CODE OF ETHICS
Skål International

 

1. INTRODUCTION 

Founded in 1934, the International Association of Skål Clubs is the only professional organisation that promotes global tourism and friendship, uniting all sectors of the travel and tourism industry. Among other things, our objectives are to promote and assist the professional development of young people involved in the travel and tourism industry, or to foster friendship, mutual understanding, peace and solidarity among our members, thus furthering the development of the common interests of the communities in which they are represented and of a responsible tourism industry. 

We are a non-profit organisation, which has developed all our activities in compliance with the law, establishing the most ethical, responsible and transparent frameworks of action with our stakeholders. 

This Code of Ethics (hereinafter referred to as "the Code") contains the fundamental policies of our Association (hereinafter referred to as "Skål"), which are based on a commitment to the highest standards of integrity, ethical behavior, transparency, safety and corporate responsibility. Acting with integrity means that all our actions must be guided by responsibility, honesty, fairness and ethics. 

The purpose of this "Code of Ethics" document is to disseminate to employees, members of the Governing Bodies (Executive Board and General Assembly), individual members and Clubs, partners and other stakeholders, the principles, values and behaviors that should serve as a guide for the development of their activity within the framework of the Association's actions. 

This Code of Ethics is applicable to all persons subject to the provisions of the second point, so it is essential to read, understand and adhere to it.  

Both the specific provisions contained in this Code and the principles and values that underpin it are a Basic Pillar in the functioning of the Association and their strict compliance is considered an essential element of coexistence within the Association. 

The Skål Association verifies compliance with these principles through the Compliance Committee (Compliance Officers), one of its most important functions being to verify the dissemination, knowledge and compliance with this Code of Ethics and the other rules of Regulatory Compliance. Likewise, its fundamental function is to facilitate the prevention, detection and elimination of irregular and/or illegal conduct, thus contributing to maintaining and protecting the values and good name of the Association. 

2. SCOPE OF APPLICATION 

The purpose of this Code of Ethics is to establish the basic principles and rules of conduct to govern the Skål Association. 

This Code applies, from its entry into force, to the following persons, irrespective of their geographical or functional location (collectively referred to as "members"): 

- Members of the Executive Board 

- General Assembly (individual members and/or Clubs) 

- Employees 

- Partners 

- Suppliers 

- Other Stakeholders 

Members of the Association to whom other codes of ethics or codes of conduct of a sectoral nature or derived from the national legislation of the countries in which they carry out their activities are also applicable, undertake before Skål that they will also comply with them. 

In all those matters specific to the sector that have legal regulation and/or require additional detailed regulation, the rules of this Code of Ethics are complemented by those contained in the Association's internal regulations (Prevention of Money Laundering, Data Protection, etc.). 

The fact that a particular conduct is not contained in this Code does not prevent it from being considered contrary to the general principles of the Code and, consequently, it may be subject to the consideration of the Compliance Committee and the corresponding disciplinary actions. 

The Association shall have no relationship whatsoever with entities whose Code of Ethics is not, at least, respectful of the general ethical principles of the Association or which do not adhere to the same.  

3. OBLIGATION TO BE AWARE OF AND COMPLY WITH THE REGULATIONS 

All members forming part of Skål International are obliged to know and comply with the Code of Ethics and the approved regulations, as well as to collaborate in facilitating its implementation in the Association, including notifying the Compliance Committee of any breach of the same or of facts that could constitute a possible infringement of the same.  

This Code of Ethics will be available to all Skål employees and members of the Executive Board  in their private area of Microsoft Teams as well as on the website for all members and for the knowledge of third parties (partners, suppliers, stakeholders, etc.) on the Skål Association website as an essential part of the principles of good corporate governance and principles of transparency.  

For the communication of this Code and its acceptance, an e-mail will be sent to all employees and to the President of each Club (who will accept this Code on behalf of all the members of that Club) and to the Individual Members, so that they may also accept it. All recipients must accept the Code of Ethics through this form and their acceptances will be received and filed by the Compliance Committee. 

As a general rule, contracts with suppliers shall expressly mention this Code of Ethics. 

Any modifications, amendments or new ethical guidelines that may affect this Code of Ethics will be communicated to employees and members of the General Assembly in the same manner as indicated above, and the modification will subsequently be posted on the website in such a way that these modifications can be made known immediately.  

Any amendment to this Code shall be approved, upon proposal of the Compliance Committee, by the Executive Board. 

   

TITLE II. GENERAL ETHICAL PRINCIPLES OF THE ASSOCIATION  

4. MISSION, VISION AND VALUES  

A. MISSION 

Through our leadership, our professionalism and our concept of friendship, working together to achieve our Vision, maximise business networking opportunities and develop a responsible tourism industry. 

B. VISION 

To be a trusted voice in the tourism sector. 

C. VALUES 

- Integrity 

- Honesty 

- Loyalty 

- Transparency 

- Professionalism 

- Confidentiality and protection of information 

- Respect for all stakeholders and members of the Association  

- Prudence in pursuing the mission of the Association 

- The quest for equity 

- Crime prevention 

5. ETHICAL PRINCIPLES OF THE ASSOCIATION 

The ethical principles of the Association, good corporate governance, corporate social responsibility, and the professional ethics of all Members are the pillars on which all the activities of the Skål Association are based. 

The conduct of Members and, insofar as applicable to the persons referred to in the previous paragraph, shall be in accordance with the following basic principles:  

a) Respect for legality 

Our members must comply with applicable laws, regulations, and standards in their work. They must understand and follow policies, procedures, and guidelines related to safety and quality. Members must also report any violations or potential violations of laws or policies. 

Furthermore, members shall not knowingly engage in unlawful activity or in acts that are or may be detrimental to the reputation of the Association, while respecting and contributing to the legitimate and ethical objectives of the Organisation. 

Skål will provide members with an explanation of the regulations applicable in each case and, in order to clarify and resolve any doubts that may arise, Skål will make all its resources available to members. 

b) Ethics and professionalism 

The Association's employees shall strictly comply with applicable accounting, tax and labour regulations, avoiding risks of inefficiencies in decision-making. 

The Association is also particularly committed to fighting corruption and fraud. As a result, it will develop specific training plans related to these issues to raise awareness among its staff. 

We expect our members to conduct themselves in a professional manner at all times. This includes being respectful and courteous to colleagues, clients and all stakeholders. Members must act with integrity, honesty and transparency in all their dealings and communicate effectively and clearly. 

c) Regarding Human Rights 

All actions of Skål International Members shall respect the Human Rights and Civil Liberties included in the Universal Declaration of Human Rights, as well as the Global Code of Ethics for Tourism. 

6. STAFF OF THE ASSOCIATION 

Human Rights: Equality and Non-Discrimination, Dignity, Integrity and Privacy 

The Association has a policy of respect for human rights. In particular, it is against child labour and forced labour, and is committed to treating all people with dignity and respect, and not discriminating against them in any circumstances. 

The Association bases its remuneration policy, overtime policy, social benefits policy and holiday policy on the applicable legislation, without prejudice to any improvements it may wish to implement in order to improve the welfare of its employees and its competitive position as an employer brand. 

The Association does not allow or tolerate discrimination on the grounds of gender, race, colour, nationality, social origin, age, marital status, sexual orientation, ideology, political opinions, religion or any other personal, physical or social condition of its members, and promotes equal opportunities.  

It is a basic principle of action of the Association to provide equal opportunities in the processes of recruitment, selection and professional promotion, ensuring at all times the absence of discrimination on grounds of gender, race, colour, nationality, social origin, age, marital status, sexual orientation, ideology, political opinions, religion or any other personal, physical or social condition. 

In particular, it promotes equal treatment between men and women and rejects any manifestation of harassment, abuse of authority, violence or any other conduct that generates an intimidating or offensive working environment for the rights of its employees, whatever its form of expression. On this basis, the Association has approved a Protocol for the Prevention of Violence and Sexual and Gender-based Harassment in the workplace, through which any employee can report any situation of harassment that may arise to a specialised channel.  

All members of the Association undertake to maintain a working environment that respects personal dignity and freedom. Likewise, relations between members or employees of the Association and external companies or collaborators shall be based on professional respect and mutual collaboration.  

Reconciliation  

Skål encourages and promotes work-life balance for all our employees, recognising the need and importance of maintaining a balance between the two spheres for the benefit of the professional, the Association and the employee. 

In this sense, the Association is committed to the implementation of all measures that can achieve an effective work-life balance, such as implementing two days of teleworking per week. 

Health and Safety at Work - Prevention of Occupational Risks 

The Association's Occupational Health and Safety objectives are: i) the prevention of incidents as a guarantee of safeguarding the health and safety of employee and ii) to promote the safety and health of employees through the prevention of occupational hazards. 

In this way, the Association complies with the Health and Safety at Work regulations in accordance with the country's current regulations and all employees are aware of and comply with the occupational risk prevention regulations, ensuring compliance with the prevention measures adopted, for their health and safety in accordance with their training and instructions. 

Thus, employees are obliged to: (i) contribute to the fulfilment of the obligations established to protect the safety and health of professionals at work and (ii) cooperate with the Association so that it can ensure safe working conditions that do not pose risks to the safety and health of employees.  

Training 

We plan training for our employees, providing equal opportunities and career development that will contribute to the achievement of the Association's objectives. 

On this basis, training courses are carried out through FUNDAE funds. Additional courses can also be carried out outside this budget and are paid for by the Association. 

All employees have a duty to actively participate in the training plans made available to them, to be involved in their own development and to commit themselves to keeping up to date with the knowledge and skills necessary to add value, to maintain excellent performance and to further their professional development. 

Resources and means for the development of the activity 

The Skål Association undertakes to make available to the employees the necessary and appropriate resources and means for the development of the activity. 

The employees of the Association undertake to make responsible use of the resources and means made available to them, using them exclusively for activities in the interests of the Association, so that these resources and means shall not be used or applied for private purposes.  

The use of the equipment, systems and software that the Association makes available to employees for the performance of their work, including the facility to access and operate on the Internet, must be in accordance with criteria of security and efficiency, excluding any use, action or computer function that is unlawful or contrary to the rules or instructions given. In other words, it is not permitted to use the equipment to use computer programmes or applications whose use is illegal, which may damage the image of the Association or its reputation, or to access, download or distribute illegal or offensive content. 

Social Networks, Blogs and other Media 

Skål International recognises the importance of responsible use of social media and digital platforms. Members are prohibited from sharing content that is inappropriate, offensive, discriminatory, defamatory or otherwise harmful to the reputation and integrity of the association, its members, employees or third parties. Misuse of these platforms may result in disciplinary action. 

Confidentiality with regard to employee and General Assembly members' data 

Skål International undertakes to request and use only such personal data of employees as is necessary or required by applicable law.  

In addition, the data of the members of the General Assembly of Skål International to which other members have access through the database of the Association's platform will be processed in a lawful, fair, transparent manner and solely for the purposes corresponding to the corporate purpose set out in the Articles of Association of the Association.  

In this way, the necessary measures shall be taken, in accordance with the provisions of the legislation in force at any given time, to preserve the confidentiality of the personal data held and to ensure that the processing thereof, when necessary for duly justified reasons, is carried out. 

Employees who, in the course of their work, have access to information of other employees shall respect and promote the confidentiality of this information and use it in a responsible and professional manner.  

Information to which they may have access must be protected from disclosure to third parties. Even when handled internally and before it is transferred within the Association, confidential information must be made available only to those employees who need it for the performance of their official duties, nor may it be used outside the exercise of their functions. 

TITLE III. GENERAL ETHICAL PRINCIPLES OF CONDUCT 

7. CONFLICT OF INTEREST 

A conflict of interest arises when the personal interests of employees and members of the General Assembly who make p the Association, directly or indirectly, are contrary to the interests of Skål International, interfere with the discharge of their professional duties and responsibilities or involve them personally in any Skål International’s transaction or business operation. 

Members must be committed to acting with integrity and good faith in activities related to the Association's business. To this end, it is essential that members do not engage in activities that give rise to a conflict of interest or could be construed as such. In this regard, they shall always act in such a way that their private interests, those of their family members or other persons related to them do not override those of the Association, in line with the Policy on Preventing Corruption in Business, which includes policies on managing conflicts of interest. 

This standard of conduct shall apply both to the relations of those subject to this Code with the Association, as well as in their relations with suppliers or any other third party having a relationship with the Association.  

In this respect, the general guidelines for conduct set out in the Policy on the Prevention of Corruption in Business must be followed without exception. 

8. GIFT AND INVITATION POLICY 

Skål employees base their relationship with all external personnel on the principles of loyalty, professionalism and transparency and act to prevent fraudulent or corrupt behavior. 

Employees may not accept or give gifts or invitations in the course of their work, except in the case of courtesy or customary business courtesies, or in the case of invitations that are considered ordinary or customary in accordance with social customs. In any case, gifts or invitations that are prohibited by the applicable regulations or that may condition professionalism or independence or influence professional decision-making shall not be acceptable.  

They may not, directly or through an intermediary, offer or grant, or solicit or accept, any unjustified advantages or benefits for the immediate or indirect purpose of obtaining a benefit, present or future, for the Association, for themselves or for a third party. In particular, they may not give or receive any form of bribe or kickback from any other party involved, such as public officials, staff of other companies, political parties, authorities, customers, suppliers and providers. Acts of bribery, which are expressly prohibited, include the direct or indirect offer or promise of any kind of improper advantage. 

In this regard, employees must follow the provisions of the Business Corruption Prevention Policy, which includes policies on accepting and giving gifts. 

9. INTELLECTUAL AND INDUSTRIAL PROPERTY 

Skål International owns the ownership and the rights to use and exploit the software, computer systems, hardware and trademarks. 

All persons associated with Skål must respect and preserve the intellectual and industrial property rights of the Association and third parties. No material protected by intellectual and industrial property rights may be copied, disclosed, distributed, uploaded, downloaded or hosted without the appropriate authorisations. If there is any doubt about the availability of a particular item protected by intellectual or industrial property rights, the Compliance Committee must be consulted. 

10. INSPECTION ACTIVITIES 

Relations with the authorities, regulators or supervisory bodies shall be conducted in accordance with the principles of transparency and cooperation, always facilitating any type of inspection that they may carry out on the Association.  

All employees have the obligation to collaborate with those departments that coordinate relations with the different supervisors, responding efficiently and diligently to requests for information required by those departments.  

11. MONEY LAUNDERING AND TERRORIST FINANCING 

Skål International has internal control policies and procedures in place to prevent and avoid money laundering operations originating from criminal or illicit activities or which could be used for the financing of terrorism, among others. The Persons Subject must pay special attention to those cases in which there are indications of lack of integrity of persons or entities with whom they do business, immediately reporting any incident in this regard through the Whistleblowing Channel (Internal Information System) set up for this purpose. 

12. FINANCIAL TRANSPARENCY AND PUBLIC RESOURCE MANAGEMENT  

The Association is committed to complying with its tax obligations in all territories and jurisdictions in which it operates, always opting for a prudent tax policy.  

Consequently, employees and members of the General Assembly shall avoid, in addition to any conduct aimed at defrauding the tax authorities, the Social Security or any other public body, obtaining any type of advantage, tax or social benefits or subsidy by fraudulent means.  

13. SUSTAINABLE DEVELOPMENT 

All members and employees are actively and responsibly committed to the conservation of the environment, respecting legal requirements and carrying out their activities in a way that minimises environmental impacts and considering the sustainable urban balance. It also undertakes to implement social and good governance policies to promote further progress in this field and to contribute to improving the sustainability objectives set out in the Association's protocols, following the recommendations and procedures that may be established.  

In this way, all members and employees commit themselves actively and responsibly to comply with and support the principles of the Global Compact. 

14. PROFESSIONAL RELATIONS 

Employees 

The conduct of the Association's employees shall conform to the principles of professionalism and integrity, as well as compliance with this Code of Ethics and the ethical values detailed in point four of this document, and any other texts that may be complementary to it. 

Professional behavior is understood as all diligent, responsible, efficient conduct, focused on quality, excellence and innovation, within its field of competence. 

Likewise, conduct of integrity is understood as acting honestly, loyally, in good faith and in line with the interests and values of the Association. 

Relations with members of Skål International (Skålleagues) 

Employees and members of the Governing Bodies of the Skål Association must act with integrity towards the members of the Association with the objectives of achieving the highest standards of quality, excellence in service delivery and the long term development of relationships based on trust, ethics and mutual respect. 

The relationship to be established with them must be based on truthfulness, transparency and commitment to confidentiality in the use and transmission of information, both professional and personal. 

Suppliers  

Supplier selection processes are carried out with transparency and objectivity, avoiding situations that could affect the impartiality or objectivity of the people who participate in them. To this end, those professionals directly involved in decisions on the contracting of supplies, services or the setting of economic conditions thereof, shall avoid any type of interference that could affect their impartiality or objectivity in this respect.  

Similarly, wherever possible, situations of exclusivity with one supplier should be avoided and relationships should be governed by the principles of integrity, professionalism and transparency.  

Respect for the Association's ethical principles shall, as far as possible, be extended to suppliers or any other person or entity doing business with the Association. In this sense, the Association shall not have relations with entities whose Code of Ethics is not, at least, respectful of the Association's general ethical principles or which do not adhere to the same.  

Public administrations 

Relations with public administrations shall be governed by the principles of legality, collaboration, transparency, professionalism and good faith. 

Skål International will abide by the administrative or judicial decisions made in each case and will retain the right to appeal in the event that it is considered that these decisions are not in accordance with the law. 

TITLE IV: PROTECTION OF PERSONAL DATA 

15. CONFIDENTIAL INFORMATION 

Transparency of information and privacy policy 

Skål International believes that the collection and good use of information is a competitive advantage and that its administration and handling must be responsible, secure, objective and in accordance with current legislation. 

During our operations, we generate proprietary or confidential, technical or commercial information that is valuable and whose disclosure could harm our interests, those of our members and suppliers. Our Association is committed to regulating in a clear and reasonable manner the identification, handling and protection of our proprietary, confidential or secret information.  

We also, in the course of our business, generate confidential information from our General Assembly members to which other members of the General Assembly itself have access in order to carry out the purpose or object of the Association. 

The recipients of the Code of Ethics should be aware of and comply with the provisions of this System. 

Information processing  

The information handled by members must be treated and reflected in an accurate, truthful and clear manner.  

Furthermore, they must preserve knowledge, facilitating its dissemination to other members with due transparency when required, and making it available to the knowledge management systems that are set up for this purpose, to facilitate the management of activities and enhance the development of people. 

Handling of Confidential Information (including information of other members of the General Assembly) 

Members have an obligation to protect the information and knowledge generated within the Association, whether by ownership or by a duty of custody of such information. 

The data of members of the General Assembly of the Skål Association to which other members have access will be processed in a lawful, fair and transparent manner and solely for the purposes corresponding to the corporate purpose set out in the Articles of Association of the Association.  

Members shall refrain from using any data, information or documents obtained for their own benefit. Nor shall they communicate information to third parties, except in compliance with applicable regulations, internal rules or when expressly authorised to do so. Likewise, they shall not use confidential data, information or documents from a third company without their written authorisation.  

They also undertake to maintain confidentiality and to use any data, information or documents obtained in the course of their duties in accordance with the relevant internal regulations. 

The obligation of confidentiality shall survive the termination of the activity or membership of the General Assembly and shall include the obligation to destroy any material relating to the Association in the possession of the member concerned at the time of termination of his or her relationship with Skål. 

Protection of personal data 

We ensure that the personal and family privacy of all persons, whether employees or others, to whose data we have access is respected. Authorisations to use data must be in response to specific and justified requests. Employees and members of the General Assembly must strictly comply with the internal and external rules established to ensure the proper handling of information and data provided to the Association by third parties.  

In the collection of personal data from employees, suppliers or any person or entity with whom a contractual or other relationship exists, all staff must obtain the required consents and authorisations, and undertake to use the data in accordance with the purpose authorised by the consenting party.  

Furthermore, all internal procedures implemented with respect to the storage, custody and access to data and which are intended to ensure the different levels of security required according to the nature of the data must be known and respected.  

Employees shall report to their superior any incident they detect relating to the confidentiality of information or the protection of personal data. 

TITLE V: IMPLEMENTATION AND MONITORING OF COMPLIANCE WITH THE CODE OF ETHICS 

Supervision and respect for the guidelines, principles and values set out in the Code of Ethics is the responsibility of all members of the Association, who are obliged to promote compliance and contribute to the maintenance of a culture of compliance, as set out in the corresponding Protocol. Without prejudice to the foregoing, the enforcement of the Code of Ethics and, in general, of compliance policies is the responsibility of the Compliance Committee. To this end, it shall be governed by the principles described in the following section. 

16. REPORTING INFRINGEMENTS 

In the event of violations or irregularities with respect to: (i) breaches of this Code; (ii) breaches of other internal regulations; (iii) other allegedly criminal acts (such as bribery in the public and private sphere, use of confidential information, fraud, etc.) and (iv) breaches of regulations and/or internal procedures regarding the prevention of money laundering and the financing of terrorism, they must be reported to the Compliance Committee immediately through the Internal Reporting System (Whistleblower Channel). 

However, all information related to the management of complaints will be considered confidential information and will be managed by the Compliance Committee, as indicated in Law 2/2023, of 20 February, regulating the protection of persons who report regulatory infringements and the fight against corruption. 

To this end, Employees and persons related to the Association, as set out in the management procedure of the Internal Information System (Whistleblowing Channel) may contact the Compliance Committee, through the Internal Information System, to report what they consider to be a breach. 

17. DISCIPLINARY REGIME 

If a breach of the Code of Ethics or of any other internal or external regulation by any person linked to the Association is detected, the conduct must be investigated and the possibility of taking appropriate measures to (i) sanction the behavior, (ii) prevent its repetition and (iii) repair the damage caused must be assessed. 

When such an infringement occurs, refer to Article IX of the Internal Regulations to verify which body sanctions it and what the procedure is. 

However, if the facts are of legal-criminal importance, the necessary measures shall be taken to ensure that, as soon as possible, the facts are brought to the attention of the Administration of Justice. 

Likewise, for the adoption of the above decisions, the Association may seek such internal or external legal advice as it deems necessary. 

In any case, the rights to: (i) presumption of innocence, (ii) be informed of the charges against him/her and (iii) an adequate defense must be respected. 

Thus, if one of these situations occurs, it will be up to the Executive Board, after receiving advice and following the appropriate procedure, whether to sanction the employee or member of the General Assembly or even to dismiss/expel him/her if the event is of particular importance. 

18. APPROVAL, DISSEMINATION AND MODIFICATION  

This Code of Ethics has been approved by the Executive Board of Skål International 

This Code of Ethics, of obligatory compliance, has been communicated to all employees of the association and to the members of the General Assembly (Clubs - Club President - and individual members) by email, who have received it and signed the attached form as a sign of conformity with it. In case of a new incorporation to Skal International, either as an employee or as a member of the General Assembly, a copy of the Code of Ethics will be provided with the respective form for their conformity. And, subsequently, for third parties, via the website https://www.Skål.org. 

All current and future employees and members of the Association accept the values, principles, standards and guidelines for conduct set out in this Code. No one, regardless of position, may ask a member of the Association to contravene the provisions of this Code of Ethics. If a member receives an order from a superior contrary to the Code of Ethics, he/she must report it to the Compliance Committee. 

This declaration of principles will be updated periodically, adopting all those proposals that are likely to be incorporated into this document. 

The amendment of this Code of Ethics shall be the responsibility of the Compliance Committee with the approval of the Executive Board.