Introduction
In accordance with UNE 19601:2025 and Article 31 bis of the Spanish Criminal Code, the Criminal Compliance Policy represents the organization’s strategic intent, as expressed by its governing body, regarding the prevention, detection, and response to criminal risks.
The Board of Directors of ATLANTIC FORWARDING SPAIN, S.L., aware of the criminal risks arising from its activity as an international freight forwarder and customs management -which is outsourced to a member of the governing body- adopts this policy as the basis of the Criminal Compliance Management System:
1. Purpose and scope
This Criminal Compliance Policy sets out the unequivocal commitment of ATLANTIC FORWARDING SPAIN, S.L. to comply with the Spanish Criminal Code and other applicable criminal regulations; to prevent offences within the framework of its activities involving international transport of goods by air, sea, and land; as well as within the outsourced customs clearance management; and to implement an effective model of organization, prevention, detection, and control in accordance with UNE 19601:2025.
This policy forms part of the Criminal Compliance Management System under UNE 19601:2025 and applies to all members of the organization, as well as to business partners that are relevant from a criminal-risk perspective, such as the customs representative Enrique Bonfils, a self-employed professional who provides services with his own organizational structure.
2. General principles
– Zero tolerance for the commission of offences within the organization or on its behalf.
– Active prevention of criminal risks associated with logistics, documentation, tax, and customs operations.
– Autonomy and independence of the criminal compliance body, with direct access to the governing body.
– Promotion of an ethical and legal compliance culture, both internally and among business partners.
– Promotion of the continual improvement of the criminal compliance management system.
3. Sensitive areas of criminal risk
The organization has identified the following activities as risk areas:
– International transport of goods.
– Customs management.
– International commercial relationships.
– Documentary and tax management.
– Accounting and invoicing.
4. Explicit prohibitions
It is strictly prohibited:
– The commission of offences in the name of, on behalf of, or for the direct or indirect benefit of the company.
– Using ATLANTIC FORWARDING SPAIN, S.L. as a means to conceal criminal activities.
– The existence of conflicts of interest that are not declared and managed, especially with third parties acting on behalf of the company.
– Any behaviour involving deception, corruption, documentary manipulation, concealment of information, or legal non-compliance.
5. Obligations and commitments
ATLANTIC FORWARDING SPAIN, S.L. undertakes to:
Apply due diligence criteria in the selection, contracting, and supervision of third parties performing sensitive functions.
Implement appropriate internal controls over customs documentation and relationships with public authorities.
Maintain a secure, accessible, confidential ethics/whistleblowing channel, protected against retaliation, with the possibility of anonymous reporting.
– Establish and periodically review measurable criminal compliance objectives.
– Train staff in the prevention of criminal risks.
– Cooperate with competent authorities in the event of investigations or legal requests.
– Document and safeguard this policy as documented information of the management system.
– Promote the continual improvement of the criminal compliance system.
6. Consequences of non-compliance
Non-compliance with this policy will result in:
– Internal disciplinary measures.
– Possible legal actions and/or termination of contractual relationships with third parties.
– Notification to the authorities where appropriate.
– Exclusion from tenders, bids, or projects where regulatory compliance is required.
7. Continual improvement and review
This policy will be reviewed at least once a year, or in the event of:
– Relevant regulatory changes.
– Changes to the structure or business model.
– Identification of new criminal risks.
8. Dissemination and accessibility
This policy will be:
– Approved and signed by the Board of Directors.
– Kept as documented information of the management system.
– Communicated to all members of the organisation in an understandable language.
– Shared with business partners with significant criminal exposure.
– Available to all interested parties in accordance with UNE 19601.
Approval
This Policy has been approved by the Board of Directors of ATLANTIC FORWARDING SPAIN, S.L., and shall be mandatory for all levels of the organization.
In Barcelona, on 1 January 2026
Miguel Torrontegui
Chief Executive Officer
MODIFICACIONES DESDE LA ÚLTIMA EDICIÓN
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