Compliance
Integrity. Responsibility. Trust.
At HRS, compliance is an integral part of how we conduct business—globally, responsibly, and with integrity. We are committed to upholding the highest standards of ethical conduct and to ensuring full compliance with all applicable laws and regulations in every jurisdiction in which we operate.
Why Compliance Matters
Operating in the global travel industry requires navigating a complex and evolving regulatory landscape while working with partners across multiple jurisdictions. In this environment, compliance is essential to ensuring thatour business activities are conducted lawfully, ethically, and responsibly at all times.
Our compliance framework is designed to ensure adherence to all applicable legal requirements, including anti-bribery and anti-corruption laws,antitrust and competition regulations, as well as foreign trade and export control provisions. At the same time, it supports fair and transparent business practices, protects the interests of our customers, partners, and employees,and safeguards the long-term success and reputation of HRS.
Compliance is embedded in our business processes and decision-making structures to mitigate legal and financial risks and to reinforce a culture of accountability and trust across all areas of our operations.
Our Expectations for Business Partners
We expect our business partners to share our commitment to integrity and lawful conduct. This includes operating in full compliance with all applicable laws and regulations, particularly in the areas of anti-corruption, competition law, and trade compliance. We also expect our partners to respect internationally recognized human rights, uphold fair labor standards, and conduct business in a responsible and ethical manner.
Our Business Partner Code of Conduct defines these principles and serves as the foundation for sustainable and trustworthy business relationships.
👉 Read our Business Partner Code of Conduct
Zero Tolerance for Corruption
HRS applies a strict zero-tolerance approach to bribery and corruption in any form. The offering, promising, granting, or acceptance of improper advantages—including bribes, inappropriate gifts, or facilitation payments—is strictly prohibited.
All business decisions must be based exclusively on objective, transparent, and legitimate criteria. These standards apply equally to our employees and to all business partners acting on our behalf or in connection with our business activities. We are committed to maintaining the highest levelof integrity, even where this requires foregoing business opportunities.
Compliance Framework
HRS maintains an independent and effective compliance organization responsible for the implementation, oversight, and continuous development ofour compliance program.
Our framework addresses all key areas of regulatory relevance. Through clearly defined policies, procedures, and controls, we ensure that compliance standards are consistently applied across all regions and business units.
Speak Up – We Listen
We encourage employees, business partners,and third parties to raise concerns whenever potential misconduct or violationsof law or policy are suspected.
To support this, HRS provides access to anindependent ombudsperson and a secure whistleblowing system. Reports can besubmitted confidentially and, where legally permissible, anonymously. Allreports are carefully reviewed and investigated in a fair and impartial manner.HRS does not tolerate retaliation against individuals who raise concerns ingood faith.
Our ombudsman and Compliance Officer can becontacted at the following address:
Stefan Rau(Attorney)
BDO LegalRechtsanwaltsgesellschaft mbH
Zielstattstraße4081379 Munich
phone: +49172-8244516
mail: stefan.rau@bdolegal.de
FAQs
All your questions, answered.
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What is the role of the ombudsman?
Employees, business partners and external parties have the right to report circumstances that indicate a breach of the law or our internal rules. This information can be reported to the ombudsman. The ombudsman offers a legally protected and confidential service outside the company. It informs whistleblowers about their rights and how the information they provide will be handled. The ombudsman will only share this information with its contact at the company if the whistleblower [1] consents to this. The ombudsman can be asked to act as a representative in the matter. The ombudsman is always available for the whistleblower to contact.
[1] Any gendered terms always include people of all genders. The HRS Group is committed to the Diversity Charter and considers everyone to be equal, regardless of gender, age, background, religion, disability or sexual orientation. The wording of this text has been chosen solely to make the text easier to read.
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Who can contact the ombudsman?
All employees and external parties, such as suppliers or service providers, can contact the ombudsman.
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What information does the ombudsman accept?
The ombudsman accepts information regarding breaches of the law and our internal rules. The main objective is to investigate and prevent economic offenses, accounting offenses and financial losses. However, any violations of internal policies such as the Code of Conduct can also be reported to the ombudsman. Confidential and anonymous reports of discrimination, sexual harassment or similar issues can also be submitted to the ombudsman.
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Can I be certain that the ombudsman will only pass on information as far as I allow?
Yes. The whistleblower alone decides what information to provide to the ombudsman and what information the ombudsman can pass on to the company in the second step of the process. The ombudsman is only permitted to pass on information against the wishes of the whistleblower in cases of misuse, i.e. if the whistleblower has intentionally provided incorrect information. The ombudsman will make this clear upon initial contact with the whistleblower.
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Does it cost me anything to use the ombudsman?
No, the ombudsman is free to use.


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