Criminal Compliance Policy

This Policy specifies the roles and responsibilities of all actors involved in the Criminal Compliance Model, from executives and directors to employees at all levels

Criminal Compliance Policy



This Criminal Compliance Policy has been prepared in line with the main regulatory references and best practices in compliance.

Eurodivisas is strongly committed to ensuring compliance with ethical principles and good governance, which is why our priorities include developing a solid corporate culture of compliance, in which the Company’s ethical values are established as central elements of our activity and decision-making.

This Policy specifies the roles and responsibilities of all actors involved in the Criminal Compliance Model, from executives and directors to employees at all level.



The Criminal Compliance Policy aims to establish a culture of compliance in accordance with Eurodivisas values and principles, so as to enable honest, full and transparent professional conduct, and to strongly condemn any type of act contrary to Eurodivisas principles and values of Eurodivisas, with no such acts being justified by benefits for the organisation.

Therefore, and in accordance with applicable legislation, we have established internal regulatory instruments and adequate control and management systems to detect and prevent regulatory risks and breaches.

This Policy is one of the main elements of the Eurodivisas Compliance System, which applies to all individuals subject to it, regardless of their geographical, hierarchical, functional location or the contractual modality that determines their relationship with the company.



Eurodivisas promotes respect for legality and ethical behaviour at all levels of the company, conveying this commitment and culture from the Board members and senior executives to all levels of the company, as well as to all its subsidiaries.

This Policy develops Eurodivisas’ general principles and guidelines on crime prevention and detection, demonstrating and strengthening its commitment to good corporate governance, an ethical business culture and compliance. The principles that should guide Eurodivisas as regards compliance are specified below:

• Acting and ensuring that others act at all times in accordance with current legislation.

• Disseminating the company’s commitment to strict compliance with the law, which establishes the values and principles that inspire Eurodivisas’ action. Therefore, both the Global Exchange Group and Eurodivisas’ actions are inspired by the Code of Ethics, the Anti-Corruption Policy and the Manual for the Prevention of Money Laundering and Terrorist Financing.

• Promoting a culture of compliance across the entire organisation and its components through the dissemination of and training in corporate ethical values, compliance and the declaration of the principle of zero tolerance towards any unlawful acts.

• Continuous assessment of the main sensitive activities that may be carried out in Eurodivisas.

The activities carried out by Eurodivisas are the following:

  – Purchase of foreign banknotes or traveller’s cheques, paying in euros.

  – Sale of foreign banknotes or traveller’s cheques for their equivalent in euros or other foreign banknotes.

  – All this is done physically in establishments open to the public or by online sale.

  – In addition, the company carries out retail trade activities in establishments that are open to the public for various products such as telephone cards, tickets to shows and tourist circuits, mobile internet devices, etc.

  – Return of VAT to foreign passengers as an agent for authorised entities.

• Promoting the implementation, supervision and continuous improvement of the policies, procedures and control mechanisms defined in the Eurodivisas Criminal Compliance Model.

• Raising awareness among all company members, through appropriate communication and training programmes, on the importance of fulfilling their duties and responsibilities in their activities.

• Making the principles and rules governing Eurodivisas’ action available to the entire company.

• Defining the functions of the governing bodies in relation to compliance, so that they foster compliance with the related internal guidelines and regulations.

• Determining the measures necessary to guarantee maximum integrity in the drafting and presentation of financial information, and proper compliance with current legislation and accounting regulations.

• Providing a regulatory and compliance framework with any third parties with whom we may maintain business relationships, to ensure full and honest practices within the framework of free competition.

• Establishing the measures necessary to comply with current personal data protection legislation and regulations, ensuring that the principles of privacy, quality and truthfulness in data processing are followed.

• Providing the measures required to prevent and, where applicable, report any conduct that may be associated with corruption and/or money laundering and terrorist financing, collaborating with official agencies.

• Providing a safe and healthy working environment in relation to promoting a health and safety culture at work.

• Making appropriate communication channels available to all company members, establishing a duty to inform and report in good faith any irregular conduct of which they are aware or which they may suspect. In any case, Eurodivisas guarantees the confidentiality and anonymity of reported parties and whistleblowers, and the absence of retaliation against whistleblowers in good faith.

• Disseminating among all staff the applicable disciplinary code, in accordance with employment regulations and applicable Collective Bargaining Agreements, in the event of a breach of the Compliance System, internal regulations and in the event of any acts or conduct that could be classified as potentially criminal.

• Periodically verifying this Policy and the Compliance Model implemented and modifying it when there are significant breaches of its provisions or when there are changes in current legislation within the Eurodivisas control structure or activity that makes it necessary.



Eurodivisas’ commitment to compliance and ethical values is integrated at all company levels, involving all individuals and making it known to them. This policy describes the organisational measures regarding compliance implemented in Eurodivisas, and defines the roles of the parties involved (4.1.ECC, Management Body and Employees) in the Criminal Compliance Model and their main duties and responsibilities.


The Eurodivisas Ethics and Compliance Committee (the “ECC”) is a collective body whose composition, functions and operating regime are established in its own Regulations. The ECC is responsible for monitoring, controlling and assessing the proper functioning of the Eurodivisas Compliance Model.

The ECC may request the support and collaboration of other areas or a third party, to whom it may entrust the performance of certain activities within the scope of its duties. To ensure the maximum effectiveness of its activities, the ECC will have free access to all Eurodivisas documentation that may be useful. In this regard, those responsible for any Eurodivisas area or department will be required to provide any information requested on the activities of the area or department related to a potential offence.

Finally, the ECC will have the human and technical resources necessary to carry out its function as efficiently as possible. It must also receive the training necessary to be fully qualified and up-to-date to carry out the activities specified in this document.


The Board, with the ongoing support of senior management, takes on a leadership role and a commitment, based on responsibility, transparency, integrity and observance, to strengthen and implement initiatives to strengthen the organisational culture of Eurodivisas.


Employees are responsible for understanding, observing and applying the Compliance Model values and principles established in this Policy, the Ethics Channel Regulations, the Anti-Corruption Policy and the Manual for the Prevention of Money Laundering and Terrorist Financing, as well as the rest of the policies existing in Eurodivisas.



The Eurodivisas Compliance Model has various measures aimed at preventing and detecting criminal risks, with this Model supervised on an annual basis or when circumstances arise that make it advisable to reduce this period, subject to a continuous improvement policy.


Prevention controls comprise all the company’s internal regulations and policies, both general (Disciplinary Code, Code of Ethics, training, etc.) and specific (controls designed and implemented to prevent specific criminal risks), which contribute to mitigating in advance the risk of bad practises or regulatory breaches in the performance of the activity.

The prevention of offences is a key element in the Eurodivisas Compliance Model, which is aware of the importance of implementing prevention measures to minimise exposure to risks and avoid their materialisation.


In addition to the prevention controls implemented in Eurodivisas, the Compliance Model includes controls designed for detection of breaches, anti-legal conduct or bad practises contrary to the Company’s policies, procedures or values after the event. In this context, Eurodivisas has general detection controls such as the Ethical Channel, through which all individuals bound by this Policy and third parties with a legitimate interest can report irregular practises.

The Ethical Channel is available to all members of the organisation and to Eurodivisas, S.A. Stakeholders, who can report breaches of this Criminal Compliance Policy and the other policies in the Compliance System through it.

The Ethical Channel can be accessed via the following URL:


The Eurodivisas Compliance Model is subject to ongoing supervision and improvement. An annual review is carried out in accordance with internal policies and procedures, and the Model is modified in the event of:

• Significant regulatory, legal or case law changes occur that affect the Model.

• Significant breaches of the Model provisions are found.

• Changes are made to the organisation, the control structure or the activity carried out by Eurodivisas.



This Policy is made available to all individuals bound by it.

All individuals bound by it are required to comply with the Criminal Compliance Policy from the time they join the company and during their employment.

Failure to comply with this Policy compromises the reputation and image of the company. All individuals bound by it are therefore required to notify the ECC of any conduct that breaches or could contravene it. Failure to comply with this Policy could entail the application of the Disciplinary Code, which may result in the termination of employment or other sanctions envisaged in the Workers Statute or in the applicable collective bargaining agreements, without prejudice to any administrative or criminal sanctions that may arise.


7.- TERM

This Policy has been approved by the Eurodivisas Management Body, is included in the company’s internal regulations, and will remain in force until its invalidation or amendment is approved. Any amendment to this Policy must be approved by the Eurodivisas Management Body.