Ethics Channel

TAXI TRAVEL TICKET, S.L.U. (hereinafter, TAXI TRAVEL or “the Company”) is a company that offers specialised transport services as its main activity. It has constituted a network of transport services providing companies and organisations the possibility of contracting transport services in any Spanish city, including the availability of adapted vehicles throughout the national territory. It also offers other activities such as reimbursement of expenses and travel agency services. The company’s customers are provided with personalised service and a superior level of assurance and quality. The company operates under the Healthcare Concierge by Bonotaxi® brand.

To this end, the company, the Sole Director, the Board of Directors, the Management, its executives, employees, representatives and external partners are committed to maintaining a culture of compliance, good governance and correct corporate management through the observance of principles of medical, commercial, accounting and personal ethics in the performance of their duties and responsibilities. This culture of corporate integrity, specifically established in the Code of Good Governance of TAXI TRAVEL TICKET, S.L.U., permeates not only the company’s internal sphere but also its activities and relationships with customers, suppliers, competitors, partners, public authorities, and the general public, in compliance with the laws and other applicable regulations.

TAXI TRAVEL has implemented a Quality Management System based on the international standard UNE EN-ISO 9001:2015.

TAXI TRAVEL has implemented various protocols which contribute to an efficient and quality management that is committed to regulatory compliance throughout the company’s various areas of operation. All these protocols provide for the communication of possible irregularities or complaints through the Ethics Channel regulated in this document, in order to channel and integrate these communications or complaints into a single mechanism.

By means of this “CORPORATE INTEGRITY POLICY AND ETHICS CHANNEL FOR COMMUNICATING POSSIBLE IRREGULARITIES” (hereinafter, the “ETHICS CHANNEL”) a mechanism is created to communicate, prevent and, if necessary, manage potential irregularities, either perceived or real, that may be detected in relation to the applicable regulations and the various internal protocols of regulatory compliance and compliance established by TAXI TRAVEL. The communication of any irregularity, whatever the regulation or internal protocol to which it refers, must comply with the provisions of this “ETHICS CHANNEL” (regardless of whether it is expressly set out or not). The purpose of this “ETHICS CHANNEL” is to remind TAXI TRAVEL members, suppliers, third parties, as well as any other external interlocutors to the company, regardless of their hierarchical level and their geographical or functional location, of the permanent expectation of ethical and legal compliance, the appropriate channelling for the communication of potential irregularities, and the description of the protections granted to the people who make such communications.

The ETHICS CHANNEL does not replace the internal channels of communication between the Company and its employees or partners, nor those that exist with suppliers and other third parties, therefore TAXI TRAVEL will encourage their use prior to that of the Ethics Channel for the resolution of any issues that may arise.

Irregularity is a broad term used throughout the “ETHICS CHANNEL”, and it describes, but is not limited to, the following:

Dishonest conduct: Non-compliance with “The Company’s” internal protocols, Code of Good Governance, codes of conduct, confidentiality commitments, personal data protection, protocols on occupational violence and prevention of harassment, sexual or gender-based harassment, compliance with administrative requirements and technical controls of equipment, accounting principles and any other internal due diligence procedures.

Illegal conduct and activities: Violation of applicable laws, rules and regulations, of the Criminal Code and special criminal laws, particularly offences that could be committed by taking advantage of or using the corporate framework of “The Company” as an instrument.

Attempted concealment or masking of any of the above.

4. A) “The Company’s” internal sphere: persons rendering services for “The Company” or on behalf of “The Company”, including its Director, representatives, executives, employees, sales agents, external partners and/or other related persons.
5. B) “The Company’s” external sphere: direct clients, recipients of services or external persons who are not members or employees of “The Company”.

4. 4. a). Channel for the “The Company’s” internal sphere: Potential Stakeholders of “The Company” (hereinafter “Reporting Party” or “Stakeholder”) are invited to exhaust the ordinary internal channels of hierarchical supervision within the organisation, before formalising a communication in accordance with this “ETHICS CHANNEL”. Supervisors shall in turn bring forward the information they may have received to the person responsible for THE “ETHICS CHANNEL” of The Company, so that appropriate action may be taken. In the event that the ordinary channels do not provide an adequate response or prove to be ineffective, any person in 4.A) is responsible for communicating, in accordance with the principles of good faith – as a well-founded suspicion of a possible irregularity – any irregularity detected, following the procedures established in this “ETHICS CHANNEL” mechanism. Communications related to the “ETHICS CHANNEL” must be submitted in writing, providing as much information as possible and, as a guideline, as follows:1.- Department of origin of the Reporting Party; 2.- Name, surname, and contact details of the Reporting Party; 3.- Date of the report; 4.- Was it previously reported (Yes / No)?   If yes, date on which the irregularity was first reported and to whom it was reported.

   5.- Irregularity status (planning phase, ongoing or completed).

   6.- Name of the persons allegedly involved and their position in “The Company”.

   7.- Nature of the incident (how is the irregularity carried out?).

   8.- Evidence and proof available, if any.

   9.- Date of discovery.

   10.- How was it discovered?

   11.- Estimated amount, if any.

   12.- Reported to external authorities (Yes / No). If yes, date of communication and status.

   13.- Other additional and relevant information.

   Issues related to equal employment opportunities and personnel policies of “The Company” are not covered by this “ETHICS CHANNEL” and are handled through internal channels established for such purposes.

   5.b). Channel for the external sphere of “The Company”:

   Any person of 4.B) who has a reasonable belief that persons within “The Company’s” internal sphere have engaged or plan to engage in illegal or unethical conduct related to “The Company” -or its human or material resources- may submit communications, claims or complaints, following the procedures set out in this “ETHICS CHANNEL” mechanism.

   Communications related to the “ETHICS CHANNEL” must be submitted in writing, providing the information set out in points 2 to 13 above (in the event of being a representative of a legal entity, the name of the Company and the position held in the same must also be disclosed).

   5.c). ANONYMOUS COMMUNICATIONS:

   Communications related to the “ETHICS CHANNEL” can also be made in writing in an anonymous manner. In this case, sufficient information and data must be provided in accordance with the above list. Vague or unspecific communications or generic allegations of misconduct cannot be taken into consideration. Anonymity shall be preserved to the extent provided for by law.

   5.d). RECIPIENT OF THE COMMUNICATIONS: All written communications relating to the “ETHICS CHANNEL” should be addressed using one of the following three channels:

    

   1) POSTAL MAIL:

   TAXI TRAVEL TICKET, S.L.U.

   Person responsible for the “ETHICS CHANNEL”

   C/ Plom, 5, 5º 1ª

   08038 Barcelona

   2) E-MAIL:

   canaletico@healthcareconcierge.es

   The content of the communications made to any of the indicated channels will be accessible solely and exclusively to the persons designated by the PERSON RESPONSIBLE for the ETHICS CHANNEL for their handling.

4. 4. 1.- CONFIDENTIALITY. “The Company” guarantees the confidential nature of the Report and the content of the process related to the handling of the communications received. However, with the approval of “The Company’s” Legal Advisor, certain details of the Report, including the results of the process, may be subject to disclosure, where appropriate, to the authorities when legally required or at their formal request. 6.2.- ABSTENTION FROM RETALIATION. No “Reporting Party” within “The Company’s” internal sphere who in good faith reports an alleged irregularity, either perceived or real, shall suffer retaliation for reporting the irregularity. Nor shall the participation of any member of “The Company’s” internal sphere in the process of handling the communication until its conclusion, or of those who may collaborate in the investigation or resolution, have any consequences whatsoever. However, the right of the “Reporting Party” and the members of “The Company’s” internal sphere to protection against possible internal retaliation does not include absolute immunity from any other type of possible personal liability (whether disciplinary within the company or criminal), which may arise from the “Reporting Party’s” own potential involvement in the irregularity that is reported, or from any other breach of “The Company’s” internal policies. However, the role of the “Reporting Party” or member of “The Company’s” internal sphere in providing information useful to the investigation should be taken into consideration in the final determination of any possible disciplinary sanction or action that may be taken. Any “Reporting Party” or member of “The Company’s” internal sphere who believes that he or she is being subjected to internal retaliation should immediately report this situation to the Person Responsible for the “ETHICS CHANNEL”. In the event that it is established that any person has retaliated in any way against a “Reporting Party” or member of “The Company’s” internal sphere who has reported an irregularity in good faith, he or she shall be subject to disciplinary liability proceedings. A “Reporting Party” or member of “The Company’s” internal sphere who reports an irregularity or makes available knowingly false evidence, or reports mere hearsay without further verification, or reports facts that are not reasonably true or reports them with manifest disregard for performing a minimum prior verification, will not be protected by this “Integrity Policy” and may be subject to disciplinary proceedings up to and including termination of employment.

   6.3.- RIGHT TO BE HEARD

   The procedure set out in point 7 of this document shall ensure the right to be heard of the “Reporting Party” and of the accused person or the person to whom the reported events refer.

4. 7.1.-The Person Responsible for the “ETHICS CHANNEL” will receive the communications and will provide the “Reporting Party” with acknowledgement of receipt of a communication relating to the “Integrity Policy” within a maximum period of seven (7) days from when the former becomes aware of its receipt.

   7.2.-The Person Responsible for the “ETHICS CHANNEL” will review and analyse the communication received as soon as possible and will assess, if necessary, with competent legal advice, whether it falls within the scope of this “Integrity Policy”. If this is not the case, or if the communication is not sufficiently well-founded, or if it is not clear and truthful, it shall proceed to file the case. Both in the case of admission of the communication and of it being filed, within a maximum period of one (1) month from the acknowledgement of receipt, or from the end of the period for acknowledging receipt without having verified it, the decision shall be communicated to the Concerned Party, stating in both cases the reason for the decision. In the event that the file is initiated, the Person Responsible for the “Ethics Channel” shall make available to the concerned/affected parties the content and processing rules of the Ethics Channel Procedure.

    

   This Corporate Integrity Policy and Ethics Channel for reporting possible irregularities was approved by the Board of Directors on 16 September 2022.