Ethic Regulations

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Our company Happy Touring Club, values and developed the present ethic guide . These values guide how we behave ourselves and communicate with one another, as well as with our clients, partners, suppliers, and other stakeholders.

We are committed to abiding by all applicable laws in the countries where we do business and to establishing an ethical corporate culture by upholding the highest standards of fair dealing, honesty, and integrity in our operations.

The Business Code of Conduct for the Happy Touring Club group can be found inside the site.

Our organization encourages individuals to report any suspected unethical, illegal, corrupt, fraudulent, or unwanted behaviour involving our company, and protects those who do so without fear of being victimized or retaliated against.

When should I file a report of ethical concern?

Anytime you see or suspect that you know of something that violates our values or ethical code and could have a serious impact on our organization, a person’s life, or their health.

We strongly advise you to contact one of our managers. If you don’t feel comfortable sharing your details, you can use our secure reporting portal instead.

You don’t need proof to believe what you’re thinking, but all signals must be sent in good faith.

Your communication will be treated with care and all messages will be handled with the strictest secrecy.

Policy for reporting ethical problems

Introduction

Values guide of Happy Touring Club help us to understand how we behave ourselves and communicate with one another, as well as with our clients, partners, suppliers, and other stakeholders.

The Happy Touring Club group is committed to abiding by all applicable laws in the countries where we do business and to fostering an ethical corporate culture by upholding the highest standards of fair dealing, honesty, and integrity in our operations.

Our Business Code of Conduct lays out our standards and expectations for our employees’ conduct and actions on behalf of the company and its clients. Our Code represents the values and ideals for conducting business, based on the UN Global Compact principles.

Purpose

The Happy Touring Club group encourages individuals to report any suspected unethical, illegal, corrupt, fraudulent, or unwanted behaviour involving our firm and protects those who raise a Concern (“Reporter”) from victimization or retaliation.

The Reporting Concerns policy was created to ensure that any concerns presented are handled efficiently, safely, and responsibly. Its purpose is to inform employees and outside parties on how to submit any legitimate concern or alert (“Concern”) about:

Legal infraction

Fraud

Corruption or bribery

Discrimination or harassment

Additional ethical issues

This policy, along with our Business Code of Conduct, is issued to all employees when they begin working with the Happy Touring Club group.

Please note that the techniques for reporting concerns outlined below are not to be used.

Confidentiality, anonymity, and non-retaliation

All Concerns reported will be treated confidentially following our HAPPY TOURING CLUB Group Privacy Statement. The Reporters’ identity will be protected, and the information provided will only be used as is necessary to investigate the Concern.

Happy Touring Club will not – nor knowingly permit any employee – to retaliate in any way (including any disciplinary action or dismissal) against anyone raising a good faith Concern.

If a Concern is made in good faith and then later unsubstantiated, the Reporter’s identity and the identity of the persons targeted by the Concern will remain protected.

When raising a Concern, you may do so anonymously.

Allegations of bad faith

Using the Concern processes to make malicious or false allegations or to unfairly target an employee on a regular basis will be deemed a violation of corporate values and will result in disciplinary action.

Reporting a Concern Procedure

Reporting possibilities Concerns may differ depending on local law. If they are of a higher standard than this Policy, all concerns may be submitted in accordance with this Policy and/or local legislation and/or local methods undertaken by our offices.

Reporting on the inside

Internally, the Happy Touring Club encourages employees to report concerns. Employees who see or feel they have information of a case of serious non-compliance with our company’s business code of conduct can report it to their line manager.

Reporting to the public

External parties’ concerns can be submitted by filling out the questionnaire on our secure online reporting portal. Happy Touring Clubgroup has access to our online reporting platform: https://report.whistleb.com/

All essential information to substantiate the Concern should be included in the Concern. The Reporter has the option of reporting anonymously or openly, and should make every effort to ensure that the material reported is accurate. Even after the first Concern has been raised, the Reporter can use the secure reporting portal to submit any further documents or information.

The Ethics Officer will look over the Concern to see what steps should be taken to examine and investigate it. If the Concern necessitates study, representatives from our Internal Audit, Human Resources, or Legal departments, as well as external specialists, will do it.

If the Concern is judged to be justified, the Ethics Officer, Managing Director, or Business Unit Management will take appropriate measures to address and correct the situation.

Depending on the seriousness of the Concern, the CEO of the Happy Touring Club group will be informed on a “need-to-know” basis.

When the Concern has been assessed, the Reporter will be contacted via the secure reporting portal, and any relevant investigations will be closed.

Unless required by law or when disclosure is required to regulatory authorities, law enforcement agencies, or professional advisors to the company, any information contained in the report will be kept confidential.

Within seven days, the Happy Touring Club organization will acknowledge receipt of a Concern.

The length of the investigation will be determined on the nature and content of the reported Concern. We will, however, provide the Reporter with feedback within three months.

Storage of personal data is subject to time constraints.

Any data pertaining to a Concern must be destroyed, archived, or preserved in line with applicable regulations. If no legal or disciplinary action is taken in response to the Concern, the data will be erased or archived within two months of the end of the verification process. If legal or disciplinary action is taken in response to the Concern, the data will be maintained until the legal or disciplinary action is completed, or archived.

Data security

This is a policy and procedure report.

February 2022