ECO TUK TUK, S.L., by decision of the Administrative Body, dated February 29, 2024, has adopted a Regulatory Compliance System or “Criminal Compliance” that complies with the requirements of Article 31 bis of the Criminal Code introduced by Organic Law 1/2015, of March 30, which amended Organic Law 10/1995, of November 23, of the Criminal Code, and came into force on July 1, 2015.
This framework also includes the Whistleblower Channel, in accordance with the requirements established in Law 2/23 of February 20, which regulates the protection of persons who report regulatory violations and the fight against corruption.
The Management Body has deemed it appropriate to incorporate into the Compliance system certain essential aspects of the SDG objectives in relation to governance, social responsibility, sustainability, etc., at ECO TUK TUK, S.L. (hereinafter, ECO TUK TUK or the Organization), as well as the various European standards on due diligence and sustainability.
In accordance with the above, the ECO TUK TUK Management Body has become aware of the need to adopt the regulatory content of the organization to the legal imperative determined by the latest regulatory and corporate standards, as well as to the ethical and moral principles from which they directly derive, as a result of ECO TUK TUK’s commitment to the principles of ethical and regulatory compliance and to the highest standards of safety and protection.
ECO TUK TUK’s Criminal Regulatory Compliance system, adopted by the Administrative Body, consists of the Compliance Policy Statement, as well as the Compliance Manual, Risk Report, and complementary policies and protocols.
- REGULATORY COMPLIANCE BODY.
The ECO TUK TUK Management Body has appointed a Regulatory Compliance Body responsible for monitoring the functioning and observance of the prevention and detection of possible crimes within the framework of the company’s activities, as well as supervising and monitoring the effectiveness of internal controls for the prevention of crimes and compliance with the ethical standards established in the company.
- DECLARATION OF COMPLIANCE POLICY
The regulatory compliance policy sets out the general principles that inspire its content and that apply to all ECO TUK TUK’s internal rules and regulations and affect its members, as well as the actions they carry out.
ECO TUK TUK declares and expresses its commitment to the highest levels of regulatory, ethical, and moral compliance, for which it is directly responsible. Therefore, compliance with and acceptance of the principles of objectivity, integrity, confidentiality, transparency, neutrality, responsibility, accountability, honesty, and anti-corruption agreements are considered an integral part of the organization’s guiding principles.
In accordance with the above, ECO TUK TUK declares its zero tolerance for illegal actions or, even without violating the law, actions that could be considered unethical, so that its activity, and that of its members, is perceived by all agents related to it as opposed to fraud and corruption in any of its forms, as well as any other regulatory breach or violation.
- GENERAL CODE OF CONDUCT OR CODE OF ETHICS
Internal code of the Organization that sets out the basic guidelines and general principles that must govern and be applied in the actions of ECO TUK TUK members. This Code has been designed to serve as the “cornerstone” of ECO TUK TUK’s compliance culture, which aims to guide the actions of all its members in the performance of their duties and in their commercial and/or professional relationships.
- COMMUNICATIONS CHANNEL OR ETHICAL CHANNEL
ECO TUK TUK has set up an Internal Information Channel (https://ecotuktuk.com/ethical-code/) as a key and ideal tool for supervision, control, and prevention in the area of ethical and regulatory compliance, with the aim of promoting a culture of transparency, ethics, and freedom from corruption, fraud, or administrative and/or criminal non-compliance, in accordance with the provisions of Law 2/2023 of February 20 on the “Protection of Whistleblowers.”
This channel provides a confidential and secure means for anyone associated with the organization to report any suspicious or illegal activity without fear of reprisals.
- ANTI-CORRUPTION POLICY AND CONFLICT OF INTEREST MANAGEMENT PROCEDURE
ECO TUK TUK is aware of the need to have, and to adopt as its own, an anti-fraud policy, in accordance with the provisions of international agreements, Article 31 bis of the Criminal Code, and Order HFP/1030/2021 of September 29, which establishes the management system for the Recovery, Transformation, and Resilience Plan, in accordance with the framework established in Regulation (EU) 2021/241 of the European Parliament and of the Council of February 12, 2021, establishing the Recovery and Resilience Facility.
- GENERAL CODE OF CONDUCT FOR THIRD PARTIES
The purpose of this Code is to ensure that ECO TUK TUK’s collaborators and/or suppliers conduct their business activities in accordance with ECO TUK TUK’s General Code of Conduct and applicable legislation, while also avoiding behavior that could be considered unethical.
- GOOD FISCAL PRACTICES POLICY
Policy establishing the principles and guidelines for action in tax, fiscal, and accounting matters that ECO TUK TUK members must take into account and apply in order to ensure compliance with applicable regulations.
- GENERAL POLICY ON RELATIONS AND CONTRACTING WITH CUSTOMERS, PARTNERS, AND/OR SUPPLIERS
The purpose of this policy is to establish guidelines or models of behavior complementary to the General Code of Conduct for ECO TUK TUK members when interacting and/or contracting with customers; collaborators and/or suppliers; public administration, public entities, authorities, civil servants, or public administrative personnel.
- PROCEDURE FOR ACTION IN THE EVENT OF ADMINISTRATIVE INSPECTION OR SUPERVISION
Document establishing the procedure to be followed by ECO TUK TUK members to ensure compliance with requests from inspection authorities, establishing a commitment to cooperate with said authorities and guaranteeing the protection of the legitimate interests of ECO TUK TUK and its members.
- CRIMINAL ACTION PROTOCOL
ECO TUK TUK has a procedure for action in the event that it becomes aware of the alleged commission of a crime within ECO TUK TUK or in response to communications or complaints received through the ethical channel implemented for reporting breaches and violations of internal regulations that could lead to criminal liability for the Organization.
- DISCIPLINARY SYSTEM
ECO TUK TUK has established and made known among its members a disciplinary system as a means of sanctioning actions that violate ECO TUK TUK’s internal procedures and regulations.
The sanctions have been determined taking into account the applicable Collective Agreements, as well as the provisions of the ET and/or specific applicable regulations.