The objective of this Code of Ethics is to define the fundamental values and principles that should guide the integrity and professional behavior of all people who are part of Mundo Campeador, SL (hereinafter, "Mundo Campeador" or the "Company").
Similarly, this Code applies to all companies linked to Mundo Campeador, as well as to all their employees, regardless of their position within the respective companies.
Therefore, the provisions contained in this document apply to all professionals providing services to companies affiliated with Mundo Campeador. These companies are:
• Boscum World 10, SL
• Gracium World 10, SL
• Hospium 10, SL
• Teacampa Reservas, SL
• Bajoaragonesa Gestión, SL
• Locatium World 10, SL
• Expitchuring, SL
• Newtown Capital, SL
• Camping Ampolla Arenal, SL
• El Portús Nautical Complex, SA
• Buenaventure 2000, SL
• Aquiana 2000, SL
• Rodas Altas, SLU
• Springer Capital, SL
In accordance with the scope indicated, all references contained in this Code to Mundo Campeador or the Company extend to all dependent companies.
In carrying out its activities, the Company has undertaken the commitment to respect constitutional rights and principles, as well as the applicable regulations within the specific framework of the sector and the broader general regulations, in order to establish a culture of respect for the Law.
SCOPE OF APPLICATION:
At Mundo Campeador, respect for and compliance with current laws are fundamental to building a sustainable business that inspires maximum confidence among its stakeholders, including employees, managers, investors, and customers.
All employees of Mundo Campeador have made a commitment to act with integrity and in accordance with applicable regulations.
This commitment seeks to foster a culture of integrity and sustainability in the development of the Company's strategic objectives, in accordance with applicable national and international regulations, and in line with the guidelines established by the Global Code of Ethics for Tourism.
The guidelines of this Code extend to third parties with whom Mundo Campeador interacts, including suppliers, service providers, contractors and clients linked to the company.
MISSION:
Mundo Campeador's mission is to develop the activity of managing campsites, offering a quality service to customers within the broad national tourism sector within the framework of legality, in accordance with the motto that as an organization it has the ability to add value to people's lives, beyond the services it markets.
In accordance with this objective, the Company improves "people's lives through unique experiences that disconnect them from the well-being of nature."
VALUES:
Mundo Campeador has assumed the responsibility of fulfilling a series of essential values that guide the Company:
COMMITMENT: Mundo Campeador has firmly committed to safeguarding the interests of its clients, employees, and third parties related to the company at all times, as well as caring for and respecting the environment and communities in which it operates.
HONESTY: The Company honestly fulfills the promises it makes regarding the services it offers to customers.
QUALITY: Mundo Campeador stands out for providing quality service to its customers, always attentive to detecting and satisfying their expectations, as well as offering them unique experiences in each of the locations, emphasizing our commitment to environmental sustainability.
PROFESSIONALISM AND PERSONALITY: Mundo Campeador's staff perform their duties professionally while offering a friendly and welcoming service to guests. Ultimately, Mundo Campeador promotes a strong business ethic in its operations, fostering a work environment that promotes equality and respect for everyone's rights.
BEGINNING:
Mundo Campeador has established a series of essential principles that are generally applicable to the way work is performed in the Company, as well as to decision-making of all kinds:
REGULATORY COMPLIANCE: The entity and all employees are committed to complying with current legislation in a sustainable manner in all areas of their activity.
RESPECT AND DIGNITY OF PEOPLE: The Company promotes mutual respect, equality and non-discrimination, without distinction based on nationality, sex, race, religion, language or any other condition.
SAFETY: Mundo Campeador ensures safety in the development of its activity, in order to strengthen risk prevention and control of all aspects that may affect people's health.
RESPONSIBILITY: The development of work within the framework of the Company is carried out by all workers with diligence and assuming responsibility for the decisions adopted.
PROFESSIONAL DEVELOPMENT: At Mundo Campeador, it is a priority that employees can develop their professional career effectively and obtain professional training that allows them to work as a team in each of the establishments, offering quality services.
CONTRIBUTION TO RESPECT FOR FUNDAMENTAL RIGHTS:
In its commitment to ethics and regulatory compliance, Mundo Campeador strictly adheres to the principles established in the Universal Declaration of Human Rights (UDHR), the International Covenant on Civil and Political Rights (ICCPR), the International Covenant on Economic, Social and Cultural Rights (ICESCR), the International Convention on the Elimination of All Forms of Racial Discrimination, the Convention on the Elimination of All Forms of Discrimination against Women, the Convention on the Rights of the Child, and the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment.
In accordance with the guidelines of these international instruments, the protection of fundamental human rights, equality, dignity and well-being of all people is ensured, without any distinction.
The Company will ensure in all cases compliance with the provisions of the Conventions issued by the International Labour Organization (ILO), among which we can mention the Freedom of Association and Protection of the Right to Organise Convention, the Right to Organise and Collective Bargaining Convention, the Equal Remuneration for Work of Equal Value Convention, the Abolition of Forced Labour Convention, the Discrimination in Respect of Employment and Occupation Convention, and the Child Labour Convention.
SEXUAL HARASSMENT, EQUAL OPPORTUNITIES AND NON-DISCRIMINATION:
Any act of harassment or violence is prohibited in the performance of work activities. Any conduct that violates equal opportunities for Mundo Campeador employees will not be tolerated.
Sexual harassment and any form of discrimination based on age, gender, sexual orientation, race, health status, nationality, political opinions or religious beliefs are not permitted within the company.
Mundo Campeador has a Protocol for the prevention of harassment, through which measures have been implemented to avoid any type of risk of this nature.
TRANSPARENCY: FINANCIAL AND NON-FINANCIAL INFORMATION:
Mundo Campeador provides rigorous and timely information, both financial and non-financial, complying with the legal guarantees that require truthful, reliable and accurate information in order to faithfully reflect the legal and economic situation of the Company.
CRIMINAL RISK PREVENTION:
At Mundo Campeador, a policy of compliance and prevention of risks of any nature has been implemented, and in particular, of criminal risks arising from the application of art. 31 bis of the Penal Code.
ACTION IN THE BENEFIT OF THE COMPANY:
Members of the organization are committed to acting, at all times and to the best of their ability, in the best interests of the company and to avoiding any action that could damage its reputation. For this reason, they must protect Mundo Campeador's image by acting ethically and responsibly in all public and private communications and actions.
THE ADMINISTRATORS:
The administrators of Mundo Campeador, and of the other companies, act in accordance with the highest ethical standards in the performance of their duties, loyally and diligently, fulfilling the obligations imposed by applicable regulations and in favor of the social interest.
THE EMPLOYEES:
The personnel selection procedures implemented at Mundo Campeador are designed to guarantee high ethical standards. Employee hiring and promotion are based on criteria of ability and suitability, in accordance with duly accredited professional experience and track record.
The company promotes the personal and professional development of its employees, fosters a positive work environment, and pays special attention to the employment integration of people with disabilities.
Consequently, freedom of employment, fundamental rights in hiring, working hours without abuse of overtime, union rights, and hygiene and health in the workplace are guaranteed.
THE CUSTOMERS:
Mundo Campeador provides high-quality services to its clients, based on the values and principles adopted by the Group, ensuring at all times that it provides a quality service that safeguards their interests and provides them with detailed information so that they can make informed decisions.
CONTRACTUAL RELATIONSHIPS WITH THIRD PARTIES:
Objective criteria are used in the hiring process to assess the suitability of establishing a contractual relationship in a way that is favorable to the Company. To this end, third parties seeking to partner with the Company are required to sign this Code and assume all obligations related to respecting workers' rights throughout the contractual relationship.
INVESTOR AND SHAREHOLDER RELATIONS:
The administrators, managers and employees of Mundo Campeador work continuously on promotion, business development and value creation to attract investors and shareholders.
RELATIONS WITH INSTITUTIONS, AUTHORITIES, OFFICIALS:
At Mundo Campeador, we promote objective and impartial conduct when dealing with institutions, authorities, and officials, and we absolutely prohibit all forms of corruption.
SITUATIONS OF CONFLICTS OF INTEREST:
Under no circumstances may Mundo Campeador staff use the name of the entities to obtain particular business advantages or opportunities or provide services to competing companies, nor may they use confidential information of the companies for their own benefit or that of a related third party.
It is important to avoid any situation that could create a conflict of interest for the benefit of individuals linked by any of the relationships mentioned below:
✓ The professional's spouse or someone with a similar relationship.
✓ Ascendants, descendants or siblings and their respective spouses.
✓ Companies related to the employee or the persons mentioned above.
If you become aware of a situation of this nature, you must inform the body responsible for compliance and comply with the provisions contained in the protocols, in this Code and in the applicable regulations.
FAIR COMPETITION IN THE MARKET:
The Company undertakes to always comply with competition regulations, avoiding engaging in anti-competitive, deceptive or unfair practices.
PREVENTION OF CORRUPTION:
In the course of the Company's business, employees are not permitted under any circumstances to offer, solicit, or accept gifts, favors, or compensation from authorities, institutions, or officials. Gifts involving payment or transfer of money, as well as payments to expedite any type of procedure or process, are also prohibited.
THIRD-PARTY GIFT POLICY:
At Mundo Campeador, it is not permitted to offer gifts, invitations, favors or courtesies to third parties, or other benefits within the framework of the activity, either directly or indirectly, in cash or in kind, for the purpose of obtaining business.
Similarly, it is prohibited to request, accept or receive any favor as consideration for performing or not performing any act.
Invitations, promotional items, courtesies, occasions or other forms of courtesies that are not in cash and that are within reasonable limits are excluded from this prohibition.
Small acts of kindness of negligible economic value are permitted, but in no case may they be carried out with the intention of influencing the recipient to take some action or fail to act in the proper manner.
In cases where a Mundo Campeador employee has doubts about the advisability or possibility of accepting a gift, courtesy, present, or invitation, they will direct an inquiry to the compliance officer.
USE OF COMPANY GOODS AND SERVICES:
The use of the resources made available to managers, directors or employees of Mundo Campeador, such as computers, email, the internet and other devices to which they have access personally or collectively, must be responsible, professional, efficient and in accordance with the needs required for the performance of the work.
The technological infrastructures will be used only for professional purposes, except in exceptional situations.
Downloading or installing illegal programs, applications or content, or those for which the appropriate license is lacking, will not be permitted.
Controlling passwords and data that allow access to Mundo Campeador information is crucial to preserving its confidentiality. Usernames, passwords, and authentication devices for computer systems are personal and non-transferable. If any transaction is detected in which these restrictions may have been disregarded, any potential security risk or incident must be reported immediately.
Random and unauthorized use of the facilities integrated into the establishments governed by Mundo Campeador will not be permitted.
PREVENTION OF MONEY LAUNDERING:
The Company is not considered an obliged entity under anti-money laundering regulations. However, its employees have committed to complying with the relevant provisions, and if any employee suspects that a transaction may be linked to money laundering, they must report it to the compliance officer.
PROCESSING OF BUSINESS INFORMATION:
Mundo Campeador employees must respect the confidentiality of information obtained in the course of their duties and have a contractual obligation to maintain secrecy regarding non-public data. This obligation remains in effect even after the contractual relationship has ended.
The information that must be kept confidential includes technological, scientific, industrial, commercial, organizational or financial information that the company has a special interest in preserving confidentially.
DATA PROTECTION:
Mundo Campeador guarantees the privacy of all personal data in accordance with European regulations and applicable Spanish law. All Company employees must be familiar with the company's internal procedures regarding the storage, safekeeping, and access to data. Any issues related to this processing should be reported to the designated person.
INDUSTRIAL AND INTELLECTUAL PROPERTY RIGHTS:
Mundo Campeador staff must respect the intellectual and industrial property rights of third parties in the course of their work, and promote the protection of copyright, patents and trademarks at all times.
OCCUPATIONAL RISK PREVENTION AND HEALTH POLICY:
At Mundo Campeador, employees are guaranteed a safe and healthy work environment, in accordance with occupational health and safety regulations. To this end, the company provides its employees with training, as well as all the necessary resources and equipment to perform their work under hygienic and clean conditions.
The possession, consumption, purchase, sale, attempted sale, distribution or manufacture of alcohol, illegal drugs and the misuse of prescription medications is prohibited while performing work activities.
In the event that temporary workers are hired through employment agencies, the same conditions will be guaranteed in accordance with applicable labor regulations, promoting the exercise of their rights and adopting all necessary measures for their protection and occupational safety.
Contractors and suppliers will likewise be subject to compliance with regulations on occupational risk prevention.
DOCUMENT PRESERVATION:
Mundo Campeador is committed to complying with the deadlines established in the regulations regarding the preservation of documents, as well as the implementation of the necessary controls to verify their proper registration.
COMMITMENT TO THE ENVIRONMENT:
At Mundo Campeador, a firm commitment to environmental protection has been made, and for this reason, various projects have been initiated to develop the activity in a sustainable manner.
complying in all cases with the relevant legal requirements in this area, in accordance with the applicable sustainability standards and the effects of preventing a negative environmental impact, as well as promoting responsible practices.
CONFIGURATION OF A CRIMINAL RISK MANAGEMENT, COMPLIANCE AND PREVENTION SYSTEM FOR MUNDO CAMPEADOR:
Mundo Campeador has established an effective organizational and management model for the prevention of risks of all kinds and, in particular, of a criminal nature.
Similarly, the entity has assigned the supervision and promotion of the Code, as well as the promotion of crime prevention, to a compliance officer with the necessary authority, appropriate training, and independent powers of initiative and control, as well as appropriate technical resources and access to all the information necessary to fulfill their role. Likewise, a Compliance Committee reporting to the Board of Directors has been appointed with specific responsibilities focused on risk prevention.
In order to carry out this preventive action, Mundo Campeador has sufficient financial, human and material resources for the operation of the compliance area and the proper implementation of the organization and management model.
Training is crucial for human resource management and for preventing risks of all kinds. For this reason, a training plan will be designed that is tailored to the activities carried out and the skills and competencies of managers, executives, and employees.
COMPLIANCE STRUCTURE:
The Compliance Committee reports to the Board of Directors and is entrusted with the following responsibilities:
(i) Adopt measures that promote regulatory compliance, as well as the dissemination of this Code and the policies implemented.
(ii) Receive complaints relating to the Code, policies and in general, all types of inquiries.
(iii) Evaluate cases of legal, Code and internal policy violations and, where appropriate, process internal investigations.
(iv) Report periodically to the Board on compliance with the management and organizational model. This body may act on its own initiative and its decisions will be binding within the structure of all companies.
In accordance with the regulatory compliance structure established in the Company, the Internal Information System Manager is the Compliance Committee, without prejudice to the possible delegation of the management and processing of complaints to one of its members.
ESTABLISHING AN ETHICS CHANNEL:
To encourage the participation of all staff and third parties in the management of the compliance model, an ethics hotline has been created. This hotline allows employees, suppliers, contractors, and clients to raise concerns, make inquiries, and report violations related to the company's activities. This hotline will be confidential, accessible to all employees, and governed by a procedure approved by the Board of Directors or its designated representative. Under no circumstances will retaliation be permitted against those who use the ethics hotline.
Any employee, regardless of their position or skills, as well as any related third parties, may report in good faith any legal violations, breaches of standards, internal policies, or irregularities. Reports must adhere to the principles of truthfulness and proportionality. Reports made with malicious intent may result in disciplinary action.
Inquiries, complaints, and any other communications through the ethics channel can be submitted via https://taigaresorts.bizneohr.com/whistleblowing-channel. Supervisors who receive reports of breaches or violations of this policy by their subordinates must notify the Compliance Committee immediately and before taking any other action. Employees may also report legal violations to the Independent Whistleblower Protection Authority.
Throughout the entire process of handling communications through the ethics channel, the rights of the whistleblower will be protected, the confidentiality of their identity will be maintained, and the provisions of Organic Law 3/2018, on the Protection of Personal Data and the guarantee of digital rights, as well as Law 2/2023, on the protection of persons who report regulatory infringements and the fight against corruption, will be complied with.
The identity of the whistleblower and the information of all persons involved in the reporting process and any subsequent investigation will be protected in accordance with applicable regulations. Furthermore, unless the Compliance Committee determines otherwise, the whistleblower will be informed of the decision reached.
DISCIPLINARY REGIME:
Failure to comply with any of the provisions contained in this Code may result in disciplinary measures being taken against the worker, in accordance with the system of infractions included in the Workers' Statute.
Among the behaviors that may lead to the imposition of a sanction in accordance with labor regulations, are non-compliance with the provisions of this Code, as well as the protocols, procedures or in general, the provisions included in the Organization and Management Model for the prevention of criminal risks, failure to report a breach of this Code, the presentation of false complaints, and engaging in harassment.
COMMUNICATION TO EMPLOYEES:
The content of this Code has been communicated to all members of Mundo Campeador, as well as to the employees of companies linked to it.
MAINTENANCE, UPDATING AND ADOPTION OF CORRECTIVE MEASURES:
The content of the Code and the organizational and management model will be continuously reviewed to adapt to changing circumstances and mitigate risks. If changes in business activity, legislative reforms, or significant non-compliance occur, the necessary corrective measures will be taken.
VALIDITY:
The Code came into force on October 20, 2025
| VERSION | RESPONSIBLE | DATE | OBSERVATIONS |
|---|---|---|---|
| V1 | Ethics Committee | 20/10/25 | None |
