(Applicable to Employees, Service Providers, Suppliers and Subcontractors of Curiosidade Plena Unipessoal Lda. and the Holistic Travel Plan – HTP Platform)
1.1. This Policy establishes the principles, rules, and procedures aimed at preventing, detecting, and mitigating corruption, fraud, and conflicts of interest in all activities of Curiosidade Plena Unipessoal Lda. and the Holistic Travel Plan (HTP) Platform.
1.2. This document ensures compliance with Law No. 93/2021 (General Regime for Corruption Prevention), as well as international integrity and business ethics standards, including ISO 37001 (Anti-Bribery) and COSO frameworks.
1.3. The central objective of this Policy is to promote a culture of transparency, integrity, and responsibility, ensuring that all HTP operations are conducted ethically, traceably, and in legal compliance.
2.1. This Policy applies to all employees, managers, service providers, suppliers, and subcontractors who maintain contractual relationships with HTP.
2.2. It covers all activities and operations, including procurement processes, business relations, strategic partnerships, and interactions with public or private entities, both in Portugal and abroad.
2.3. It also applies to third parties acting on behalf of HTP, who must formally adhere to this Policy as a condition for collaboration.
For the purposes of this Policy:
4.1. HTP adopts zero tolerance toward any form of corruption, bribery, fraud, or facilitation payments.
4.2. All operations must observe transparency, traceability, and legal compliance, with adequate documentation allowing audit and supervision.
4.3. Any suspected violation of this Policy must be reported immediately through formal reporting channels.
4.4. HTP guarantees protection to good-faith whistleblowers, as provided for in the Whistleblower Protection Policy.
4.5. Supervision of this Policy will be carried out by a Compliance and Ethics Officer (a role that may be combined with the DPO), who will report directly to Management and ensure the implementation and updating of the prescribed measures.
4.6. The Management of Curiosidade Plena Unipessoal Lda. holds ultimate responsibility for approving this Policy, allocating necessary resources for its implementation, and periodically reviewing its application.
5.1. It is prohibited to offer, promise, receive, or accept any undue advantage, financial or otherwise, that could influence commercial, contractual, or institutional decisions.
5.2. Participation in decisions or processes where an employee, provider, or supplier has a personal, financial, or family interest is prohibited, unless previously declared and authorized by Management.
5.3. All employees and managers must submit an annual declaration of potential conflicts of interest, updated whenever new relevant situations arise.
5.4. All parties involved must fully cooperate in internal and external audits and investigations related to reports or infractions, providing information and documents whenever requested.
6.1. HTP provides a confidential and secure channel, accessible to employees, providers, and suppliers, for reporting suspected corruption, fraud, conflicts of interest, or other violations of this Policy.
6.2. All reports will be impartially analyzed, investigated, and documented, resulting in a formal report with conclusions and a Corrective Action Plan (CAP), establishing deadlines, responsibilities, and mitigation or correction measures.
6.3. The CAP will be monitored by the Compliance Officer/DPO until all defined actions are fully resolved, with auditable records.
6.4. Records related to reports and CAPs will be stored for a minimum period of 5 years, in accordance with legal and regulatory requirements.
6.5. HTP guarantees confidentiality and protection against retaliation for all whistleblowers acting in good faith.
7.1. All employees and service providers in critical functions must attend mandatory annual training on ethics, integrity, and corruption prevention.
7.2. Specific sessions will be organized for managers and those responsible for procurement and supplier contracting, addressing risks and internal procedures.
7.3. All training sessions will have documented records of participation and results, with periodic evaluation of their effectiveness.
8.1. HTP will maintain a Corruption and Fraud Risk Map, updated annually, identifying critical processes and areas (e.g., procurement, payments, and institutional relations).
8.2. Suppliers, partners, and subcontractors will be subject to integrity and compliance due diligence procedures prior to contracting and periodically thereafter, especially when involved in financial operations or institutional representation.
8.3. All resulting information will be documented and analyzed by the Compliance Officer/DPO, integrating HTP’s Operational Risk Matrix.
9.1. Any gift, present, invitation, or hospitality received or offered with a value exceeding €50 (or another limit defined annually by Management) must be reported to the Compliance Officer and approved by Management before acceptance or granting.
9.2. All gifts and hospitality will be documented in a formal record, subject to annual internal and external audits.
10.1. This Policy will be disseminated to all employees, service providers, and suppliers and will remain permanently accessible in HTP’s Policy and Privacy Center and other official digital media.
10.2. All new employees and service providers must sign a declaration of knowledge and acceptance of this Policy as a condition to begin duties or partnerships.
11.1. All records related to reports, audits, risk reports, CAPs, approvals, and training will be stored for a minimum of 5 years, in a secure and auditable format.
11.2. These records will be available for internal and external inspections and by competent authorities upon formal request.
12.1. Sanctions will be applied according to the severity of the infraction, distinguishing between negligence, intentional violation, or recurrence, ensuring an investigation process and right of defense.
12.2. Measures may include:
12.3. In all cases, offenders must fully cooperate with internal and external investigations and regulatory authorities.
13.1. This Policy will be reviewed annually based on internal and external audits and risk reports.
13.2. An Annual Implementation and Compliance Report will be prepared, including the number and types of reports, CAPs implemented, measures taken, training sessions held, and risks identified, presented to Management and available for inspection by authorities upon request.
13.3. HTP will make non-confidential summaries of the Annual Report results available to relevant stakeholders (employees, service providers, and suppliers) to reinforce transparency and ethical culture.
13.4. The results of audits, CAPs, and the annual report will be used to update this Policy and HTP’s Operational Risk Matrix, ensuring continuous improvement and regulatory alignment.
13.5. This Policy complements and integrates with the Whistleblower Protection Policy, Cybersecurity Policy, Terms and Conditions, and HTP’s Operational Risk Matrix.
Definitions of Technical Terms and Key Concepts
Version History and Dates
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