Iberinbound Ethics channel

1. What the ethics channel is

Iberinbound Travel SLU is committed to acting with integrity and in compliance with the law. This channel allows anyone to report, confidentially and without fear of retaliation, any irregular, unethical or unlawful conduct related to our company, in line with Spanish Law 2/2023 on the protection of persons who report regulatory breaches and the fight against corruption.

2. Who can use it

The channel is open to:

• employees, former employees, interns and job candidates
• managers and shareholders
• clients, suppliers, contractors and their staff
• any other person who has information about a breach obtained in a work or professional context

3. What you can report

• breaches of European Union law or Spanish law, including criminal offences and serious or very serious administrative offences
• fraud, corruption, bribery or money laundering
• harassment, discrimination or breaches of labour and health and safety rules
• breaches of data protection, consumer protection or environmental rules
• any other conduct contrary to our values or internal policies

The channel is not intended for general enquiries, commercial complaints or booking issues. For those, please contact iberinbound@iberinbound.com.

4. How to report

Send your report by email to ethics@iberinbound.com. This mailbox is only accessed by the person in charge of the ethics channel.

You can also report by post, marked “Confidential – Ethics channel”, to: Iberinbound Travel SLU, C/ Enric Granados 91, Principal 1ª, 08008 Barcelona, Spain. If you wish, you can request a face-to-face meeting, which will take place within 7 days of your request.

Please describe the facts as precisely as possible: what happened, when, where, who was involved and any evidence you have. You may report anonymously, but giving a way to contact you helps us investigate.

5. What happens next

• We will acknowledge receipt within 7 days, unless this could compromise the confidentiality of the report.
• The person in charge will analyse the report and, if appropriate, open an investigation.
• We will inform you of the outcome within a maximum of 3 months from receipt, extendable by a further 3 months in complex cases.
• If the facts could constitute a criminal offence, they will be passed on to the Public Prosecutor.

6. Confidentiality and protection against retaliation

The identity of the person reporting, of the people concerned and of any third party mentioned will be kept confidential and will only be disclosed to the authorities when required by law.

Iberinbound prohibits any form of retaliation, including threats or attempts, against anyone who reports in good faith. Knowingly reporting false information is not protected and may lead to disciplinary or legal action.

People affected by a report have the right to be heard, to the presumption of innocence and to the protection of their identity.

7. External channels

You can also report directly to the competent authorities, including the Independent Authority for the Protection of Whistleblowers (Autoridad Independiente de Protección del Informante, A.A.I.) and, in Catalonia, the Anti-Fraud Office of Catalonia (Oficina Antifrau de Catalunya).

8. Personal data

Personal data received through the channel is processed by Iberinbound Travel SLU to manage and investigate reports, in compliance with a legal obligation (art. 6.1.c GDPR and Law 2/2023). It is accessed only by the people who need it for the investigation and is kept only as long as necessary: data is deleted after 3 months if no investigation is opened, and in any case within the limits set by Law 2/2023. You can exercise your data protection rights as described in our Privacy policy.