CODE OF CONDUCT AND POLICY FOR THE PREVENTION OF COMMERCIAL SEXUAL EXPLOITATION OF CHILDREN AND ADOLESCENTS – ESCNNA

AQUA TOUR TRAVEL

Company name: ELITE INTERNATIONAL SAS – AQUA TOUR TRAVEL
NIT: 901.469.590
Home: Bogotá DC, Colombia
Activity: Travel and Tourism Agency
Email: reservas@aquatourtravel.com

Date of adoption: October 1, 2026
Version: 1.0

1. INSTITUTIONAL DECLARATION

ELITE INTERNATIONAL SAS – AQUA TOUR TRAVEL, henceforth Aqua Tour Travel, expressly states its commitment to the comprehensive protection of children and adolescents and to the prevention, rejection and eradication of any form of Commercial Sexual Exploitation of Children and Adolescents (ESCNNA) associated with travel and tourism.

Aqua Tour Travel states that:

IT DOES NOT OFFER, PROMOTE, FACILITATE, ORGANIZE, INTERMEDIATE AND TOLERATE TOURIST ACTIVITIES THAT INVOLVE THE SEXUAL EXPLOITATION OF CHILDREN AND ADOLESCENTS.

The company adopts this Code of Conduct as an integral part of its business, commercial, operational and social responsibility management.

This document is adopted in accordance with the Law 679 of 2001, Law 1336 of 2009, Resolution 3840 of 2009 and other applicable Colombian regulations.

2. OBJECTIVE

To establish the policies, commitments, procedures and internal measures that Aqua Tour Travel, its legal representatives, administrators, employees, contractors and other persons linked to the provision of tourist services must observe, for the purpose of:

Preventing the sexual exploitation of children and adolescents in travel and tourism.
Prevent the tourist services offered by Aqua Tour Travel from being used to facilitate these behaviors.
Raise awareness and train staff.
Establish internal prevention and reporting mechanisms.
Promote a corporate culture of protecting children and adolescents.
Inform customers, travelers, suppliers and partners about Aqua Tour Travel's commitment.

3. SCOPE OF APPLICATION

This Code will be mandatory for:

Legal representative.
Management.
Administrative staff.
Sales consultants.
Reservations and operations staff.
Marketing and advertising staff.
Guides or coordinators linked by Aqua Tour Travel.
Contractors.
Freelancers.
Suppliers directly linked to the tourism operation.
Business partners, where applicable.
Anyone acting on behalf of or representing Aqua Tour Travel.

Compliance will be required both in the physical facilities and during the execution of tourist activities and in the company's digital channels.

4. PRINCIPLES

Aqua Tour Travel will conduct its activities under the following principles:

4.1. Comprehensive protection

Children and adolescents are subjects of special protection and their rights must be respected at all times.

4.2. Zero tolerance

Aqua Tour Travel maintains a policy of zero tolerance against any form of commercial sexual exploitation of children and adolescents.

4.3. Prevention

The company will implement measures aimed at preventing risky situations within its commercial and tourism activities.

4.4. Responsibility

Any employee who has knowledge of facts that may constitute ESCNNA must act in accordance with the legislation and established procedures.

4.5. Confidentiality

Information related to possible situations of rights violations will be handled with due confidentiality, without prejudice to the legal duty to inform the authorities.

5. EXPRESS PROHIBITIONS

Aqua Tour Travel prohibits its collaborators, contractors and related third parties from:

5.1.

Offering, promoting or marketing tourist packages that directly or indirectly involve the sexual exploitation of children or adolescents.

5.2.

Providing information to tourists or third parties about places, establishments or people where activities of commercial sexual exploitation of minors are coordinated or practiced.

5.3.

Transporting, driving or facilitating the transfer of tourists to establishments or places where sexual exploitation of children or adolescents is practiced.

5.4.

Providing accommodation, transport, excursions, activities or any other tourist service for the purpose of sexual exploitation of minors.

5.5.

Using vehicles, boats or other means of transport contracted by Aqua Tour Travel to facilitate activities related to the exploitation or sexual abuse of minors.

5.6.

Using Aqua Tour Travel's social media, WhatsApp, websites, booking platforms, email or other digital means to promote, facilitate, contact, offer or disclose activities related to the sexual exploitation of minors.

5.7.

Using photographs, videos, texts, advertising or any material that sexualizes, objectifies or violates the rights of children and adolescents.

6. COMMITMENT TO CUSTOMERS AND TOURISTS

Aqua Tour Travel will inform its clients and travelers that:

In Colombia, the commercial sexual exploitation of children and adolescents is prohibited. Aqua Tour Travel rejects any conduct of this nature and will not allow its tourism services to be used to facilitate it.

Travelers must respect Colombian laws and regulations for the protection of children and adolescents during their travels.

7. COMMITMENT TO SUPPLIERS

Aqua Tour Travel will promote the adoption of ESCNNA prevention practices by suppliers related to its tourism operation.

In particular, efforts will be made to ensure that suppliers of:

Hotels.
Transport.
Tour operators.
Incoming agencies.
Guides.
Excursions.
Cruises.
Support services.
Recreational activities.

know and respect the applicable provisions regarding the protection of children and adolescents.

Where appropriate, Aqua Tour Travel may incorporate contractual clauses for the prevention and rejection of the ESCNNA.

8. STAFF RESPONSIBILITIES

All Aqua Tour Travel employees must:

Know and comply with this Code of Conduct.
Reject any request related to the sexual exploitation of minors.
Do not provide information that facilitates such activities.
Report any suspicious situation internally.
Report to the competent authorities the facts of which there is knowledge and a legal obligation to do so.
Participate in the scheduled training sessions.
Protect information related to potential victims.
Avoid any action that could put a child or adolescent at risk.

9. PROCEDURE IN THE EVENT OF A RISK SITUATION

When an employee receives, becomes aware of, or identifies a request, conduct, or situation that may be related to the sexual exploitation of children and adolescents (ESCNNA), they must:

STEP 1 – DO NOT FACILITATE

Do not make reservations, provide transportation, make recommendations, make contacts, make payments, coordinate, or do any other actions that may contribute to the conduct.

STEP 2 – REPORT INTERNALLY

Immediately report the situation to Management or the person designated by Aqua Tour Travel.

STEP 3 – PRESERVE THE INFORMATION

To preserve, when legally appropriate and without putting any person at risk, relevant information that allows the authorities to investigate the facts.

STEP 4 – REPORT

When there are facts that may constitute a crime or a violation of rights, Aqua Tour Travel must report them to the competent authorities in accordance with Colombian law.

STEP 5 – DO NOT INVESTIGATE ON YOUR OWN

Collaborators must not conduct investigations, interrogations, or confrontations that could endanger the potential victim or affect an official investigation.

10. REPORTING CHANNELS

Aqua Tour Travel will have the following internal channels:

Mail: reservas@aquatourtravel.com

Official channels of the competent authorities may also be used to make the corresponding complaints.

Reports must be handled confidentially and forwarded to the authorities when appropriate.

11. TRAINING

Aqua Tour Travel will develop awareness and training activities for its employees on:

Rights of children and adolescents.
Prevention of the ESCNNA.
Law 679 of 2001.
Law 1336 of 2009.
Code of Conduct.
Identifying risk signs.
Internal reporting procedure.
Responsibility of tourism providers.

The company will retain evidence of the training activities carried out.

12. ADVERTISING AND COMMUNICATIONS

All advertising, commercial communication, campaigns, social media posts, websites, audiovisual material or promotional content of Aqua Tour Travel must respect the rights and dignity of children and adolescents.

It is prohibited to use advertising that:

Suggest sex tourism with minors.
Promote sexual activities with minors.
Use sexualized images of minors.
Present destinations or establishments as places to sexually access minors.
Provide information directly or indirectly for such activities.

Law 679 of 2001 expressly establishes obligations related to tourism advertising and prohibits tourism providers from engaging in conduct of this nature.

13. SOCIAL NETWORKS AND DIGITAL CHANNELS

Aqua Tour Travel will implement measures to prevent its digital channels from being used for:

Soliciting sexual services with minors.
Sharing child sexual exploitation material.
Facilitating contacts related to sexual exploitation.
Promote establishments with this purpose.
Coordinate illegal activities related to minors.

Any content of this nature that is detected must be handled in accordance with internal procedures and legal reporting obligations.

14. PROTECTION OF CHILDREN AND ADOLESCENTS DURING TRAVEL

When Aqua Tour Travel organizes family trips, excursions, educational groups, academic mobility, conventions or other activities where minors participate, it will endeavor to establish prevention measures appropriate to the nature of the service.

These may include:

Identification of those responsible.
Prior information for parents or guardians.
Support protocols.
Emergency information.
Coordination with suppliers.
Verification of service conditions.
Rules of conduct for travelers and companions.

15. RELATIONSHIP WITH HOTELS AND ACCOMMODATION ESTABLISHMENTS

Aqua Tour Travel will endeavor to work with legally authorized establishments and suppliers that carry out their activities in accordance with applicable regulations.

Where appropriate, establishments will be encouraged to have policies and codes of conduct to prevent the sexual exploitation of children and adolescents.

16. MANAGEMENT RESPONSIBILITY

Aqua Tour Travel Management will be responsible for promoting the implementation of this Code and for:

Ensure its disclosure.
Promote training.
Coordinate preventive actions.
Maintain the supporting documentation.
Periodically evaluate compliance.
Take corrective action when necessary.

17. EMPLOYEE COMMITMENT

All employees must know, accept and comply with this Code.

Aqua Tour Travel may incorporate the following commitment into its engagement processes:

I declare that I am aware of and agree to comply with Aqua Tour Travel's Code of Conduct and Policy for the Prevention of the Commercial Sexual Exploitation of Children and Adolescents, as well as applicable Colombian laws. I agree not to promote, facilitate, participate in, or tolerate any conduct related to the sexual exploitation of children and adolescents, and to promptly report any such situation of which I become aware.

18. DISCIPLINARY AND CONTRACTUAL MEASURES

Failure to comply with this Code may result in the corresponding administrative, labor, contractual or legal measures, in accordance with the nature of the relationship and the applicable legislation.

When conduct may constitute a crime, Aqua Tour Travel may bring the situation to the attention of the competent authorities.

19. LEGAL CONSEQUENCES

Aqua Tour Travel will inform its collaborators, clients and users that conduct related to the sexual exploitation of children and adolescents may generate administrative and criminal consequences.

The Colombian Penal Code specifically addresses the crime of sex tourism related to minors.

Law 679 of 2001 also includes administrative sanctions for tourism providers who engage in certain behaviors related to the sexual exploitation of minors.

20. DISCLOSURE OF THE CODE

Aqua Tour Travel will keep this code available for reference by:

Contributors.
Contractors.
Suppliers.
Customers.
Business partners.
Competent authorities.

Tourism regulations require the adoption and establishment of effective codes of conduct for the prevention of the sexual exploitation of children and adolescents.

21. MESSAGE FOR CUSTOMERS

Aqua Tour Travel may use the following message in its quotes, vouchers, contracts, website and communications:

🚫 AQUA TOUR TRAVEL SAYS NO TO ESCNNA

Aqua Tour Travel rejects and prevents all forms of commercial sexual exploitation of children and adolescents in travel and tourism.

Our employees, suppliers, partners, and travelers must respect the rights of children and adolescents and comply with Colombian law.

The sexual exploitation of minors is a crime.

If you are aware of a situation that could put a child or adolescent at risk, please inform the relevant authorities immediately.

Aqua Tour Travel – Traveling is also about protecting.