1. INTRODUCTION
By means of this document, ATLANTIC FORWARDING SPAIN, S.L. declares its commitment to respect for legality, corporate integrity, and the prevention of criminal offences of any kind. This Criminal Compliance Code of Ethics and Conduct establishes the values, principles, and rules of conduct that must guide the behavior of all persons linked to the organization.
This Code forms part of the Criminal Compliance Management System (CCMS) implemented in accordance with UNE 19601:2025, and aims to promote a culture of compliance, detect risks, and prevent any conduct that may result in criminal liability for the legal entity under Article 31 bis of the Spanish Criminal Code.
2. SCOPE OF APPLICATION
This Code is mandatory for:
– Management and employees of ATLANTIC FORWARDING SPAIN, S.L.
– Collaborators such as agents, advisers, freight forwarders, correspondents, logistics operators.
– Third parties acting in the name, interest, or benefit of the company.
– Business partners and suppliers subject to contractual relationships or service provision.
Non-compliance with the Code may lead to internal, contractual, or even criminal sanctions, depending on the seriousness.
3. GUIDING PRINCIPLES OF CONDUCT
3.1 Legality
All members of the organization must strictly comply with applicable national and international laws, including criminal, tax, customs, labour, and environmental regulations.
3.2 Integrity
Engaging in corrupt practices, conflicts of interest, improper use of resources, or manipulation of information is prohibited. Transparency in decision-making is an essential value of ATLANTIC FORWARDING SPAIN, S.L.
3.3 Zero tolerance of offences
Under no circumstances will the commission of offences within the company be tolerated. The organization commits to acting against any detected or reported irregularity.
3.4 Respect and non-discrimination
The company guarantees a workplace free from harassment, discrimination, violence, or any form of degrading treatment.
3.5 Environmental and social responsibility
Commitments regarding the environment, sustainability, and human rights will be respected.
4. CRIMINAL COMPLIANCE POLICY
ATLANTIC FORWARDING SPAIN has adopted a proactive compliance and criminal prevention policy based on:
– Periodic identification and assessment of criminal risks.
– Implementation of effective internal controls.
– Ongoing training for staff.
– Oversight by the established Criminal Compliance Body, as well as an external collaborator contracted for this purpose.
– Review and improvement of the system.
The criminal compliance policy has been approved by the Board of Directors, which holds ultimate responsibility for its development and compliance.
5. PROHIBITED CONDUCT
5.1 Corruption and bribery
It is strictly prohibited to offer, promise, request, or accept bribes, hidden commissions, unauthorized gifts, or undue advantages. This includes relationships with authorities, collaborators, suppliers, and customers.
5.2 Document falsification and fraud
It is strictly prohibited to falsify, alter, or destroy commercial, accounting, or customs documents (such as DUA, BL, invoices, contracts, or certificates).
5.3 Money laundering
It is strictly prohibited to conceal the illicit origin of funds, participate in opaque financial structures, or carry out suspicious transactions not economically justified.
5.4 Tax offences and smuggling
Any action involving tax evasion, customs infringements, under-invoicing, over-invoicing, or irregular imports must be avoided.
5.5 Unauthorized access to and misuse of information
The misuse of personal data, trade secrets, or confidential information of employees, the company itself, or customers/suppliers is strictly prohibited.
6. RESPONSIBILITIES AND ROLES
6.1 Governing Body
Responsible for defining the criminal compliance strategy, approving policies, and providing resources to the system.
6.2 Criminal Compliance Body
Carries out supervision, advisory, training, monitoring, and investigation functions, and must act with independence, confidentiality, and rigour. At ATLANTIC FORWARDING SPAIN, S.L., the Board of Directors acts as the criminal compliance body, with functional independence and direct responsibility for:
– Identification and assessment of criminal risks.
– Supervision of the compliance system.
– Management of reports/complaints and corrective actions.
– Periodic review of the system.
– Promotion of compliance training and communication.
6.3 Senior Management
Must lead by ethical example, ensure the rules are respected, and take action against any breach.
6.4 Staff
Every employee must act in accordance with the Code, understand the risks in their area, and report any irregular or suspicious conduct.
7. IDENTIFIED RELEVANT OFFENCES
Given its logistics and customs activity, ATLANTIC FORWARDING SPAIN has identified the following as its main criminal risks:
– Money laundering
– Corruption in business
– Smuggling
– Bribery
– Offences against the Public Treasury and Social Security
– Fraud and scams
– Document forgery
– Terrorist financing
– Disclosure of secrets
– Environment and natural resources
– Offences against the market and consumers
– Corporate offences
– Influence peddling
These risks are included in the PCOM2 Criminal Risk Matrix, a document periodically updated by the Criminal Compliance Body.
8. ETHICS CHANNEL AND WHISTLEBLOWING MANAGEMENT
The company has a confidential and secure channel to report:
– Conduct contrary to this Code.
– Suspicions of offences or serious infringements.
– Breaches of internal policies.
– Channel safeguards:
● Anonymous reporting is accepted.
● Confidentiality and non-retaliation are guaranteed.
● Investigations will be impartial and documented.
● The channel complies with Law 2/2023 on the protection of whistleblowers.
As stated, ATLANTIC FORWARDING SPAIN, S.L. has a reporting channel with guarantees of confidentiality and absence of reprisals. Both identified and anonymous reports are accepted; for this purpose, a web form accessible from the corporate network is provided. Reports are received and managed directly by the Board of Directors, in its capacity as the criminal compliance body, which will assess, investigate, and resolve them impartially.
9. COMMITMENT TO STAKEHOLDERS
ATLANTIC FORWARDING SPAIN, S.L. recognizes that its activity has a direct impact on different stakeholders, with whom it maintains commercial, labour, and contractual relationships. Accordingly, it declares the following ethical commitments:
9.1 Public Administrations
We commit to acting with full respect for administrative, tax, customs, and public procurement legality, especially in our relationships with bodies such as the Tax Agency, Port Authorities, the Ministry of Transport, or any other national or international public entity. Any interaction with public officials will be carried out lawfully, and any kind of bribe, gift, or undue incentive is expressly prohibited.
9.2 Customers, freight forwarders, logistics operators, and other members of the international logistics chain
We commit to providing our logistics, customs, and international trade services with full transparency, quality, and diligence, strictly complying with contractual commitments, customs regulations, and the requirements to maintain the Authorised Economic Operator (AEO) authorization. Information provided to customers must be truthful, traceable, and supported by documentation.
9.3 Employees and collaborators
ATLANTIC FORWARDING guarantees an environment free from harassment, discrimination, or reprisals. Equal opportunities, occupational health protection, and work–life balance are fostered. Any inappropriate behavior or conduct that violates dignity will be investigated and sanctioned.
Training in ethics and criminal compliance will be actively promoted, especially in sensitive roles.
9.4 Suppliers and third parties
Suppliers are required to commit to ethical standards equivalent to those required internally. All contracting must be governed by principles of objectivity, transparency, and absence of conflicts of interest. It is prohibited to accept gifts, commissions, or favours from any supplier or third party.
9.5 Society and the environment
We commit to environmentally respectful management aligned with sustainability principles. We reject any practice that poses an ecological risk or socially irresponsible conduct.
9.6 SPECIFIC RULES OF CONDUCT
In addition to the prohibited conduct already established, the following individual rules of conduct apply to everyone in the organization:
– Use of company resources (vehicles, IT systems, phones, and documentation) must be strictly professional, avoiding private or negligent use.
– Participation in any decision or contracting where there is a personal, family, or economic conflict of interest is prohibited. Such conflicts must be declared in writing to the criminal compliance body.
– Gifts, courtesies, or invitations exceeding symbolic or socially acceptable value may not be accepted or offered (approximate value below €100).
– Absolute confidentiality must be maintained regarding sensitive information, especially operations, customers, prices, customs documentation, and internal processes.
– Public statements (including on social media) on behalf of the company are prohibited without express authorization.
– Consumption of alcohol or drugs during working hours or while representing the company is prohibited.
– Anyone who detects irregular conduct or conducts contrary to the Code must report it through the ethics channel.
10. INDIVIDUAL AND PROFESSIONAL RULES OF CONDUCT
The following specific rules apply to all staff, managers, collaborators, and third parties linked to ATLANTIC FORWARDING SPAIN, S.L., without prejudice to specific legal and contractual obligations.
10.1 Gifts, invitations, and business courtesies
Gifts, invitations, advantages, or favours that could compromise professional independence or create the appearance of influence may not be accepted. A symbolic value limit of €100 is established, provided it does not occur repeatedly or cumulatively over time.
Any courtesy exceeding this limit or repeated periodically must be reported to the criminal compliance body. It is strictly prohibited to accept gifts or gratuities from authorities or public officials, in strict compliance with the Criminal Code.
10.2 Representation expenses and travel
All expenses incurred for commercial representation or business travel must be justified, proportionate, and pre-authorized.
For meals, transport, events, or accommodation linked to customers or suppliers, criteria of reasonableness and good faith apply and may be subject to subsequent verification.
Invitations offered by third parties must be reported to the compliance body if they exceed the symbolic value threshold or if acceptance may create an appearance of dependency.
10.3 Use of social media and public statements
Public statements on behalf of the company are prohibited without express authorization. Sharing corporate information, images, customer data, or comments about operations via social media, forums, or public media is not permitted.
Use of the company’s logo, image, or name in external communications requires prior approval from Management.
10.4 Conflicts of interest
Employees and managers must avoid any situation where their personal, family, or economic interest conflicts with the legitimate interest of the company. They must refrain from participating in decisions affecting linked companies, close relatives, intimate friends, or entities in which they have an economic stake.
Any actual or potential conflict of interest must be communicated in writing to the criminal compliance body, which will assess its relevance and implement preventive measures where appropriate. Board members must annually sign a declaration of absence of conflicts of interest.
ATLANTIC FORWARDING SPAIN, S.L. acknowledges that personal or family ties may exist between individuals working in the organization. Such relationships are not prohibited but must be managed according to transparency, impartiality, and conflict-of-interest prevention principles. Therefore, anyone with a significant family or emotional tie with another member of the organization -especially in cases of direct kinship such as parents, children, siblings, or domestic partner- should voluntarily and confidentially declare it to the criminal compliance body or Human Resources.
This declaration does not in itself imply any irregularity, unless it may lead to influence, direct hierarchical reporting, or cross-access to sensitive information. In such cases, measures such as reassignment of functions, separation of roles, or abstention from critical processes will be applied. Failure to voluntarily communicate it, if it results in a risk situation, may be considered an ethical breach.
10.5 Use of corporate resources
Physical, digital, and financial company resources must be used exclusively for professional purposes. Unauthorized personal use of vehicles, IT equipment, software licenses, or corporate cards is prohibited.
Access to information systems and databases must be done using personal, non-transferable credentials, and use will be logged. Breaches may be sanctioned under the internal disciplinary regime.
10.6 Confidentiality and information protection
Anyone with access to confidential company information (operations, customers, tariffs, customs documents, projects, personal data) must maintain strict confidentiality even after the employment or contractual relationship ends.
It is strictly prohibited to disclose, reproduce, or use such information for personal purposes or for third parties. Using information to obtain commercial advantages, divert customers, or favour competitors is considered particularly serious.
10.7 Internal professional relationships
All members of the organization are expected to maintain respectful professional conduct based on collaboration, transparent communication, and respect for hierarchy.
Conduct involving harassment, humiliating treatment, verbal aggression, discrimination, or abuse of authority will not be tolerated.
ATLANTIC FORWARDING has specific protocols to act against harassment and confidential reporting channels.
10.8 Representation expenses and business travel
All trips, per diems, meals, or expenses from meetings or events must serve a justified professional purpose and, where applicable, have prior authorization from the relevant manager. Representation expenses (meals with customers, suppliers, or commercial delegations) must be proportionate, transparent, and properly documented with an invoice or receipt.
Expenses not linked to professional activity are prohibited, as are those involving excessive luxury, payments without documentary support, or unauthorized expenses. Any expense involving authorities or public officials must be assessed in advance by the criminal compliance body, in strict compliance with current criminal legislation.
The company may require reimbursement of improperly justified expenses, without prejudice to disciplinary proceedings where justified.
11. ANNEXES TO THE CRIMINAL COMPLIANCE SYSTEM
This Code of Ethics and Conduct is complemented by the following documents, which form an integral part of the Criminal Compliance Management System of ATLANTIC FORWARDING SPAIN, S.L. and will be signed, where applicable, by the obligated parties:
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- PCOM4-A01: Commitment to the Code of Ethics and Conduct
- PCOM4-A02: Annual declaration of absence of conflict of interest
- PCOM4-A03: Communication of acceptance of a gift or invitation
- PCOM4-A04: Individual declaration regarding representation expenses and travel
- PCOM4-A05: Declaration of training received in criminal compliance
These documents must be kept in the criminal compliance document system (CCMS) or in Human Resources records, as applicable, and will be available to competent authorities in the event of a legal request or external audit.
12. DATA PROTECTION AND INFORMATION SECURITY
ATLANTIC FORWARDING commits to protecting personal and corporate data under its responsibility, complying with the General Data Protection Regulation (GDPR), the LOPDGDD, and the guidelines of the Spanish Data Protection Agency. All data processing must be based on principles of lawfulness, minimization, limitation, and transparency. The company has physical and logical security protocols in both documentary and digital environments.
13. DISCIPLINARY REGIME AND SANCTIONS
Non-compliance with this Code may result in:
– Disciplinary sanctions under the applicable Collective Bargaining Agreement or the Workers’ Statute.
– Contract termination with third parties.
– Reporting to administrative or criminal authorities.
– Inclusion of the incident in criminal compliance reports.
14. REVIEW AND CONTINUAL IMPROVEMENT
This Code will be reviewed quarterly by the Criminal Compliance Body, in response to regulatory or structural changes, or after relevant incidents or external audits.
The review is part of the CCMS continual improvement process under Chapter 10 of UNE 19601:2025.
15. EFFECTIVE DATE, DISSEMINATION, AND ADHERENCE
This Code is approved by the Board of Directors and will be disseminated to all staff via corporate email, intranet, and mandatory training. Anyone joining the company must sign the adherence document, declaring that they have received, understood, and accepted the obligations of this Criminal Compliance Code of Ethics and Conduct.
16. DECLARATION OF COMMITMENT
All employees and managers must:
1. Declare that they have received, understood, and commit to complying with this Code.
2. Sign PCOM4-A01 Commitment to the ATLANTIC FORWARDING SPAIN Code of Ethics and Conduct, which will be filed in HR or in the compliance system.
CHANGES SINCE THE LAST EDITION
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