Tax Compliance Policy

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Version	Description of changes	Revision Date	Approved by	Date of approval
1	Approval first version		Ethics and Compliance Committee Board of Directors	05-02-2024 05-03-2024

1. Introduction

It is the wish of the Board of Directors and Senior Management of the JULIÀ GROUP to have a policy for the prevention of risks due to tax non-compliance and by means of which the tax strategy of JULIA INTERNACIONAL, S.L. and the companies in which it has a majority shareholding (hereinafter jointly referred to as the JULIÀ GROUP or the Company, indistinctly) is established.

This Policy expressly sets out the Group’s general commitment to comply with tax regulations in Spain and in the other countries in which the company operates. It is also the objective and commitment to develop the best practices in this area and to maintain an appropriate relationship with the corresponding Tax Administration, and it is the responsibility of the Directors, Executives and employees to comply with this commitment, as well as all third parties who interact with the JULIÀ GROUP.

2. Scope of application

This Tax Compliance Policy applies to the JULIÀ GROUP, in general, as well as to the different companies that comprise it:

Company	TAX ID	Registered Office
EUROWAYS, S.L.	B58606062	C/ Pablo Iglesias 84, L’Hospitalet de Llobregat 08908 Barcelona
AUTOCARES JULIÀ, S.L.U.	B08095390	C/ Pablo Iglesias 84, L’Hospitalet de Llobregat 08908 Barcelona
JULIÀ TRAVEL, S.L.U.	B29045895	C/ Puerto de Used, 20 28031 Madrid
INMOBILIARIA DUCH, S.L.U.	B08104705	C/ Pablo Iglesias 84, L’Hospitalet de Llobregat 08908 Barcelona
KAUTRAS, S.L.	B63026330	C/ Pablo Iglesias 84, L’Hospitalet de Llobregat 08908 Barcelona
CAMPANEVADO, S.L.U.	B78342029	C/ Puerto de Used, 20 28031 Madrid
MED TRAVEL VENTURES, S.L.	B66627605	Passeig Joan de Borbó 103, Port Marina Vela Local 5 – 08039 Barcelona

3. Objectives of the policy

The Tax Compliance Policy of GRUPO JULIÀ aims to achieve the following objectives without detriment to efficient business management:

To create a Tax Compliance culture.
To transmit to all members of the Group (Directors, Executives and other employees), as well as to third parties related to it, the resounding and truthful message that the JULIÀ GROUP is opposed to the commission of any tax offence or illegal act and that it ensures that the development of its tax activity is based on respect for the Law, on the promotion and defence of the values that emanate from the Code of Ethics and, in particular, on compliance with tax regulations in all their forms, in order to preserve the image and values of the Group.
Reinforce the commitment, already in place, to work towards respect for tax regulations and to maintain zero tolerance for non-compliance of any kind.
Comply with the legal and regulatory requirements that are established in order to achieve continuous improvement of the SGCPT, as well as to comply with the recommendations of the UNE 19602 Standard.
To avoid any type of tax penalty that could be imposed on any of the Group’s companies, as well as the economic losses or reputational damage that these could cause to the JULIÀ GROUP.
Establishing the necessary mechanisms to guarantee that the persons included in its scope of application are aware of potentially criminal conduct, also including a disciplinary system for actions contrary to the regulations, in accordance with the provisions of the collective agreement in question.
The existence of a clear commitment in the organisation to continuous improvement of the control framework.

In short, the main objective of the JULIÀ GROUP through the approval of this Tax Compliance Policy and the implementation of its SGCPT is to monitor and supervise those situations potentially generating tax risks that may arise in its sphere of action, minimising the possibility of incurring any type of liability (criminal, commercial or tax) due to the commission of any offence or non-compliance of a tax nature.

4. Principles of action

The actions of the JULIÀ GROUP concerning the management of tax matters shall be governed by the following principles of action:

Faithful compliance with tax regulations by the JULIÀ GROUP and, consequently, by all persons involved not only in tax management, but also in the performance of transactions with a tax impact.
In line with the previous section, the JULIÀ GROUP shall ensure that it complies with its tax obligations in due time and form, filing its taxes in an appropriate manner with all the relevant information and in accordance with the applicable regulations.
Assessing the impact of any new developments or changes in the tax environment on the operations of the JULIÀ GROUP companies.
The adoption of decisions on tax matters by the JULIÀ GROUP on the basis of a reasonable interpretation of the applicable regulations.
Informing the governing bodies of the companies that make up the JULIÀ GROUP of the main tax implications of the transactions or matters submitted for their approval, when they constitute a relevant factor in forming their will.
The establishment of the necessary mechanisms to analyse, prior to approval, the tax implications of any type of investment, corporate transaction, signing of contracts or other actions that could have tax implications.
The implementation of procedures to ensure the existence of an effective and complete system for the detection, reduction and management of tax risks, with the appropriate mechanisms to control and prevent possible non-compliance by the JULIÀ GROUP in its area (i.e. the SGCPT).
The integration and coordination of the set of actions necessary to prevent and combat the commission of tax offences by any professional of the company or any other company related to it, in their joint activity.
Fostering a relationship with the tax authorities based on respect for the law, loyalty, trust, professionalism, collaboration, reciprocity and good faith, without prejudice to any legitimate disputes which, while respecting the foregoing principles and in defence of the corporate interest, may arise with these authorities regarding the interpretation of the applicable regulations.
The reduction of conflicts arising from the interpretation of the applicable regulations, through the use of instruments established for this purpose by the tax systems.
Generate an environment of transparency, integrating the different systems developed for the prevention of irregularities, tax infringements, etc., and maintaining the appropriate channels to encourage the communication of possible irregularities.
Ensure that the bodies in charge of supervising and controlling the application of the Tax Compliance Policy and the SGCPT have the resources, autonomy and sufficient authority and independence to oversee operation and compliance in an effective and proactive manner, without prejudice to the responsibilities corresponding to other bodies and management of the Group and, where appropriate, to the administrative and management bodies of the companies that carry out the business of the JULIÀ GROUP.

5. Tax strategy

The JULIÀ GROUP’s tax strategy is governed by the following guidelines:

To comply with current tax regulations, adopting at all times a reasonable interpretation of the same and closely linked to its activity.
Avoid the use of opaque structures for tax purposes, understood as those in which, through the interposition of special purpose vehicles located in tax havens or territories that do not cooperate with the Tax Authorities, are intended to prevent the latter from being aware of the person ultimately responsible for the activities or the ultimate owner of the assets or rights involved.
Avoid interpretations tending towards aggressive tax planning, as well as the use of artificial and opaque structures, with the aim of reducing the tax burden.
Avoid operating through tax havens and non-cooperative territories with the European Union with which Spain has not signed an agreement to avoid double taxation. And, should GRUPO JULIÀ be obliged to do so, to carry out a detailed analysis of the inherent tax risks.
To promote a relationship of full collaboration with the Tax Authorities, based on the principles of transparency, good faith and mutual trust.
To collaborate with the competent Tax Authorities in the detection and search for solutions with respect to those fraudulent tax practices that may develop in the markets in which the JULIÀ GROUP is present, in order to eradicate those that already exist and prevent their extension.
To diligently provide the information requested by the Tax Authorities, truthfully, in due time and to the appropriate extent.

6. Reporting of conduct and disciplinary systems

6.1 Behavioural communication

The effectiveness of the JULIÀ GROUP’s SGCPT and of this Tax Compliance Policy requires having a communication channel through which consultations can be made to the Ethics and Compliance Committee on the interpretation of the Code of Ethics or reporting a possible violation or breach of the Code of Ethics, of the Tax Compliance Policy or of the other internal regulations, processes and controls that make up the SGCPT, as well as other criminal or irregular practices.

Therefore, all members of the Group 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 in conjunction with the Ethics and Compliance Committee, ensuring that no retaliation, discrimination or sanctions will be taken against persons who report any illegal or irregular breach in good faith.

The personal data collected through the Ethics and Whistleblowing Channel are processed by the Data Controller at GRUPO JULIÀ. The data is retained on a time-limited basis for internal investigations and may be confidentially shared with third parties related to the investigation. In cases of international transfer, data protection is guaranteed in accordance with European regulations. Members can exercise their data protection rights and lodge complaints.

In addition, certain third parties (including customers, suppliers and other business partners) have access to the JULIÀ GROUP’s Ethics and Whistleblowing Channel to report the risks, breaches and behaviours referred to above of which they may become aware.

6.2 Consequences of non-compliance

All members of the Group are responsible for understanding, observing and applying the provisions of this Tax Compliance Policy.

Therefore, any actions contrary to the provisions of this Tax Compliance Policy that result in non-compliance in the tax or compliance area may be sanctioned in accordance with the provisions of internal procedures, applicable legislation or the corresponding sanctioning regime. Disciplinary measures will be imposed to correct the infringements detected depending on their seriousness.

The measures adopted from a labour perspective shall be respectful of the applicable regulations, without losing forcefulness or proportionality with the seriousness of the facts from which they arise, informing the legal representatives of the employees if appropriate.

7. Implementation guidelines

GRUPO JULIÀ implements the control mechanisms and procures the necessary resources for effective compliance with tax regulations and this Tax Compliance Policy, ensuring that all persons involved in tax practice have sufficient technical training commensurate with their level of responsibility, as well as independence in their actions.

In compliance with the above, GRUPO JULIÀ has a Tax Department in its organisational structure, currently made up of two people, a functional unit reporting directly to the Financial Department, which may, if it deems it appropriate at any time, resort to external advisors or consultants.

The Group has a solid structure for the verification and control of actions with tax implications. The Tax Department is duly equipped with the necessary resources to manage the relevant tax declarations for GRUPO JULIÀ, as well as having the capacity to adapt to current legislative changes. The heads of the Tax Department closely monitor the possible tax risks that could affect the Group, implementing preventive measures to avoid their occurrence and mitigate their effects should they materialise.

Likewise, external experts in tax, accounting and labour issues provide additional support in decision-making and management of the Tax Compliance Policy. GRUPO JULIÀ channels any uncertainty or query on tax matters to these external advisors, and external reviews of tax returns, tax decisions and regulatory updates are carried out within the Group.

In addition to this external advice, both the Accounting and Human Resources Departments have a second external line of control for those decisions that may have tax implications for the Group. This ensures independent and comprehensive supervision of financial and human resources activities, guaranteeing regulatory compliance and minimising tax risks.

The Tax Department is obliged to report to the Board of Directors on internal changes that may significantly affect the Group and must regularly ensure that tax policies are communicated both to the members of the JULIÀ GROUP itself and to third parties related to it.

The head of the Tax Area forms part of the Ethics and Compliance Committee, which 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. This Committee is also responsible for managing the Ethics and Complaints Channel and internal investigation procedures.

Likewise, the members of the Tax Area will be responsible for providing advice on tax matters to the different Areas and Departments concerned. In particular, they will identify, advise and report on the risks of sanctions and financial and reputational losses due to non-compliance.

The Finance Department and Management, as part of its function of supervising the effectiveness of internal control and risk management systems, as well as the preparation and integrity of financial information, will receive information from the Tax Department, at least annually and on the occasion of the closing of accounts, on the relevant tax policies followed during the year. It shall also receive information in the event of significant events or changes in tax regulations that affect the business and may entail a financial loss for the entity. It shall also inform the corporate bodies to the extent appropriate in accordance with its powers. The Board of Directors determines the risk control and management policy, approves the investments or operations which, either due to their high amount or their special characteristics, have a special tax risk, and also determines the tax strategy of the JULIÀ GROUP.

Under these responsibilities, the Board of Directors, through its Chairman, Chief Executive Officer, its Managers and, in particular, through the Tax Department, promotes the monitoring of tax principles and good tax practices.

The functions of supervising the functioning and effectiveness of the JULIÀ GROUP’s SGCPT are assigned to the Ethics and Compliance Committee, functions that already form part of its area of responsibility for supervising the general Compliance programme and which it will carry out independently and permanently.

The Tax Department ensures proper compliance with this Tax Compliance Policy by establishing the necessary internal control mechanisms and rules, reporting to the Board of Directors. Without prejudice to the information that may be transmitted to the Board of Directors of the JULIÀ GROUP at any time, this body may request the Tax Department at any time for information or advice necessary for decision-making.

The Tax Department is entrusted with the following functions, among others:

Verifying compliance with the JULIÀ GROUP’s Tax Compliance Policy and other internal tax policies.
Detecting, analysing and monitoring tax risks and contingencies.
Tax planning of investments and divestments made by the JULIÀ GROUP, recommending the use of appropriate and optimal structures.
Providing training to employees on tax matters, as well as on the Tax Risk Control and Management System.
Adopt the pertinent measures, implementation of systems and automatisms that increase security and efficiency in the achievement of the objectives set.
Attend to and/or advise on complaints or comments received directly or through the channels for reporting non-compliance (Ethics Channel) and for resolving queries relating to the Group’s Tax Risk Management and Control System.

8. Dissemination and communication

The Ethics and Compliance Committee, together with the Tax Department of the JULIÀ GROUP, is responsible for ensuring the effective dissemination of this Tax Compliance Policy and making it known to employees or any interested party, as well as any modifications that may be agreed, as the case may be.

In this regard, dissemination and training activities are carried out in the area of tax risk prevention aimed exclusively at training the members of the Group and disseminating this Policy.

In addition, as established in the UNE 19602 standard, the Group’s Tax Compliance Policy is made available to third parties through the website, together with other relevant information such as the Code of Ethics.

9. Control of compliance

The effectiveness of compliance with this Policy requires an adequate control model. Fiscal control is configured as follows:

The companies of the JULIÀ GROUP are obliged to report annually to the Financial Department their tax situation together with the rest of the obligations to which they are subject to report.

The controls for tax risk management are subject to the annual review cycle of the internal control areas in order to assess their suitability and effectiveness.

External consultancies and advisors act as a line of defence, assessing the activity of the front lines, following a risk-based approach and with a universal scope.

In addition, as part of the general risk management and control model of the JULIÀ GROUP, it is compulsory to have a series of specific tax risk indicators, in order to contribute to the establishment and management of the risk profile in tax matters.

The process of evaluating and monitoring these indicators is carried out in order to:

Identify tax risks.

Assess the impact of the materialisation of tax risks.

Develop measures of redirection that allow a dynamic management of the tax risk.

Report and generate relevant information on the evolution of tax risks for the Group’s governing bodies.

The Ethics and Compliance Committee is informed every four months by the Tax Department of the relevant tax information, including the main risks, degree of compliance with the Principles and the Tax Strategy, and any other information that must be reported as a result of the legal provisions in force and/or the commitments assumed by the JULIÀ GROUP.

On an annual basis or upon the occurrence of any event requiring changes to this Tax Compliance Policy, the Ethics and Compliance Committee reviews it and, if appropriate, the updates and modifications deemed necessary or advisable are submitted to the consideration of the Board of Directors of GRUPO JULIÀ.

Without prejudice to the foregoing, the modification of references to the nomenclature of areas, units and Internal Regulations shall be carried out by the Tax Department without the need for this type of modification to be submitted to the approval of the Board of Directors of the JULIÀ GROUP, but with the mandatory periodic notification.