AUTOPULLMAN San Sebastián, S.L. CORPORATE COMPLIANCEAUTOPULLMAN SAN SEBASTIÁN, S.L. is a company whose corporate purpose is road transport in all its forms. Our activity is focused on the bus and minibus rental service for transfers from the Basque Country to any destination. Our “Crime Prevention System” or “Criminal Compliance System” (hereinafter “Compliance System”) includes as an essential concept that all the people who form AUTOPULLMAN SAN SEBASTIÁN carry out our activities with the commitment to comply with current legislation, with special reference to criminal law, as well as with the ethical principles set out in our internal regulations, consistent with our values of professionalism, quality, punctuality and personalisation, and our culture of social commitment, gender equality and transparency. This “Criminal Compliance Policy” (hereinafter the “Policy”) establishes and communicates the objectives and general principles of action of the Compliance System. Objectives: The main objectives of the AUTOPULLMAN SAN SEBASTIÁN Compliance System are: To promote a positive and constructive culture of business ethics at AUTOPULLMAN SAN SEBASTIÁN, involving all the people who make up the company, based on the principle of “zero tolerance” towards the commission of illegal acts, breaches of regulations or any type of corruption, abuse or discrimination. Comply with the different legal obligations and business diligence guidelines in this area, with special reference to European Union, state and regional regulations. Prevent the commission of crimes and breaches of regulations in the company, avoiding legal liabilities (criminal, civil, etc.), the imposition of sanctions and fines and third party claims. To increase the reputational capital of AUTOPULLMAN SAN SEBASTIÁN, avoiding risks and guaranteeing its value. Consolidate the relationship with the most relevant “third parties of interest”: clients, suppliers, collaborators in projects, public administrations, etc. Anticipating the demands of the international market. Therefore, the Compliance System contributes to guaranteeing and increasing the value of AUTOPULLMAN SAN SEBASTIÁN and to protecting the company against possible liabilities. Scope of application This Policy is binding and applicable, without exception and regardless of their position, responsibility, occupation or location, to all AUTOPULLMAN SAN SEBASTIÁN personnel, in the terms defined by the applicable criminal law. General Principles of Action In order to achieve the objectives of the AUTOPULLMAN SAN SEBASTIÁN Compliance System, the following General Principles of Action are established: Obligatory compliance with applicable legislation, internal regulations and other regulations applicable to AUTOPULLMAN SAN SEBASTIÁN depending on its activity (project bases, etc.). Identification and assessment of risks. AUTOPULLMAN SAN SEBASTIÁN identifies and evaluates the different risks that exist due to its activity, and implements the necessary measures to mitigate or eliminate them. Definition and implementation of appropriate procedures. AUTOPULLMAN SAN SEBASTIÁN has policies, procedures and processes for the prevention of crime and non-compliance with regulations that are appropriate to its activity and structure. Updating of the Compliance System. Monitoring, analysis and continuous updating of risks and procedures. Training. AUTOPULLMAN SAN SEBASTIÁN staff receive sufficient training to be aware of the objectives and operation of the company’s Compliance System. Obligation to report possible unlawful conduct or conduct involving non-compliance with regulations: for this purpose, an Ethics Channel is established, accessible through the website https://autocaresdavid.com/, managed in the first instance by an external company and guaranteeing total confidentiality. Obligation to cooperate. All AUTOPULLMAN SAN SEBASTIÁN personnel are obliged to collaborate in any possible steps or investigations that may be carried out to clarify the facts related to the alleged infringements. Provision of resources. AUTOPULLMAN SAN SEBASTIÁN will dedicate sufficient resources to ensure the effective operation and continuous improvement of its Compliance System, with special reference to the duties of supervision, monitoring and control. Control body. AUTOPULLMAN SAN SEBASTIÁN has an internal body for supervising compliance with its Compliance System (“Compliance Officer”). Consequences of non-compliance. AUTOPULLMAN SAN SEBASTIÁN will apply the disciplinary system and will take the actions that correspond to it in law in the event of non-compliance both of a criminal nature and of other internal or legal regulations applicable to the company.
- Communication. This Policy and the company’s Ethical Channel will be available to all interested persons through its corporate website https://autocaresdavid.com/. Likewise, they will be the object of communication actions for their proper understanding and implementation.Updating and review This Policy shall be reviewed and updated periodically in order to adapt it to regulatory changes and those that may arise in the activities of AUTOPULLMAN SAN SEBASTIÁN, guaranteeing its effective implementation at all times. Approval and validity This Policy has come into force at the time of its approval by the sole Administrator of AUTOPULLMAN SAN SEBASTIÁN, S.L. on 31 May 2022 and shall be applicable in the terms established and until its update, revision or repeal is approved. In Oiartzun (Gipuzkoa), 31st May 2022. Signed: D. CESAR MARTÍN PAILOS Sole Administrator