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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Can I contact the ombudsman anonymously?
Yes, whistleblowers can contact the ombudsman anonymously. This includes the whistleblower's initial contact with the ombudsman. If the whistleblower prefers, the ombudsman will then maintain the whistleblower's anonymity when dealing with the company.
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What will happen with the information I provide?
The information is investigated while taking into account the relevant laws and internal rules, and the wishes of all parties concerned (e.g. the anonymity of the whistleblower). To this end, the ombudsman will check the information provided, before forwarding it to its contact at the company.
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Can I contact the ombudsman to enquire about the investigation's progress?
Whistleblowers can find out the status of the investigation from the ombudsman at any time. The ombudsman will share as much information about its findings with the whistleblower as is legally permitted, at the latest after the completion of the investigation.
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If I contact the ombudsman, will it become my legal representation?
No, the ombudsman is not permitted to represent the whistleblower in any official or judicial proceedings. Therefore, the Ombudsman cannot and must not take any steps to enforce the individual rights or claims of the whistleblower in court.
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Is the ombudsman truly independent?
Yes. The ombudsman acts as a standalone, independent lawyer and is not subject to any instructions from the company regarding the content of the matter. After a thorough investigation, the ombudsman decides whether and to what extent the information submitted to it can be passed on to the company.


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