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Ethical Code & Professional Conduct Guidelines

CARION-POL-03 — Ethical Code & Professional Conduct
Compliance & Responsibility

Ethical Code & Professional Conduct Guidelines

CARION Aviation Services conducts its business with honesty, integrity, and in full compliance with applicable laws. We maintain zero tolerance for bribery, corruption, and any form of unethical business practice across our entire operation and supply chain.

Document code: CARION-POL-03 Version: 01 Legal framework: Spanish Penal Code Art. 286 bis et seq. · EU Anti-Corruption Regulation · GDPR · LOPDGDD Applies to: All CARION personnel, contractors and representatives

1. Policy Statement

CARION Aviation Services has zero tolerance for bribery, corruption, and any form of unethical business practice across its entire operation and supply chain. This policy applies to all employees, contractors, subcontractors, and any third party acting on behalf of CARION.

As a professional aviation ground services operator, CARION is committed to conducting all commercial activities with full transparency, integrity, and strict compliance with Spanish and EU law — including the provisions of the Spanish Penal Code on bribery and corruption (Articles 286 bis et seq.) and applicable EU anti-corruption regulation. Our operational standards are structured to meet the rigour expected of regulated aviation service providers.

2. Anti-Bribery & Anti-Corruption

Prohibition of improper payments

No employee, contractor, or representative of CARION shall offer, give, solicit, or accept any bribe, kickback, or improper payment in connection with company business.

Gifts & hospitality

Gifts and hospitality offered or received must be reasonable, transparent, and never intended to influence a business decision. All gifts above €50 must be recorded and disclosed to the Operations Director.

Facilitation payments

Payments to expedite routine government or airport authority actions are strictly prohibited, regardless of local custom or commercial pressure.

Conflicts of interest

Any conflict of interest must be disclosed to the Operations Director prior to engaging in the relevant transaction. Non-disclosed conflicts are a disciplinary matter.

3. Fair Dealing & Competition

  • CARION competes fairly and does not engage in anti-competitive practices, price-fixing, or market allocation in breach of EU or Spanish competition law.
  • All commercial agreements with clients, FBOs, and suppliers are conducted transparently and in good faith.
  • No CARION representative shall misuse commercially sensitive information obtained from competitors, clients, or airport authorities.

4. Confidentiality & Data Protection

GDPR & LOPDGDD compliance

CARION protects the confidentiality of client, passenger, and operator information at all times, in compliance with the EU General Data Protection Regulation (GDPR) and Spanish Organic Law on Data Protection (LOPDGDD).

VIP & sensitive data

Personnel handling VIP or sensitive passenger information are bound by signed confidentiality agreements (NDA) prior to any operational deployment involving private aviation clients.

Need-to-know principle

Information is shared with third parties only on a strict need-to-know basis. Unauthorized disclosure of operational or client data is a serious disciplinary and legal matter.

5. Workplace Conduct

Equal treatment & non-discrimination

CARION provides a workplace free from discrimination, harassment, and unfair treatment, regardless of gender, age, nationality, religion, disability, or sexual orientation — in full compliance with Spanish labor law and EU equality directives.

Respect & professionalism

All personnel are expected to treat colleagues, clients, crew members, and third parties with respect and professionalism at all times, both on and off the aircraft ramp.

Device & social media policy

Use of mobile phones, social media, or any device to capture, share or publish client, crew, or aircraft-related information is strictly prohibited without prior written authorization.

6. Reporting Violations

Any employee, contractor, or third party who becomes aware of a violation of this Code is encouraged to report it directly to the Operations Director. CARION will not retaliate against any person who, in good faith, reports a suspected violation. All reports are treated with strict confidentiality.

For queries or to report a concern: operations@carionaviation.com
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