Corporate Policies

Good Corporate Governance Code

The objective of this document is to compile and disseminate the principles and values that Avia Marketing aims at conveying to its personnel, third parties related to the company, government institutions, and our vendors, as pertaining to the environment and the community in general, based on the guidelines set for a company that adheres to Corporate Social Responsibility standards. Additional to the aforementioned, we adopt Aviatur Corporate Group's policies pertaining to:

• • Principles of the United Nations Global Compact
  • Vendors Code of Conduct
  • Social Responsibility Policy
  • Money Laundering and Terrorism Financing Prevention Policy
  • Environmental Sustainability Policy
  • IT Security Policy
  • Human Rights Policy

And other policies issued by Aviatur Corporate Group.

Ethical Management

• • The company does its best to investigate the legal situation of related parties to avoid working with vendors or hiring employees who are part of the OFAC and UN lists, or people or companies who have or may have had links to drug trafficking, terrorism or illegal activities connected to counterfeit, theft, fraud or who may have a criminal record. We only do business with individuals or enterprises with moral solvency.
  • We apply policies that tend to stop asset laundering.
  • We do not accept bribes, nor do we allow illegitimate pressure or extortion to select any of our commercial operations. We only take on contracts that are awarded by means of clean processes.
  • We do not pay bribes, and expressly prohibit corrupt practices to obtain a commercial advantage.
  • We are respectful of the law and fully comply with Colombian and international regulation in all regards.
  • Avia Marketing fulfills its commitments even if it implies economic loss and abides by its word as a way to show how serious and respectful we are of our vendors and clients.
  • All human beings deserve to be treated with respect and equality, regardless of differences related to our natural conditions and race, nationality, social footing, gender, religion, age, political affiliation, social or cultural background, physical or health limitations and ways of thinking.
  • Our managers or employees are not authorized to use the company's funds or goods to contribute to any type of political.
  • The company does not allow, amongst its employees, the direct or indirect dissemination of political propaganda. They are not asked, directly or indirectly, to be part of any political affiliation. Their right to vote is respected.
  • The company is respectful of the free competition principle and refrains itself from using practices such as disrepute, deceit, unfair advertising or the illegal acquisition of classified information.

With our Customers

• • Avia Marketing works exclusively with clients legally constituted under Colombian or international laws.
  • We abide by our commitments with our clients.
  • We are responsible for the quality of our products, which are based on standards set forth by the corresponding government and control entities.

Money Laundering and Terrorism Financing Prevention. “SARLAF”

Based on Aviatur Corporate Group's general policy on prevention and control of money laundering, terrorism financing and any other similar crime category contemplated in current national and international laws and regulations, Avia Marketing hereby stipulates that it demands from its vendors statements that declare that the equity and economic revenue that enables them to undertake their corporate purpose are not the result of illicit activities, such as drug trafficking, asset laundering, unfair enrichment,  kidnapping, extortion or human trafficking . If this is the case for any of their shareholders, employees, managers and/or legal representatives, or if this applies to any of their vendors, and if any of the aforementioned are part of the OFAC (Office of Foreign Assets Control), UN lists or any other list with the same or similar nature, either national or international ones, or if any of the above has been legally convicted for any crime, Avia Marketing is entitled to unilaterally cancel the contract at any given point without prior notice and without resource to later claim.

Unusual and suspicious operations are reported to UIAF

With our Vendors

• • The company works with vendors who are respectful of their workers, who should be enrolled in the Social Security system.
  • We do not work with vendors who do not follow taxing standards.
  • The company's officers must be respectful of vendors when establishing a relationship with them or processing their claims.
  • Selection criteria shall only be based on product or service quality and price, as well as appropriate conditions for the end consumer or client.
  • Company employees or managers in charge of selecting a vendor should not have any economic interests in the chosen company; they shouldn't have first or second degree of blood or family ties working for them either.
  • Vendors shall certify that they do not have any first or second-degree blood or family ties to any of the company's employees or managers. If this is the case, vendor selection will only be approved by General Management, and if the company administrator has ties to the chosen company, the selection will be approved by the board of trustees.
  • The company fulfills its obligations related to vendor payment.
  • We work exclusively with clients legally constituted under Colombian or international laws.
  • We demand guarantee on products offered to the public.
  • No employee will be entitled to provide our vendors with information that will make it impossible to have a transparent selection process.
  • Our workers know that it is prohibited to receive any sort of compensation, commission or payment relating to a selection process.

Our vendors are obligated to adhere to the consumer protection statute and/or special standards pertaining to activities such as tourism, issued by competent authorities.

Child Protection Policy

The company expressly prohibits connections to any company or individual that promotes child exploitation or abuse.

Regarding tourism services, Avia Marketing holds National Tourism Registration number 20565, which is related to our actions against child and adolescent exploitation, pornography, and sexual tourism, pursuant to Law 1336 from 2009, aiming at fulfilling obligations contemplated in articles 16 and 17 of Law 679 from 2001 and resolution 3840 from 2009, as well as preventing behavior stipulated in article 19, Law 679 from 2001. Commitments are as follows:

Refrain from offering, expressly or surreptitiously, sexual exploitation of children or adolescents as part of tourism promotion or tour packages programs.

• • Refrain from providing, directly or indirectly, tourists with information related to places from which commercial sexual exploitation of children and adolescents is coordinated or practiced.
  • Refrain from taking tourists, directly or indirectly, to establishments or places that benefit from or carry out commercial sexual exploitation of children, as well as taking children or adolescents to the places where tourists stay, even if they are located offshore.
  • Refrain from facilitating vehicles in tourism routes that have sexual exploitation of children or adolescents as its main purpose.
  • Stop children and adolescents from entering hotels - or any other places where tourists may lodge-, bars, similar businesses and other establishments that provide tourism services, with the purpose of sexual exploitation or abuse.
  • Implement measures aiming at stopping any individual associated to the company from offering tourism services that enable sexual activities with children and adolescents.
  • Protect children and adolescents - Colombian or Foreign- from any form of sexual exploitation and violence caused by local or international tourists.
  • Disavow child labor exploitation.
  • Disavow race or gender discrimination.
  • To come forward before the Ministry of Commerce, Industry and Tourism and other relevant authorities when under the possession of facts or suspicion of activities related to the sexual exploitation of children and adolescents, ensuring that the company has mechanisms to report such cases to the corresponding institutions.
  • Design and disseminate, within the company and with its goods and services vendors, a policy in which the vendor establishes measures to prevent and counter all form of children and adolescent sexual exploitation during trips and tourism activities.
  • To train all personnel already working for and new staff coming into the company, as well as vendors who, because of the nature of their activities, have contact with tourists, on the prevention of commercial sexual exploitation of children and adolescents.
  • Educate customers on the legal consequences in Colombia related to sexual exploitation and abuse of children and adolescents, especially about prison sentences and financial sanctions ordered by competent authorities against people involved in child and adolescent sexual exploitation, pornography, and sexual tourism.

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Policies against Smuggling and Piracy

Avia Marketing does not use illegal or unlicensed software, nor does it promote smuggling or piracy practices.

Avia Marketing hereby declares that, regarding Colombian law, fulfills and exclusively works with vendors that declare respectful fulfillment of applicable regulations in matters of software, licensing, authorizations and other permits established by the competent authorities pursuant to the activities being undertaken.

Avia Marketing does not work with vendors who have, have had claims, processes, lawsuits, litigations, sanctions, penalties or likewise applied against them for illegally bringing into the country contraband goods or fostering piracy.

Environmental and Social Policy

Avia Marketing adheres to the corporate environmental policy from Aviatur Corporate Group, who, by taking into consideration its commitment to Sustainable Development, aims at managing its businesses by generating economic and social value using natural resources in an efficient manner. The Corporate Environmental Policy has been defined based on the following elements:

• • Aspect identification and assessment of environmental impacts generated by all activities from our organization.
  • Implementation of good environmental practices to minimize negative impact associated to our activities.
  • Implementation of technology and infrastructure improvements that help minimize the negative environmental impact from our activities.
  • Rational use of natural resources in the activities undertaken by our organization.
  • Fostering an environmental culture within the organization through awareness and training of our employees, with clear messages conveyed to our interest groups.
  • Fulfillment of current environmental legislation.

The following lines of work have been established for the implementation of the policy above:

• • Rational use of water and electricity
  • Rational use of paper
  • Comprehensive waste management
  • Carbon footprint calculation and compensation

 

Environmental Principles and Values:

The corporate environmental policy has the following principles:

• • Environmental training for our employees and interest groups.
  • Process and infrastructure innovation to improve our environmental performance.
  • Prevention aiming at avoiding or minimizing negative environmental impact instead of correcting consequences.

The corporate environmental policy comprises the following values:

• • We consider ourselves responsible for our actions and their consequences, as related to our employees, clients, and vendors.
  • We are respectful of people, the environment, and their surroundings.
  • We are committed to managing resources efficiently, while operating responsibly from a social and environmental perspective, promoting sustainable development.
  • Well-being for our employees, aiming at protecting their right to have a sustainable and productive life, harmonizing with nature.

Avia Marketing and its vendors hereby declare that the services and goods we provide currently meet, and will meet, applicable environmental, natural resources, human health, industrial safety, landscaping and cultural heritage standards, as well as any other regulations related to environmental and social responsibility.

Regarding tourism, we implemented sectorial technical standard NTS-TS-003, pertaining to sustainable tourism, whereby we commit to maintaining a balance in all aforementioned aspects, aiming at guaranteeing long-term sustainability.

Data Protection

Pursuant to Law 1581 from 2012, Decree 1377 from 2013 and all other standards that amend or rescind it, the vendor in a free, express, voluntary and duly informed manner authorizes Avia Marketing to collect, compile, store, use, circulate, suppress, process, exchange, give treatment to, update and dispose of the data that has been supplied to it and that has been incorporated into different databases and banks, or into all sorts of electronic repositories available to Avia Marketing. Data collected could be used to a. Demonstrate contractual relationship between the vendor and Avia Marketing. b. The rendering of services related to offered products and services. Cases in which the USER decides to subscribe to, be entered in, query upon or acquire products or services. c. The completion of all activities related to the service and/or product, to be included in a list of emails to send requests from Avia Marketing. d. Receive communication on service changes. e. Processing of its own requests, activity administration, clarifications, and research and market statistics. f. Marketing and sales of our own products and services. g. Notification of new services or products that may be related to the ones already contracted or acquired. h. The undertaking of any activity that may be complementary or accessory and necessary to the rendering of the service. i. The production of assessments and programs necessary to determine consumption habits. j. Needed to fine-tune security filters and business rules for commercial transactions. k. Carry out periodical assessments of our products and services aiming to improve their quality. l. Assess the quality of the services we render, and generally, fulfill the obligations we have contracted with you. m. The shipping, through traditional and electronic means, of technical, operational and commercial information about products and services offered by Avia Marketing and/or its associates or vendors, currently and in the future. n. satisfaction survey requests. o. while undertaking other company functions.  The handling of this information shall be done pursuant to Avia Marketing's Personal Data Treatment Policy, available from our webpage www.aviamarketing.com. In this regard, Avia Marketing Is expressly and unequivocally authorized to maintain and handle all its information to keep on treating all its data pursuant to stipulations from the Privacy Disclaimer and the Personal Data Treatment Policy. If you wish to have your information suppressed or modified, we'd like to invite you to contact us by means of the following email: info@aviamarketing.com

Occupational Safety and Health Policy

Avia Marketing strictly adheres to occupational safety and health legislation and any other requirements committed to continuous improvement, we also foster responsibility and self-care within our value chain.

The following guidelines shall be followed to achieve the goals of our Policy:

• • The implementation of an integrated management system committed to continuous improvement that will enable us to achieve our objectives and goals, as well as periodic reviews and updates.
  • Hazard identification and risk assessment for all activities from all our companies, as well as the implementation of controls aiming to reduce work-related ailments and accidents.
  • Channeling of well-being, prevention and protection actions aiming at protecting the health of our workers and our property.
  • Implementation of Epidemiological Surveillance Systems comprising priority risks, aiming at promoting health and prevent work-related illnesses and accidents.
  • Promotion of our initiative related to the non-consumption of alcohol, tobacco, and drugs by fostering support strategies with activities targeting the employee community and the work environment.
  • Training our employees aiming to prevent incidents associated to vehicle driving.

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Our Sustainability System - Sustainable Tourism

Background:

By the late 80s, with the creation of the WTO (World Tourism Organization), a committee -formally linked to the United Nations- is created to address world environmental issues. In the 90s, Environmentally Responsible Tourism was already spoken of and between 2000 and 2011, a sustainable development plan is formulated to address Sustainable Tourism concepts and themes.

WHAT IS SUSTAINABLE TOURISM?

Tourism is one of the sectors with the highest growth rate around the world, reason why it has become one of the main development engines in many countries. Such growth could have positive and negative impacts, depending on the adequate management given to destinations chosen to operate in.

Sustainable tourism is an industry committed to tourism activities respectful of the environment, inclusion of local communities, generation of fair and equalitarian employment conditions and, of course, economic growth for the destinations in which tourism activities take place.

What do we protect with Sustainable Tourism?

Natural heritage

Refers to a set of elements comprising a landscape; physical and biological monuments, geological and physiographic formations, areas comprising animal and vegetation species and strictly delimited places or areas that have an exceptional universal value from a scientific and natural beauty preservation perspective.

Cultural heritage

Refers to a set of works from artists, architects, musicians, writers and scholars, as well as anonymous creations with a popular origin, material and immaterial works which express the creativity of a community; it also refers to language, rites, beliefs, places, historical monuments, literature, works of art, local archives and libraries.

Environment

Refers to a system comprising intertwined natural and artificial elements that are modified by human action. Refers to the environment that conditions the way of life of a society, which includes natural, social and cultural values that exist in a given place and moment in time.

SUSTAINABILITY POLICY

Aviatur Holding Group runs its activities committed to respecting the environment, keeping in mind both cultural and social aspects of all products and services we offer, always aiming for our customers’ satisfaction.

We act within the legal frame of the law of Colombia, through a highly trained team creating awareness of our environment.

Our management system acts bettering on a daily basis our behavior toward the environment we live in. We rely on a suitable group of suppliers who provide us with the best service possible. Our company wheels on Corporate Environmental, Social Responsibility and Climate Change Policies that make a great input to reaching to achievement.

OUR SUSTAINABILITY COMMITMENTS

• Customer Service
• Protection against illegal trafficking of flora, wildlife, and cultural assets
• Recommendations for travelers
• Good sustainability practices.

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CULTURAL AND SOCIAL ASPECTS

ESCNNA (SEXUAL AND COMMERCIAL EXPLOITATION OF CHILDREN AND ADOLESCENTS) AND PREVENTION AGAINST CHILD PORNOGRAPHY

According to the global tourism code of ethics, these activities are associated to resting, leisure, sports, access to culture and nature; therefore, the sexual and commercial exploitation of children and adolescents in connection with travel and tourism has a negative impact on the industry.

According to Law 679 from August 3, 2001, issued by Congress, the government has put in place regulations to prevent and counter exploitation, pornography and sexual tourism involving minors.

Pursuant to the stipulations from this Law, all people should prevent, bar, combat and report the exploitation, accommodation, use, publication, dissemination of images, texts, documents, audiovisual files, improper use of global information networks, or the establishment of telematic links of any sort related to pornographic material or allusive to sexual activities involving minors.

Taking into consideration stipulations from Article 17, Law 679 from 2001, the agency warns tourists as to the fact that exploitation and sexual abuse of minors in the country are criminally and administratively sanctioned, under current and valid law.  Likewise, and aiming to fulfill Resolution 3840 from December 24, 2009 and pursuant to Article 1 of Law 1336, from July 21, 2009, Aviatur S.A. adopted a Code of Conduct model aiming at preventing and impeding sexual exploitation of children and adolescents in connection with tourism activities.

CODE OF CONDUCT

To comply with stipulations from Resolution number  3840, from December 24, 2009 by means of which the Code of Conduct contemplated under article 1 from Law 1336, July 21, 2009 is established " in order to amend and make more robust Law 679 from 2001, which aims at combating exploitation, pornography and sexual tourism involving children and adolescents", establishing obligations for tourism services providers pertaining to the adoption of a Code of Conduct model to promote prevention policies to avoid the sexual use and exploitation of children and adolescents in connection with tourism activities.

Therefore, all employees of companies belonging to the Aviatur Organization must fulfill, with no exception, the following commitments:

1. 1. Refrain from offering, expressly or surreptitiously (secretly), sexual exploitation of children or adolescents as part of tourism promotion or tour packages programs.
   2. Refrain from providing, directly or indirectly, tourists with information related to places from which commercial sexual exploitation of children and adolescents is coordinated or practiced.
   3. Refrain from taking tourists, directly or indirectly, to establishments or places that benefit from or carry out commercial sexual exploitation of children, as well as taking children or adolescents to the places where tourists stay, even if they are lodging on offshore ships, with the purpose of sexually and commercially exploiting them.
   4. Refrain from facilitating vehicles in tourism routes that have sexual exploitation of children or adolescents as its main purpose.
   5. Stop children and adolescents from entering hotels or any other places where tourists may lodge, bars, similar businesses and other establishments that provide tourism services, with the purpose of sexual exploitation or abuse.
   6. Implement measures aiming at stopping any individual associated to the company from offering tourism services that enable sexual activities with children and adolescents.
   7. To come forward before the Ministry of Commerce, Industry and Tourism and other relevant authorities when under the possession of facts or suspicion of activities related to the sexual exploitation of children and adolescents, as well as knowledge related to the existence of places where these activities take place, ensuring that the company has mechanisms to report such cases to the corresponding institutions.
   8. Design and disseminate, within the company and with its goods and services vendors, a policy in which the vendor establishes measures to prevent and counter all forms of children and adolescent sexual exploitation during trips and tourism activities.
   9. To train all personnel already working for and new staff coming into the company on the prevention of commercial sexual exploitation of children and adolescents.

• • Inform customers about legal consequences in Colombia related to the exploitation and sexual abuse of children and adolescents.
  • To post in a visible place, for all establishment employees to see, the valid Code of Conduct and all other commitments and measures that the vendor wishes to implement aiming at protecting children and adolescents.

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VENDOR CONTRACTING

One of the criteria to select vendors stipulates that the provider shall certify that it employs sustainable practices in the destinations it operates.

SUPPORT TO LOCAL COMMUNITIES

• • We promote commercialization of products (handcrafts and gastronomy) coming from within the region.
  • We also promote visits to national destinations.

NATURAL AND CULTURAL ASPECTS

HERITAGE CARE

Keep in mind that we have, in our country, the following natural and cultural heritage sites as declared by UNESCO, which we shall respect and help preserve:

• • Marimba music and traditional singing from the Colombian Southern Pacific region Nariño, Cauca and Valle del Cauca
  • Palenque de San Basilio cultural space - Bolívar
  • Barranquilla carnival - Atlántico
  • Easter week processions in Popayán-Cauca
  • Blancos y Negros (Blacks and Whites) carnival - Nariño
  • Regulatory System from Wayuu, enforced by pütchipü'ü ("palabrero")-Guajira
  • Traditional knowledge from jaguar shamans from Yuruparí-Vaupés
  • San Francisco de Asís celebration-Quibdó
  • Santa Cruz de Mompox historic center-Bolívar
  • Coffee cultural landscape of Colombia-Risaralda, Caldas, Quindío and Valle del Cauca
  • San Agustín Archeological Park-Huila
  • Tierradentro Natural Park
  • Los Katios national park-Choco, Antioquia
  • Port, fortresses and monumental group of Cartagena-Bolívar

Click here for more information on Colombian heritage towns.

Click here for more information on different heritage facts.

ENVIRONMENTAL ASPECTS

• Saving and rational use of water and electricity program
• Saving and rational use of paper program
• Integral waste management program
• Environmental management plan.

RESPONSIBLE BEHAVIOR AND COMMITMENTS WITH DESTINATIONS

Recommendations to customers:

1. 1. Do not extract flora and/or wildlife species from their natural habitat. It constitutes an environmental crime.
   2. Do not introduce exotic flora and wildlife species into a new environment. This causes serious alterations to their natural habitat and their food chain.
   3. Do not feed wild animals directly. Feeding should be controlled and advised by wildlife experts.
   4. Do not make excessive noise as it could alter the natural environment of local wildlife.
   5. Do not burn any materials or have bonfires. The gases produced during a bonfire may be toxic and cause grave problems to the ecosystem and communities around them.
   6. Solid waste generated should not be disposed of in an inadequate manner.
   7. Take into consideration recommendations related to entering, behavior, stay, respect and conservation of these tourist destinations.

Travel and Tour Agency Aviatur S.A. is committed to fulfill Law 679 from 2001 (ESCNNA Prevention), Law 63 from 1986 (Protection of Cultural Assets), Law 1185 from 2008 (Protection of Cultural Heritage), Law 17 from 1981 (Protection of Wildlife and Flora), Law 1333 from 2009 (Environmental Penalties) and Law 376 from 2009 (Tobacco, alcohol and other psychoactive substance consumption prevention amongst minors).

Additionally, we enforce a Code of Conduct model aiming at preventing and impeding sexual exploitation of children and adolescents, pursuant to Resolution 3840, from December 24, 2009 and Article 1 of Law 1336, from July 21, 2009.