Compliance Policy

Responsable

Role	Position	Name
Responsible	Ethics and Compliance Committee	Various
Responsible for legal interpretation and updating	Ethics and Compliance Committee	Various
Responsible for compliance	Ethics and Compliance Committee	Various

Version Control

Version	Description of changes	Revised by	Revision Date	Approved by	Date of approval
1	Initial version
2	Revision according to UNE 19601 and UNE 19602			Ethics and Compliance Committee and Board of Directors	15-01-24 18-01-24

1. Introduction

The JULIÀ GROUP (hereinafter the JULIÀ GROUP or the Company, indistinctly) could be criminally liable in the event of a crime being committed and not having 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, CCMS) has been adopted and effectively implemented in accordance with the requirements of article 31 bis 5 of the Criminal Code.

Therefore, at GRUPO JULIÀ we have a SGCPT to highlight our commitment to ethical and regulatory compliance, as well as to minimise the commission of criminal acts and tax offences.

Specifically, the SGCPT is a set of internal regulations that makes clear the ethical and compliance position that the JULIÀ GROUP maintains in the development of its activities and complies with the provisions of the Criminal Code, the UNE 19601 on Criminal Compliance Management Systems (hereinafter, UNE 19601) and the UNE 19602 on Tax Compliance Management Systems (hereinafter, UNE 19602). In this way, the PTMS establishes a series of principles and guidelines for action that must be respected and complied with at all times.

Finally, it should be noted that the aim of the JULIÀ GROUP’s SGCPT, in addition to promoting a true business culture and respect for the Law, is none other than to ensure compliance with the legal-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 SGCPT are the following:

To inform all members of the Company and its stakeholders of the importance of compliance with the SGCPT and to raise their awareness of the importance of regulatory compliance and especially the prevention of criminal risks.
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, with the principles established in the Code of Ethics, and in strict compliance with criminal matters, promoting a culture of proper compliance, and strongly condemning any criminal action.
To guarantee that the JULIÀ GROUP complies with the duties of control and supervision of its activity, establishing suitable measures to prevent or reduce the risk of the commission of crimes, exercising the legally appropriate control over its members and third parties.
Establish a general framework for the Company’s SGCPT, 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 SGCPT is the development of the activities by GRUPO JULIÀ that are detailed below.

With regard to the subjective scope of the JULIÀ GROUP’s SGCPT, compliance is mandatory for all members, regardless of their position or position; as well as, where appropriate, for any other interested party of the Company.

In this sense, this Compliance Policy is a public document, to which any member of the JULIÀ GROUP, as well as its interested parties, may have access as appropriate.

Therefore, the aforementioned compliance is not the exclusive property of those who have control and supervision functions, but 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 the JULIÀ GROUP.

The JULIÀ GROUP companies to which the SGCPT 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 in the administrative bodies promote, whenever possible, the adoption of SGCPT or control measures equivalent to those implemented in GRUPO JULIÀ.

The companies that eventually join the JULIÀ GROUP or are considered to be controlled by the companies of the Company must adopt the appropriate decisions for the purpose of adapting their internal regulations to this Compliance Policy and the JULIÀ GROUP’s PQMS and make them immediately effective on the part of their members.

As has been introduced, the adherence to the principles and objectives of this Compliance Policy and the SGCPT is also promoted to the interested parties of the JULIÀ GROUP (such as its suppliers and collaborators), as long as the specific existing circumstances so permit, and with the sole purpose of guaranteeing compliance with the Law and diligent action at all times.

4. Principles of the JULIÀ GROUP’s SGCPT

The general principles governing the JULIÀ GROUP’s SGCPT and all the actions of its members are as follows:

To respect and act in accordance with the provisions contained in current legislation, the Company’s Code of Ethics and all internal protocols and regulations with the aim of preventing, detecting, avoiding and responding appropriately to the commission of any acts that may constitute crimes according to the criminal regulations applicable at any given time.
Promote a culture of business ethics and prevention of criminal actions, and do not tolerate the commission of illegal acts.
To have permanently updated and effective control systems for the prevention, detection and adequate reaction to illicit or irregular actions.
Establish the necessary procedures, protocols and internal rules to prevent criminal actions.
Ensure the material, financial, technological and human resources for the application of this Compliance Policy and to have an effective SGCPT.
Disseminate the duty to all members of the Company to report in good faith any facts or conduct that are reasonably suspected of constituting criminal acts.
To have an Ethics and Whistleblowing Channel where all members of the Company can report any fact that could potentially constitute a criminal offence, guaranteeing in all cases the indemnity of the person reporting such facts in good faith.
Investigate as quickly as possible any allegedly criminal acts detected, guaranteeing at all times the rights of the persons under investigation.
Apply the system of penalties in the event of non-compliance linked to possible criminal offences in accordance with the applicable labour regulations.
Continuously train the entire Company in criminal compliance matters, guaranteeing the updating of their knowledge and the promotion of a culture of business ethics and compliance with the Law.
Continuously improve the SGCPT in general, and particularly the elements that comprise it, based on the information obtained and generated during its application.
Disseminate internally this Compliance Policy, the functioning of the SGCPT, the Code of Ethics and all those internal protocols and rules that affect the Company in an updated manner, as well as to other interested parties that may represent criminal risks.

5. SGCPT of GRUPO JULIÀ

The JULIÀ GROUP has a CPCMS (crime prevention organisation and management model) that must be reviewed periodically to ensure its efficiency. Specifically, the SGCPT comprises the following elements:

Criminal and tax risk report.
Code of Ethics.
This Compliance Policy.
Compliance Manual.
Ethics and Complaints Channel.
Other internal policies, protocols and regulations.

The SGCPT identifies the main crimes that must be prevented (Risk Map) by GRUPO JULIÀ. It also establishes procedures and controls for the prevention of criminal actions, as well as the Departments affected and those responsible for their supervision, which will fall to the Ethics and Compliance Committee.

Likewise, the appropriate material, human and financial resources are allocated annually to carry out preventive activities to avoid the commission of crimes.

The Ethics and Compliance Committee

The Ethics and Compliance Committee of GRUPO JULIÀ is the collegiate body responsible for supervising the implementation of the SGCPT, ensuring that its content is adequate and promoting its compliance, appointed by the Board of Directors, with autonomous powers of initiative and control for the supervision of the functioning and compliance of the SGCPT. In addition, the Ethics and Compliance Committee is also in charge of managing the Ethics and Whistleblowing Channel and internal investigation procedures.

The Ethics and Compliance Committee will subject the CQMP to periodic review and continuous improvement to ensure that its design and operation are adequate to the requirements of the applicable regulations and to demonstrate that proper control is being exercised.

The Ethics and Compliance Committee is responsible for promoting the necessary initiatives for the appropriate dissemination and training of personnel in ethics and the prevention of criminal risks, so that the members of the Company can adequately comply with their obligations in this area.

The Ethics and Compliance Committee should be contacted in case of doubt as to how to act, as well as to communicate any relevant fact or improvement.

6. Ethics and Whistleblowing Channel

The effectiveness of the JULIÀ GROUP’s SGCPT and of this Compliance Policy requires having a communication channel through which queries can be made to the Ethics and Compliance Committee regarding the interpretation of the Code of Ethics or reporting a possible violation or breach of the Code of Ethics, the Compliance Policy or the rest of the internal regulations, processes and controls that make up the SGCPT, 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 as follows: https://grupojulia.integrityline.com

The Ethics and Whistleblowing Channel is managed by the Ethics and Whistleblowing Channel Manager and guarantees that no retaliation, discrimination or sanctions will be taken against persons who report any breach or criminal offence in good faith.

In addition, certain third parties (including customers, suppliers and other sales representatives) have access to the Ethical and Whistleblowing Channel of the JULIÀ GROUP to report the aforementioned risks and breaches of which they may become aware.

7. Commitment to ethical and regulatory compliance

The JULIÀ GROUP is a business organisation that carries out its activity in accordance with the requirements of ethical and regulatory compliance. In this sense, respect for all the values and principles of action established in our Code of Ethics forms part of our organisational culture. In this way, each of the members that form part of the JULIÀ GROUP accept these values and principles as our own, extending them to all third parties with whom we maintain business relations.

Respect for compliance with current legislation and the technical procedures to which our activity is linked also forms part of our organisational culture. In terms of Compliance, this commitment means that each and every member of the JULIÀ GROUP must try to avoid any conduct or activity that involves a breach of current legislation.

The JULIÀ GROUP requires all its members, in the development of their business activities, to comply with the regulations that are applicable in their corresponding areas of activity. Furthermore, we must also promote an organisational culture aligned with Compliance with those third parties with whom we maintain commercial relations.

In any case, the prohibition of committing criminal acts or infringing tax regulations through or on behalf of the JULIÀ GROUP applies to any member of the JULIÀ GROUP, whatever their position or function. Failure to comply with any of the provisions established in the SGCPT will be subject to a sanction proportionate to the seriousness of the act and in accordance with the applicable labour regulations.

GRUPO JULIÀ will actively apply policies that promote a good working environment, a culture of prevention and that contribute to preventing situations that deteriorate it. Likewise, collaboration, cooperation and trust in relations between the different levels and units of the JULIÀ GROUP and between its members will be encouraged and strengthened.

At GRUPO JULIÀ we understand that the prevention of criminal and tax risks is not a one-off activity but a permanent and constantly evolving one. To this extent, our SGCPT 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.

8. Control structure of the JULIÀ GROUP

The effectiveness of the SGCPT depends to a large extent on the preventive and control functions, as well as on the involvement of all its members in the exercise of their functions.

In accordance with the requirements of the Criminal Code, the JULIÀ GROUP has defined a control structure made up of:

The Board of Directors of the Company, as the highest decision-making body.
The Ethics and Compliance Committee.
The Senior Management, in addition to those responsible for the corresponding preventive procedures or controls.
All members of the JULIÀ GROUP.

9. Consequences of non-compliance

Failure to comply with this Policy and the other regulations that make up the SGCPT may give rise to the application of labour disciplinary measures, including disciplinary dismissal, or the termination of the corresponding contract, in any case, under the current labour law framework, without prejudice to any criminal sanctions or civil claims that may be applicable.

The severity and repetition of the infringement shall be taken into account when determining the disciplinary sanction, and the system of sanctions regulated in the applicable Collective Bargaining Agreement and the Workers’ Statute shall always be applicable.

Notwithstanding the foregoing, such breaches may also be reported to the relevant authorities, in the event that they may constitute a criminal offence.

10. Approval of this Compliance Policy

This Compliance Policy has been approved by the Board of Directors of the JULIÀ GROUP, at which time it has come into force.

This Compliance Policy may be reviewed and modified by the Board of Directors of the JULIÀ GROUP at its own initiative or at the suggestion of the Ethics and Compliance Committee, in order to improve the SGCPT or adapt it to new legal requirements or regulatory changes.