General

Across Europe is aware of its responsibility towards society to be a good corporate citizen. In order to achieve Corporate Responsibility, Across Europe cooperates with its employees, customers, partners, suppliers and locals at destinations. Across Europe wants to make sure that its local agents, suppliers and other business partners (herein referred to as ‘Partner’ or collectively as ‘Partners’) take action for more responsible tourism. This Partner  Code of Conduct forms an integral part of Across Europe’s contract with its Partners and provides guidance for ethical behavior and ethical core values.

Compliance with applicable law in general

Across Europe expects its Partners to comply with all applicable international, national and local laws and regulations, industry minimum standards and any other relevant statutory requirements whichever requirements are more strict.

Staff engagement

Staff are engaged with development and implementation of sustainability steps and receive periodic guidance and training.

Transport

Means of transport should comply with the local regulations. When selecting coach transport, the Partner should take into consideration minimum quality and safety requirements. The Partner is responsible for the training of drivers and a code of conduct with regards to driving. If available, The Partner will supply environmentally friendly transport. The Partner will make efforts to provide the latest models of transport, which exhale the least amount of CO2 and will try to renew them regularly.

Accommodation

The Partner will prefer the use of accommodations that are environmentally friendly and will choose to use sustainable accommodation, in case of equal possibilities. In case there is clear evidence that contracted accommodations jeopardize the provision or integrity of basic services such as food, water, energy, healthcare or soil to the local communities it can be a reason to terminate the co-operation with them. Accommodations that work with internationally acknowledged (e.g. GSTC recognized) and/or Travelife certification (taking into account price and comfort criteria) will be given preference. All Partner’s contracts with accommodation providers include standard sustainability clauses (e.g. child labour, anti-corruption and bribery, waste management and protection of biodiversity).

Entertainment/ excursions

Excursions and attractions in which captive wildlife is held are not offered, except for properly regulated activities in compliance with local, national and international law. Excursions which include interactions with wildlife comply with relevant codes of conduct. Disturbance of natural ecosystems is minimized. Excursions that operate on the basis of acknowledged and controlled sustainability standards are given preference if

available. The company offers no products or services of excursion providers that harm humans, animals, plants, natural resources (e.g. water/energy), or which are socially/culturally unacceptable.

Sexual exploitation of children and adolescents

The Partner does not tolerate or allow child prostitution at the premises and facilities of contracted accommodations.

Any suspicious behaviour from guests, employees, staff of the Partner or any other person on the Partners premises or during excursions must be reported to the local authorities by the Partner. Across Europe will terminate the contractual agreement prematurely if the Partner does not take adequate measures to prevent sexual exploitation of children within the direct supply chain (e.g. accommodations and excursions).

Human rights & labour conditions

Local partners comply with all relevant national laws protecting the rights of employees. Basic Rights:

The Partner shall not discriminate based on gender, age, religion, race, tribe, caste, social background, disability, nationality, membership in workers’ organizations, political affiliation, sexual orientation, or any other personal characteristics. All employees shall be free to enter their employment with the Partner through their own choice and shall also be free to terminate their employment when they choose without penalty, as long as the process occurs in accordance with the (oral or written) employment contract;

All forms of forced labour are forbidden; The freedom of association and the right to collective bargaining shall be recognized by the Partner; Workplace practice and conditions which violate basic rights are not allowed: Physical abuse or punishment or threat of physical abuse or punishment, any kind of sexual or other harassment and other forms of intimidation are prohibited; The Partner provides a means through which staff can make representation to senior management about key employment issues. The Partner provides for an effective complaints procedure through which employees may raise grievances (including those about harassment) and seek redress.

Occupational health, hygiene and safety are guaranteed in the workplace at least within the framework of national regulations with continuous development to improve the working environment.

Safe workplace

The Partner shall not employ children younger than 15 years of age unless local minimum age law stipulates a higher age for work or mandatory schooling, in which case the higher age shall apply. If however, local minimum age law is set at 14 years of age in accordance with developing country exceptions under ILO Convention No. 138, the lower will apply; If the Partner employs young people between the age of 14 and 18, the Partner must treat them with particular consideration, for example by restricting their working hours.

The Partner does not contract directly or indirectly accommodations which are involved in compulsory labor or which employ children to complete work which is normally undertaken by adults. There are special working times and conditions for children (< 14 years) working within the business, in accordance with the

UN Convention on the Rights of the Child and/or the ILO convention 138. The condition is mentioned in Partner’s contract with the accommodation.

Wages and working hours

Wages paid by the Partner must meet or exceed legal minimums and/or industry standards. No illegal or unauthorized deductions from wages are allowed; Working hours of the employees are to be kept in line with the legal requirements and / or industry standards; The employees shall be granted their stipulated annual leave and sick leave without any form of repercussions; Female employees shall be granted their stipulated maternity leave and other rights in case of pregnancy.

The Partner ensures that their employees can easily access relevant information on their employee rights and all relevant information for their employment. Employees have access to frequent trainings on health and safety.

Environment

Partners shall minimize their negative impact on the environment; The Partner shall actively reduce the amount of energy and water used and shall minimize the use of chemicals known to cause damage or pose risks to health and/or the environment; The Partner shall comply with mandatory national and international law, particularly in regard to the procedures and standards for waste management, handling and disposal of chemicals and other dangerous materials, emissions and effluent treatment; The Partner shall monitor and control wastewater and solid waste generated and shall treat it as required prior to discharge or disposal; Waste of all types shall be reduced to the greatest extent possible by the Partner.

The Partner shall take active measures to minimize the negative impact on and take precautions to protect biodiversity.

The Partner actively encourages stakeholders to reduce single plastic use along the value chain.

Environmental pollution, incl. CO2 shall be avoided and the environmental impact shall be kept at a minimum during all activities.

Local sourcing and benefiting communities

The Partner shall actively choose locally produced goods in preference to imported ones wherever possible.

The Partner shall promote local products and services to guests, by recommending guides, restaurants, markets and craft centres wherever possible.

Activities and services provided shall not jeopardize the provision and integrity of basic services such as food, water, energy, healthcare, etc. to the neighboring communities.

Customer experience

Customer satisfaction, including aspects of sustainability are permanently monitored.

Business Ethics

Across Europe expects the highest level of integrity in all business relations. Any form of corruption, bribery, extortion, fraud are strictly prohibited. The Partner shall give to Across Europe full disclosure to any

requested or relevant information regarding their business activities, financial situation and performance on Across Europe`s behalf, which may affect the performance of their contract with Across Europe, in accordance with applicable laws, regulations and industry practices.

Anti-bribery: Across Europe`s business is based on quality and competence and acts responsibly and ethically in business relations. No employee may accept or offer gifts such as money, loans, commissions or similar benefits in the form of money to or from third parties, regardless of the value of the gift.

Information security

Across Europe expects that the Partner takes appropriate measures to guarantee confidentiality, secure the know-how and protect the privacy of customers, clients and employees.

Monitoring & enforcement

As a principle, Across Europe trusts all its Partners to respect the terms and conditions of this Partners Code of Conduct and to actively do their utmost to achieve Across Europe standards.

The Partner shall ensure that the principles set forth herein are communicated, implemented and adopted within their own business. The Partner shall involve employees, management and other stakeholders such as the communities in an appropriate way; The Partner is encouraged to take steps to promote adherence to this Partner Code of Conduct throughout their own supply chain. However, the Partners sub-contractors are not bound by the terms of this Partner Code of Conduct.

When being prompted, the Partner shall report in a self-assessment modus about its compliance and progress in all matters mentioned herein, the Partner shall complete the self-assessment forms fully, promptly and accurately.

If the Partner is in breach of the terms and conditions of this Partner Code of Conduct (e.g. evidence of child labour, or an employee of the Partner acting as an intermediate for child prostitution, or disregard of ecological legislation) Across Europe shall be entitled to terminate any contract and cooperation with the Partner with immediate effect and reserves to take any further legal action at its discretion.

Last update: 31 October 2024