies that may eventually join GRUPO JULIÀ or are considered controlled
by the Company’s companies must adopt the appropriate decisions for the
purpose of adapting their internal regulations to this Compliance Policy and to GRUPO JULIÀ’s
PCCTMS and make them immediately effective for their members.
As introduced above, adherence to the principles and objectives of this
Compliance Policy and of the PCCTMS is also promoted among GRUPO JULIÀ’s stakeholders (such as
its suppliers and collaborators), provided that the specific circumstances so
allow, and with the sole purpose of ensuring compliance with the Law and diligent
conduct at all times.

To promote an ethical corporate culture and the prevention of criminal conduct, with
no tolerance for the commission of unlawful acts.

Principles of GRUPO JULIÀ’s PCCTMS
The general principles governing GRUPO JULIÀ’s PCCTMS and all actions of its members
are as follows:

GRUPO JULIÀ’s PCCTMS
– GRUPO JULIÀ has a PCCTMS (organisation and management model for the prevention of
offences) that must be reviewed periodically to guarantee its efficiency.
Specifically, the PCCTMS includes the following elements:
– Criminal and tax risk report.
– Code of Ethics.
– This Compliance Policy.
– Compliance Manual

5. Ethics and Whistleblowing Channel.
Other Policies, Protocols and internal regulations.
The PCCTMS identifies the main offences that must be prevented (Risk Map) by
GRUPO JULIÀ. It also establishes procedures and controls for the prevention of
criminal conduct, as well as the affected Departments and those responsible for their
supervision, which shall fall to the Ethics and Compliance Committee.
Likewise, adequate material, human and financial resources are allocated annually
to carry out preventive activities to avoid the commission of offences.
The Ethics and Compliance Committee
GRUPO JULIÀ’s Ethics and Compliance Committee is the collegiate body responsible for
supervising the implementation of the PCCTMS, ensuring that its content is appropriate, and promoting
its compliance. It is appointed by the Board of Directors, with autonomous powers of
initiative and control for the supervision of the functioning and compliance of the PCCTMS.
In addition, the Ethics and Compliance Committee is also responsible for managing the Ethics
and Whistleblowing Channel and internal investigation procedures. The Ethics and Compliance Committee shall subject the PCCTMS to periodic review and continuous improvement to ensure that its design and operation are appropriate to the requirements of the applicable regulations and to demonstrate that due control is being exercised. The Ethics and Compliance Committee is responsible for promoting the initiatives necessary for the proper dissemination of and training in ethical matters and the prevention of criminal risks, so that the members of the Company can properly comply with their obligations in this area. We must contact the Ethics and Compliance Committee in case of any doubt regarding how we should act, as well as to communicate any relevant fact or improvement.

Ethics and Whistleblowing Channel
The effectiveness of GRUPO JULIÀ’s PCCTMS and of this Compliance Policy requires the existence
of a communication channel through which queries can be made to the Ethics
and Compliance Committee regarding the interpretation of the Code of Ethics or to communicate a possible breach or
non compliance with the Code of Ethics, the Compliance Policy or the rest of the internal regulations,
processes and controls that make up the PCCTMS, as well as other criminal or irregular practices.
Therefore, all members of the Company are obliged to report the
possible risks and breaches referred to above through the Ethics and
Whistleblowing Channel created for this purpose.
The Ethics and Whistleblowing Channel is the following: https://grupojulia.integrityline.com
The Ethics and Whistleblowing Channel is managed by the person responsible for the Ethics and Whistleblowing Channel,
ensuring that no retaliation, discrimination or sanctions shall be taken against
persons who report any breach or criminal offence in good faith.
In addition, certain third parties (including customers, suppliers and other commercial partners) have
access to GRUPO JULIÀ’s Ethics and Whistleblowing Channel in order to report the risks and
breaches referred to above of which they may become aware.
Commitment to ethical and regulatory compliance
GRUPO JULIÀ is a business organisation that carries out its activity in accordance with the
requirements of ethical and regulatory compliance. In this regard, respect for all those values
and principles of action established in our Code of Ethics forms part of our organisational
culture. In this way, each of the members who form part of GRUPO JULIÀ accepts these values and principles as
their own, extending them to all those third parties with whom we maintain business
relationships.
Respect for compliance with current legislation and the technical diligence to which we link our activity
also forms part of our organisational culture. In matters of Compliance, this commitment implies that each
of the members of GRUPO JULIÀ must seek to avoid any conduct or activity that entails a breach of
current legislation.
GRUPO JULIÀ requires all its members, in the development of their business actions,
to comply with the regulations applicable within their respective areas of activity. In addition, we must also promote an organisational culture aligned
with Compliance among those third parties with whom we maintain business relationships.
In any case, the prohibition of committing criminal acts or breaching tax regulations
through or in the name of GRUPO JULIÀ extends to any member of GRUPO JULIÀ,
regardless of their position or function. Non compliance with any of the provisions established in
the PCCTMS shall be subject to a sanction proportionate to the seriousness of the act and in accordance with the
applicable labour regulations.
GRUPO JULIÀ shall actively implement policies that foster a good working environment, a
preventive culture, and help prevent situations that may deteriorate it. Likewise,
collaboration, cooperation and trust in the relationships between the
different bodies and units of GRUPO JULIÀ and among its members shall be encouraged and promoted.
At GRUPO JULIÀ, we understand that the prevention of criminal and tax risks is not a
one off activity but rather permanent and in constant evolution. Accordingly, our PCCTMS
is active and is reviewed periodically. Therefore, at GRUPO JULIÀ we are committed to
developing, reviewing and continuously improving all our policies, procedures and
processes focused on the prevention of criminal and tax risks.
Disciplinary system
GRUPO JULIÀ’s Compliance Manual (section 4.1.3) establishes a disciplinary system
for breaches in matters of criminal compliance, as well as of the Law and GRUPO
JULIÀ’s Code of Ethics and any of its policies, procedures or internal rules.
In the event of a breach, GRUPO JULIÀ shall exercise the appropriate legal and sanctioning measures
in accordance with the Workers’ Statute, legal regulations and the current collective bargaining
agreements that may apply.
GRUPO JULIÀ’s control structure
The effectiveness of the PCCTMS depends to a great extent on the preventive and control functions, as
well as on the involvement of all its members in the performance of their functions.
In accordance with the requirements of the Criminal Code, GRUPO JULIÀ has defined a control
structure made up of: – – – –
The Ethics and Compliance Committee.
The Company’s Board of Directors, as the highest decision making body.
Senior Management, as well as the corresponding persons responsible for procedures or
preventive controls.
All members of GRUPO JULIÀ.
Consequences of non compliance
Breaches of this Policy and of the rest of the regulations that make up the PCCTMS
may give rise to the application of labour disciplinary measures, including disciplinary dismissal,
or the termination of the corresponding contract, in any case within the current legal labour framework,
without prejudice to any criminal sanctions or civil claims that may apply.
When determining such disciplinary sanction, the seriousness and repetition of
the infringement shall be taken into account, always applying the sanction regime regulated in the
applicable Collective Bargaining Agreement and the Workers’ Statute.
Notwithstanding the foregoing, such breaches may also be reported to the
relevant authorities if they may constitute a criminal offence.
Approval of this Compliance Policy
This Compliance Policy has been approved by GRUPO JULIÀ’s Board of Directors, from which moment it entered into force.
This Compliance Policy may be reviewed and amended by GRUPO JULIÀ’s Board of
Directors on its own initiative or at the suggestion of the Ethics and
Compliance Committee, for the purpose of improving the PCCTMS or adapting it to new legal requirements or
regulatory changes.