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Ethical Code

Travel Operator Groupement

Ethic of Work


Travel Operator Groupement (hereinafter also TOG or the Company) is a leading company that operates directly or through subsidiaries that own well-known and prestigious brands in the following sectors:

  • Tourist, as a Tour Operator specialized in organizing travel, holidays and related services
  • Air transport
  • Hotel
  • Travel agencies including retail
  • Accommodation and tourist services in general

Travel Operator Groupement aims to provide quality services in keeping with its tradition.

Travel Operator Groupement activity takes place in an international context that leads the company and its subsidiaries to operate in a multiplicity of institutional, economic, political, social and cultural contexts in continuous and rapid evolution.

Travel Operator Groupement aspires to maintain and develop the relationship of trust with its stakeholders, that is, with those categories of individuals, groups or institutions whose contribution is required to fulfil their mission.

Stakeholders are shareholders, collaborators (meaning by this definition the directors, managers and employees of the Company), customers, suppliers and business partners. In a wider sense, all those individual groups are stakeholders, as well as the organizations and institutions that represent them, whose interests are influenced by the direct and indirect effects of Travel Operator Groupement activity.

Therefore, in order for the activity to be carried out correctly, it is necessary for all its stakeholders to operate in the best way by making available to the Company its own cultural, technical, operational and ethical baggage.

Travel Operator Groupement therefore considered it appropriate to clearly define the set of values ​​that the Company recognizes, accepts and shares, as well as the set of rules and principles of behavior that are at the base of its activity.

This set of principles and rules is contained in this Code of Ethics which the Company expects the spontaneous sharing, acceptance and dissemination as well as the respect by all its stakeholders.


Description of the Code of Ethics

The Code defines the principles and models of conduct of the business of the Company as well as the commitments and responsibilities of the collaborators.

Travel Operator Groupement acts in full compliance with laws, transparency, fairness and professional commitment in order to develop its value for the benefit of shareholders and the professional growth of its human resources.

In this regard, the Code provides information regarding the solution of ethical and commercial problems. In particular, the conviction of acting in some way for the benefit of the company does not justify the adoption of behavior in contrast with these principles.

All actions, operations and transactions referable to the Company’s activity must be undertaken and pursued in full compliance with the law, impartiality and the principles of fair competition, must be managed with the utmost correctness, must be inspired by the completeness and transparency of information, must be supported by documentary evidence and must be subject to verification and control.

Relations with the Authorities must be based on maximum transparency and collaboration, in full compliance with their institutional functions.

The Code, together with all other regulations, policies and provisions issued by the Company, constitutes the program to ensure effective perception and detection of violations of laws.

Recipients of the Code of Ethics

The Code applies to all collaborators of the Company and to all other subjects or companies acting on its behalf, who are therefore committed to observing and enforcing the contents of this Code of Ethics in the context of their functions and responsibility, as well as during the performance of one’s professional activity.

The Company will ensure that the companies of the Group adopt the Codes of conduct whose principles are inspired, and in any case do not conflict in any way, with those of this Code.

The Company will have to take steps to ensure that the Code is considered a standard of best practices for conducting business by those individuals with whom it has long-term collaboration relationships, such as consultants and experts.

Method of consultation of the Code of Ethics

It will  be available on the Company’s website: http://www.travel-operator-groupement.com



In decisions affecting relations with its stakeholders Travel Operator Groupement avoids any discrimination based on age, sex, health status, race, nationality, political opinions and religious beliefs of its interlocutors.


As part of their professional activity, the Company’s collaborators are required to diligently comply with the laws in force, the Code of Ethics and internal regulations. In no case can the pursuit of Travel Operator Groupement interest justify their non-compliance.

Correctness in case of potential conflicts of interest

When conducting any activity, situations must be avoided where the parties involved in the transactions are, or may even only appear, in a conflict of interest. By this we mean both the case in which a collaborator pursues an interest different from the business mission and from the balancing of the interests of the stakeholders or takes advantage “personally” of business opportunities of the company, whether the case in which the customer representatives or suppliers, or public institutions, act contrary to the fiduciary duties linked to their position.

In this perspective, the employee and the collaborator are required to avoid any situation and to refrain from any activity that may oppose a personal interest to those of the Company or that may interfere and interfere with the ability to make impartial and objective decisions in the interest of the Company itself. Employees and collaborators must therefore exclude any possibility of overlapping or in any case crossing, by exploiting their functional position, economic activities that respond to a logic of personal and / or family interest and the duties they hold within the Company.

Any situation of conflict of interest, even indirect or potential, must be promptly reported to the relevant bodies (eg Supervisory Body, Legal Representative of the Company, etc.) so that the existence and severity of the situation can be assessed and the consequent effects.

Internal controls

It is Travel Operator Groupement policy to spread a culture of control at all levels, characterized by an awareness of the existence of internal controls and an awareness of the positive contribution they make to improving efficiency.

Internal controls means all the instruments necessary or useful for guiding, managing and verifying the Company’s activities with the aim of ensuring compliance with laws and company procedures, protecting company assets, efficiently managing activities and providing accounting data and accurate and complete financials.

The responsibility for implementing an effective internal control system is common to every level of the organizational structure; consequently all Travel Operator Groupement  employees, in the context of the functions performed, are responsible for the definition and correct functioning of the control system.

As part of their skills, managers are required to participate in the corporate control system and to involve their employees in it.

Transparency and completeness of information

Travel Operator Groupement employees are required to provide complete, transparent, understandable and accurate information, so that, in establishing relationships with the company, stakeholders are able to make autonomous and conscious decisions about the interests involved, the alternatives and the relevant consequences.

In particular, in the formulation of any contracts, Travel Operator Groupement takes care to specify to the contractor the behaviors to be taken in all the foreseen circumstances, in a clear and understandable way.

Duties of collaborators

Travel Operator Groupement expects its collaborators, in the performance of their duties, to behave ethically flawlessly, as well as legally and professionally correct, to strengthen mutual trust and consolidate the Company’s image.

Therefore, collaborators are requested:

  • To operate with probity and integrity in relations between them, with Group companies, with their shareholders, with competing companies, with customers and, in general, with third parties, be they public administrations or private individuals
  • To observe the legal provisions specific to each of the legal systems in which the Company operates
  • To avoid conflicts of interest with the company to which they belong and with the others of the Group and, in any case, behavior that determines negative publicity for them
  • To support the Company’s commitment to combating and deprecating every illegal form of tourism concession


Relations between employee

Relations between employees of the same Company or of different companies of the Group must always be based on the principles of civil coexistence and must be carried out with respect, reciprocally, for the rights and freedom of persons.

Hierarchical relationships within the company

The relationships between the levels of responsibility, connected to the different hierarchical positions existing in the Company, must be carried out with loyalty and correctness, respecting the professional secrecy.

All those responsible for specific activities and organizational structures must exercise the powers connected to the delegation received with prudent balance, respecting the dignity of the person of their collaborators. With regard to the methods of exercising the powers attributed, specific reference should be made to the specific company procedure.

All the members of the organizational structures or of specific work groups, in turn, must lend the maximum collaboration to the managers of one and of the others, observing the dispositions for the execution and for the discipline of the work imparted by them and, in general, by the Company.

Relations with authorities and public institutions and others subjects representing collective interests

All those who, for whatever reason, maintain relations with state, government and public institutions, including community and foreign authorities on behalf of Travel Operator Groupement, as well as with other subjects representing collective interests, and with the natural persons who represent them must operate constantly and strict compliance with the regulations in force in Italy and in the country in which the relationship takes place, basing its activity on fairness and transparency.

In particular, consistently with the principles of this Code, it is prohibited, in relations with the representatives of the Public Administration, directly or indirectly, to:

  • Promise or make cash payments, gifts or gratuities outside of the purposes or for purposes other than institutional and service purposes.

Donations of money, gifts and free services offered by third parties

In the performance of his duties, no collaborator, either directly or indirectly through members of his family, can request or accept money, other gifts and favorable services of any non-symbolic value from third parties who have business relationships or work with the Company.

“Non-symbolic” value means gifts, services, payments, etc., with a unit value not exceeding the value of Euro 300. In the case of gifts, services, payments, etc., with a unit value greater than Euro 300, the collaborator is required to immediately inform the Human Resources Department, with whom he will agree on the behavior to be kept.

In any case, the services and discounts obtained through the association of employees, pensioners and collaborators of Travel Operator Groupement Companies are excluded.

The provision of tourist services by suppliers is also excluded, according to the practices in use in the sector, provided they are previously reported to the Human Resources Department.

Accounting transparency

The completeness and clarity of accounting data, reports and financial statements represent a fundamental value in relations with shareholders, third parties and supervisory bodies.

In order for this value to be respected it is first of all necessary that the basic information and the accounting records of the transactions are complete, truthful, accurate and verifiable.

Therefore, each collaborator is required to take steps to ensure that the management facts are correctly and promptly represented in the accounting, keeping adequate supporting documentation for the activity performed for each operation.

The Statutory Auditors and the appointed auditing company have free access to the data, documentation and information useful for carrying out their activities.

Corporate communication

In order to avoid the dissemination of erroneous news and information or the occurrence of situations involving responsibilities of any nature and content for the Company, communication outside the Company must be clear, precise and truthful in order to promote awareness and consent to company policies and the Company’s programs and projects.

Particular attention must be paid to the external communication of documents, news and information concerning the events that occur in the sphere of direct activity of Travel Operator Groupement, not in the public domain.

The communication of information to the public, in particular, must be managed by the specifically appointed organizational structures (normally unit of the External Relations and Press organizational).

Relations with the mass media must be based on the respect of the same rules already outlined for relations with public institutions. In any case, relations with the press and the mass media must be based on protecting the image of the Company.

Confidential information

The information and confidential documents, the personal data of the collaborators and suppliers, the work projects, the know-how and the technological processes must be kept and adequately and continuously protected both with respect to third parties and with respect to colleagues who do not are directly affected. The subjects who, for work reasons, have access to them must, however, treat them according to the instructions and procedures established by the employer.

At any time and, in particular, on the occasion of the stipulation and execution of contracts, the duty of confidentiality must be strictly observed both in dealings with third parties, in relations with the press and in relations with subjects not authorized to communicate.

The employees and collaborators of the Company are committed to protecting privacy, both with reference to data pertaining to other employees of the Company itself, and with reference to data relating to customers, suppliers, consultants, any other contractor and all subjects who have business relations with them, in compliance with current legislation.

Travel Operator Groupement employees who are in possession of it are prohibited from using or communicating to others, without justified reason, privileged information concerning financial instruments, listed in Italy or abroad, issued by the parent company, by companies of the entire Group or by foreign companies to the Group itself.

Relations with political organizations, trade unions and welfare

Any form of any contribution, direct or indirect, to parties, movements, committees and political and trade union organizations, to their representatives and candidates, is prohibited, except those due according to specific provisions of the law and in respect of the forms, ways and of the contents contained therein, subject to approval by the Company’s Board of Directors.

Relations with customers and suppliers

The selection of suppliers and purchases of goods and services must take place in compliance with the principles of this Code and internal procedures, using the written form and in compliance with the organizational structure.

In any case, the selection must take place exclusively on the basis of objective parameters of quality, convenience, capacity and efficiency.

In business dealings with customers and suppliers, donations, benefits, services of any other kind, both direct and indirect, gifts, acts of courtesy and hospitality are prohibited, unless they are of a nature and value that does not compromise the image of the Company and that it cannot be interpreted as aimed at obtaining favorable treatment that is not determined by the market rules. 

Protection of the company’s assets

Every collaborator has the responsibility for the conservation and protection of the assets and instruments that are personally entrusted to him for the job and must contribute to guaranteeing the safeguard of the entire company assets. To this end he must pay the utmost respect to the operational and safety procedures established by the Company.

In any case, the documents relating to the activity of the Company, the work tools and any other property, physical or immaterial, owned by the same must be used exclusively for the realization of the Company’s institutional purposes and with the methods established by it. They may not be used by the collaborator for personal purposes nor transferred by him or made available, even temporarily, by third parties. Exceptions are possible “fringe benefits” (for example the company car for mixed use) of which the Personnel function of the Companies of the Group has authorized the use also for personal purposes, in compliance with the regulations in force.



The introduction of the administrative responsibility of legal persons represents one of the most significant reforms which, in implementation of the commitments undertaken at the community and international level, in fact, is part of the broad movement to combat international corruption that has imposed on the member states , the assumption of homogeneous means of repression and prevention of crime involving the economic sector.

The liability of legal persons is presented for various aspects of a distinctly penal nature, although the same has been expressly defined as “administrative”.

There is a hybrid responsibility: the peculiar characteristics of criminal and administrative responsibility coexist and the criminal procedural system is adopted for the purpose of its ascertainment and the consequent imposition of the sanction.

Travel Operator Groupement requires its employees to comply with the regulatory provisions in force in the state in which the activity takes place.

Crime in relations with the public administration

The Company expects its collaborators, in the performance of their duties, not to engage in unlawful conduct constituting crimes in relations with the Public Administration, namely:

  • Embezzlement to the detriment of the State
  • Undue receipt of disbursements to the detriment of the State
  • Extortion
  • Corruption due to an office act
  • Corruption due to an act contrary to official duties
  • Corruption in judicial proceedings
  • Incitement to corruption
  • Fraud against the State or other Public Authority
  • Aggravated fraud to obtain public funds
  • Cyber fraud to the detriment of the State or other public authority

Corporate crimes

The Company expects that its collaborators, in the performance of their duties, will not engage in unlawful conduct constituting corporate crimes under the civil code, namely:

  • False corporate communications
  • False corporate communications to the detriment of shareholders and creditors
  • False in the prospectus
  • False statements in the reports or communications of the auditing companies
  • Prevented control
  • Fictitious capital formation
  • Undue return of contributions
  • Illegal distribution of profits and reserves
  • Unlawful transactions on the shares or quotas of the company
  • Transactions prejudicial to creditors
  • Failure to disclose a conflict of interest
  • Undue distribution of corporate assets by liquidators
  • Unlawful influence on the meeting
  • Price Manipulation
  • Obstacle to the exercise of the functions of the public supervisory authorities

Crimes with the purpose of terrorism and subversion of the democratic order

The Company expects that its collaborators, in the performance of their duties, do not put in place acts or behaviors that can facilitate the commission of the crimes introduced by the New York Convention of 9/12/1999 for the repression of the financing of national terrorism and international.

Crimes against the individual personality

The Company expects its collaborators, in the performance of their duties, not to engage in unlawful conduct constituting the crimes against the individual personality envisaged by the Penal Code on measures against trafficking in persons and child pornography, namely:

  • Reduction or maintenance in slavery or in servitude
  • Child prostitution
  • Child pornography
  • Possession of pornographic material
  • Virtual pornography
  • Tourist initiatives aimed at exploiting child prostitution
  • Trafficking in persons
  • Purchase and sale of slaves

Financial crimes

The Company expects that its collaborators, in the performance of their duties, do not put in place acts or behaviors that may facilitate the commission of crimes on the crimes of abuse of privileged information and market manipulation.



The Company’s commitment is focused on achieving the highest standards of best practices with regard to its business, ethical and social responsibilities towards all its stakeholders. The Code defines the expectations of the Company towards its collaborators and the responsibility that these must take on to transform these policies into reality.

The management of the Company responsibly ensures that these policies and expectations are understood and put into practice by the collaborators. Management is held responsible to the competent internal control bodies and must finally provide assurance that the commitments expressed in the Code are implemented.

Any sanctioning measures for violations of the Code will be adopted in accordance with the laws in force and the related national labour contracts, and will be commensurate with the particular violation of the Code.

The measures may also include the termination of the fiduciary relationship between the Company and the collaborator, with the contractual and legal consequences with respect to the employment relationship envisaged by current regulations.

The following tasks are assigned to the Supervisory Body for the implementation of the provisions contained in the Code of Ethics:

  • Make decisions regarding violations of the Code of significant importance
  • Expressing binding opinions regarding the revision of the most relevant policies and procedures, in order to ensure their consistency with the Code of Ethics
  • Provide for the periodic review of the Code of Ethics

The Supervisory operates with impartiality, authority, continuity, professionalism, autonomy and suggests any updates to the Code also on the basis of reports received from stakeholders.

The Supervisory also operates with broad discretion and with the full support of the Company’s top management, with whom it collaborates in complete independence.


In order to guarantee the effectiveness of the Code of Conduct, the Company prepares information channels through which all those who become aware of any unlawful conduct within the Company can report, freely, directly and confidentially, to the Supervisory Body.

It is the duty of each employee and collaborator to report, without delay, any non-compliant behavior, including third parties, to the principles of the Code. The confidentiality of the identity of the informant is guaranteed, except for the requirements connected to the fulfilment of the duties of the Body, as well as the immunity of the person reporting from retaliation, unlawful conditioning, inconvenience and discrimination of any kind in the workplace, for having reported the violation of the contents of the Code of Conduct.

If an employee wishes to appeal against a violation (or alleged violation) of the Code, he must contact his direct superior.

If the dispute remains unresolved, or the employee feels uncomfortable in contacting his direct superior for the presentation of the appeal, he will report to the Supervisory Body.

If a third party wishes to appeal against a violation (or alleged violation) of the Code, it must contact the Supervisory Body.


With regard to employees

Failure to comply with and / or violation of the rules of conduct indicated in the Code by employees of the Company constitutes non-fulfilment of the obligations deriving from the employment relationship and gives rise to the application of disciplinary sanctions.

The applicable sanctions will be applied in compliance with the provisions of the law and the applied contract.

These penalties will be paid based on the relevance of the individual cases considered and will be proportionate to their seriousness.

The ascertainment of the aforementioned infringements, the management of disciplinary proceedings and the imposition of sanctions remain the responsibility of the appointed and delegated corporate functions.

This Code will be displayed in a public place accessible to all Company employees.

With regard to managers and administrators

In the event of violation by managers of the rules of conduct indicated in the Code of Conduct, the Company will assess the facts and behavior and take appropriate action against the persons responsible pursuant to the provisions of the law and applicable Contract, bearing in mind that such violations constitute non-fulfilment of the obligations deriving from the employment relationship.

In the event of violation of the Code by the directors of Travel Operator Groupement, the Supervisory will inform the entire Board of Directors which will take the appropriate initiatives pursuant to the law.

With regard to collaborators, consultants and other third parties

Any conduct put in place by collaborators, consultants or other third parties connected to Travel Operator Groupement by a non-employee contractual relationship in violation of the provisions of the Code of Conduct, may determine, in the most serious hypotheses, also the termination of the contractual relationship, without prejudice to any request for compensation if the conduct results in damage to the Company and this also independently of the termination of the contractual relationship.