• Introduction
• Anti-Corruption and Institutional Integrity Policy
• Anti-Harassment Policy
• Gender Equality Policy
• Child Protection Policy

July 1^st ,2026

Introduction

At Ciconia Pathways, we uphold the highest standards of integrity in all aspects of our operations. Our commitment to integrity is reflected in our policies and practices, which encompass various areas including anti-corruption, anti-harassment, child protection, complaints processes, and gender equality. This Integrity Policy serves as a foundational framework to guide our conduct and decision-making, ensuring transparency, accountability, and ethical behavior across the organization.

Key Principles

1. Ethical Conduct: We conduct our business with honesty, fairness, and transparency, adhering to all applicable laws, regulations, and ethical standards.
2. Compliance: We comply with all relevant laws and regulations pertaining to our operations, including but not limited to anti-corruption laws, labor laws, and data protection regulations.
3. Zero Tolerance for Corruption: We maintain a zero-tolerance policy towards corruption in any form, including bribery, kickbacks, and fraudulent activities. Our Anti-Corruption Policy outlines our commitment to preventing, detecting, and addressing corruption within the organization and in our interactions with external parties.
4. Respectful Workplace: We foster a respectful and inclusive workplace culture where all employees are treated with dignity and respect. Our Anti-Harassment Policy and Gender Equality Policy promote a work environment free from discrimination, harassment, and bias, and provide mechanisms for reporting and addressing any violations.
5. Child Protection: We are committed to protecting the rights and well-being of children in all aspects of our operations. Our Child Protection Policy outlines measures to prevent child labor, exploitation, and abuse, and provides guidance on reporting and responding to incidents involving children.
6. Effective Complaints Process: We maintain an effective complaints process that enables employees, customers, and other stakeholders to raise concerns or grievances in a safe and confidential manner. Our Complaints Process and Policy ensure that all complaints are handled promptly, impartially, and with due process, and that appropriate actions are taken to address any issues raised.

Implementation and Oversight

Training and Awareness: We provide an annual session of awareness programs to our employees at all levels to ensure understanding and compliance with our Integrity Policy and related policies. 

Monitoring and Reporting: We employ systems to oversee adherence to our Integrity Policy and to promptly report any suspected breaches. We urge employees to raise any concerns or suspicions of misconduct using the designated channels outlined in our Complaints Process and Policy, as well as the procedures delineated within each of our policies for addressing complaints.

Continuous Improvement: We are committed to continuously reviewing and improving our Integrity Policy and related policies to ensure their effectiveness and relevance in addressing emerging risks and challenges.

Conclusion

At Ciconia Pathways, integrity exceeds being just a policy; it embodies a core value that directs our actions, choices, and interactions. Through firm adherence to integrity principles across all facades of our operations, we foster trust and confidence among our employees and stakeholders. This commitment ensures the enduring and sustainable success of our business, reinforced by unwavering trust in our endeavors.

Adoption Statement

This Policy has been reviewed and formally adopted by the Board of Directors of Ciconia Pathways on the date listed above. All Ciconia Pathways departments, staff, and stakeholders are expected to comply with the standards and obligations set forth in this document.

The policy will be incorporated into relevant procedures and training, and reviewed following any significant changes to organizational operations or international best practices.

ANTI-CORRUPTION AND INSTITUTIONAL INTEGRITY POLICY

Approved by the Board of Directors

Effective Date: 1 July 2026

“ Integrity, transparency and the fight against corruption have to be part of the culture. They have to be taught as fundamental values.“
Ángel Gurría (Secretary General of the OECD, 2018).

1. INSTITUTIONAL COMMITMENT. Ciconia Pathways is deeply committed to human rights and the social integration of migrants and refugees. Building and maintaining the trust of our beneficiaries, donors, public administrations, and society at large is fundamental to our mission; therefore, our commitment to integrity, honesty, and transparency is not optional; it is the foundation of our actions, always oriented toward the benefit of society.

Through this Anti-Corruption and Institutional Integrity Policy, we express our absolute rejection of any form of corruption, bribery, fraud, money laundering, trafficking of influence, or unfair practices, both internally and in our relationships with public entities, suppliers, donors, or any third party. We maintain an unconditional zero-tolerance commitment: no circumstance, commercial pressure, or local custom justifies it.

We adopt this policy in compliance with the United Nations Convention Against Corruption (UNCAC), Law 10/2010 on the Prevention of Money Laundering, the Criminal Code (Articles 286 bis, 419 et seq.), and GRECO standards (Group of States against Corruption of the Council of Europe).

2.- SCOPE OF APPLICATION. This policy is mandatory for all persons working for or acting on behalf of Ciconia Pathways, without distinction and regardless of their legal status, contract type, location, or duration of assignment. The Foundation requires the same level of honesty and integrity from its partners and third parties with whom it collaborates.

• Contracted staff: regardless of contract type, hours, seniority, or hierarchical level. 
• Volunteers and interns: pursuant to Law 45/2015 on Volunteering and the organization’s commitments. 
• Board of Directors: with enhanced responsibility under Article 31 bis of the Criminal Code. 
• Suppliers, consultants, and external collaborators must formally adhere to this Policy as a contractual condition. 
• Local and international partners: particularly in projects funded by European funds (AMIF, ESF+) where responsibility extends to the entire implementation chain.

3.- PROHIBITED CONDUCT.

A) Bribery and Corruption.  Any offer, delivery, or receipt of advantages to induce improper actions. Both active and passive forms are prohibited, regardless of amount: 

Improper payments to public officials. 

• Accepting payments, gifts, or favors influencing organizational decisions. 
• Facilitation payments to expedite procedures. 
• Using intermediaries to channel prohibited payments.

B) Fraud and Misappropriation. Deception in obtaining funds or misuse of resources: 

• Falsifying or altering accounting documents. 
• Concealing or inflating unjustified expenses. 
• Diverting subsidized funds (Law 38/2003).

C) Money Laundering. Prohibited legitimizing illicit funds (Law 10/2010).

D) Conflict of Interest.   Personal interests clashing with organizational ones. Obligation: Disclose immediately and recuse from decisions.

E) Trafficking of Influence.  No one may use Ciconia Pathways’s position, reputation, or privileged information for personal gain, favoritism, or influencing public decisions.

4.- GIFTS, HOSPITALITY, AND ENTERTAINMENT POLICY.

Ciconia Pathways recognizes that institutional relationships involve courtesies and hospitality, but these can become corruption if their value, frequency, or context are inappropriate.

Permitted (with mandatory registration):

• Low-value gifts from suppliers (<€30): declare in Gifts Register within 5 business days.
• Proportionate business meals with legitimate purpose.
• Professional events/training with prior Executive Director approval.

Prohibited:

• High-value gifts, regardless of origin or recipient.
• Payments or gifts to public officials on behalf of the organization (Law 9/2017).

Control: All gifts received or given are recorded in the Gifts and Hospitality Register, reviewed quarterly by Executive Management, and included in the annual transparency report (Law 19/2013).

5.- PRE-VERIFICATION PROCEDURE. Ciconia Pathways shall be obligated to execute a written contract and conduct mandatory documentary verification before receipt of any donation, contribution, or strategic partnership equal to or exceeding €10,000, which verification shall include: 1. Verification of the counterparty’s legal identity and reputation; 2. Screening against sanctions lists (OFAC, EU, UN, and Spanish Ministry of Treasury); 3. Assessment of the source of funds (sworn declaration together with banking documentation); 4. Review of criminal records and confirmation that the counterparty is not a Politically Exposed Person (PEP); and 5. For European Union funds, confirmation of anti-fraud systems compatible with AMIF/ESF+. The Compliance Officer shall implement said procedure, the Integrity Committee shall approve high-risk cases, and all documentation shall be retained in the records for a minimum period of five years in accordance with Law 10/2010 on the prevention of money laundering and Law 2/2023 on the protection of whistleblowers.

6.- ACCOUNTING RECORDS. The work of this organization is based on accuracy, traceability, and full transparency of all our accounting and documentary records. Therefore, we categorically reject any conduct contrary to financial laws or that causes harm to third parties. Therefore:

• All economic operations must be supported by original, legible, and verifiable documentation.
• Accounting documentation shall accurately describe the goods and services received, reflecting their actual market price.
• Cash payments exceeding €1,000 shall not be made, in accordance with Spanish legislation on the limitation of cash payments (Law 11/2021).
• Supporting documentation for accounting records shall be retained for a minimum period of six years, and ten years for projects funded by European Union funds.
• The organization shall submit its accounts to an annual external audit, whose results will be communicated to the Board of Trustees and published in the transparency report.

7.- Whistleblowing and Investigation Procedure. In its commitment to legality and good practices, Ciconia Pathways provides a confidential whistleblowing channel for all persons subject to this Policy to report suspicions or knowledge of conduct that may constitute acts of corruption, fraud, bribery, or other violations of this Policy. Reports may be submitted anonymously, and all whistleblowers are protected against any form of retaliation. Reports may be submitted via email to info@ciconia.org.es or in a sealed envelope addressed to Ayman Hannoun, Director of Operations of the Organization.

The reporting person shall receive acknowledgment of receipt within a maximum period of seven business days and shall be informed of the actions taken by the Organization.

• Data Protection: The processing of personal data within the framework of reports and investigations shall be carried out in accordance with the GDPR and the Spanish Data Protection Act (LOPDGDD), ensuring the confidentiality of the whistleblower’s identity.
• Non- Compliance. Failure to comply with this Policy will result in consequences proportionate to the severity of the misconduct. Depending on the circumstances, measures may range from a written warning to contract termination, with no possibility of future collaboration. Where the facts may constitute a criminal offense, the relevant authorities will be notified immediately, and Ciconia Pathways will fully cooperate with them.

It is worth noting that the implementation and effective application of this Policy constitute a mitigating circumstance for the criminal liability of the legal entity, in accordance with Article 31 bis of the Spanish Criminal Code.

8.- DISSEMINATION. Ciconia Pathways, as an organization committed to the rule of law, recognizes that for this Policy to be effectively implemented, all individuals to whom it applies, as well as those who wish to engage with us, must know it, understand it, and commit to complying with it.

This Anti-Corruption Policy will be communicated to all employees through ordinary channels (Human Resources Department, email, etc.). It will remain permanently published on the Foundation’s website to demonstrate transparency and commitment.

9.- VALIDITY. This Anti-Corruption Policy is approved by the Board of Directors of Ciconia Pathways and enters into force on the date of its publication, replacing any previous policy on the same subject. It shall remain in force until its amendment or repeal is approved.

The Policy will be reviewed at least annually, or earlier if applicable legislation or the Foundation’s circumstances change. It is complementary and must be read together with the policies established by this organization.

Anti-Harassment Policy

Approved by the Board of Directors

Effective Date: 1 July 2026

“ All labor has dignity.” – Martin Luther King, Jr.

1.  INSTITUTIONAL COMMITMENT. Ciconia Pathways is an organization committed to social integration, education, and accompaniment of people in situations of vulnerability, as we firmly believe in the universality of human rights. With this vision and mission, we recognize the importance of respecting the dignity of each person, not as an aspiration, but as an irrevocable legal and ethical obligation. Harassment, discrimination, and any form of violence in the workplace directly attack people’s integrity, contradicting the values that guide this foundation and that constitute our very reason for being.

1- This policy establishes Ciconia Pathways’s commitment to ensuring, at all times, a workplace free from harassment and discrimination for its contracted staff, collaborators, volunteers, interns, and the beneficiaries of its programs. This commitment aligns with the obligations outlined in Organic Law 3/2007, Organic Law 10/2022, and ILO Convention No. 190, among other applicable regulations.

2. SCOPE OF APPLICATION. It is important to establish that this Policy applies to all persons acting on behalf of, or under the direction of, Ciconia Pathways, without any distinction and regardless of the type of relationship they have with the organization. This is in accordance with Article 4, Section 2, Subsection (e) of the Workers’ Statute, which recognizes every person’s right to respect in the workplace.

• Contracted staff, regardless of contract type, working hours, or seniority.
• Volunteers and interns, pursuant to the Law 45/2015 on Volunteering.
• Collaborators, suppliers, and third parties interacting with staff or beneficiaries.
• Beneficiaries of Ciconia Pathways programmes. Migrants, refugees, and asylum seekers served by the organisation have a guaranteed right to non-discrimination under Law 15/2022 and OL 4/2000 on Foreigners’ Rights.
• Minors participating in the organisation’s programs have enhanced protection under OL 8/2021 (LOPIVI).

3.- PROHIBITED CONDUCT. Ciconia Pathways strictly prohibits, expressly and unconditionally, the following conduct, regardless of whether it occurs in person or through digital or electronic means, in the workplace or in any activities related to the organization:

• Sexual harassment: Any verbal, non-verbal, or physical conduct of a sexual nature that either violates a person’s dignity or creates an intimidating, hostile, degrading, humiliating, or offensive environment, including:

• Unwanted physical contact of a sexual nature.
• Comments, innuendos, jokes, or questions of a sexual nature.
• Sending, displaying, or distributing pornographic or sexually offensive material.
• Requests or propositions for sexual favors.
• Use of messaging, social media, or digital platforms for sexual purposes.

• Sex-based harassment, gender identity and sexual orientation. Any conduct related to sex, gender identity, or sexual orientation that aims at or results in the denigration or violation of a person’s dignity, including:

• Comments or jokes based on sex or gender stereotypes.
• Questioning authority based on sex.
• Systematic and repeated exclusion from activities or communications due to these factors.

• Workplace harassment (mobbing). Psychosocial risk requiring mandatory prevention: Any conduct carried out systematically and repeatedly against persons protected by this policy, aimed at or resulting in the deterioration of the work environment or their health.

• Unjustified exclusion from meetings and communications limiting professional development.
• Repeated, systematic, and unjustified public criticism of work or individuals.
• Assignment of degrading, excessive, or meaningless tasks.
• Spreading rumors or false information damaging individuals’ reputations.

• Discrimination. Any unfavorable treatment motivated by ethnic origin, gender identity, sexual orientation, nationality, migration status, religion, age, disability, or any other personal or social condition is strictly prohibited. In particular, this organization may not justify unequal treatment on the basis of migration status or vulnerability.

• Specific Legal Obligations. As an organization, we are deeply committed to current legislation and international human rights standards. Accordingly, we are obligated to prevent the following additional situations as required by applicable regulations:

• We strictly prohibit retaliation against individuals who report harassment or discrimination in good faith or participate in internal investigations.
• Harassment of persons with disabilities in access to employment or service delivery is never permitted under any circumstances.
• During digital conferencing systems used for work, any form of violence or harassment is categorically prohibited.
• When minors participate in our programs, their best interests will always prevail, including the immediate obligation to notify competent authorities.

4.- INSTITUTIONAL PREVENTION POLICY. To comply with current legislation and in alignment with our institutional philosophy, Ciconia Pathways assumes the following commitments:

• Gender perspective: We act, recognizing that sexual and gender-based harassment disproportionately affects women, responding immediately to any situation.
• Zero tolerance: No form of harassment or discrimination will be accepted. All infringing conduct will be investigated and, if confirmed, sanctioned, regardless of the rank or function of the person involved.
• Absolute confidentiality: Under no circumstances will the identity of the whistleblower or the content of the investigation be disclosed, maintaining permanent confidentiality.
• Continuous training: Ciconia Pathways commits to providing harassment prevention training upon hiring and at least one annual update for all staff.
• Accessible reporting channel: The organization maintains a confidential reporting channel accessible to all staff, volunteers, and beneficiaries who need it.

5.- WHISTLEBLOWING AND INVESTIGATION PROCEDURE. Persons who experience or witness any conduct mentioned in this policy have the right to file a report. The organization ensures serious, confidential, and legally compliant treatment of all reports.

• How to file a report: Through the confidential reporting channel established by the organization, verbally before any management body, or directly with the President of the Foundation when the affected person is part of management.
• Investigation committee: Upon receiving a report, the HR Department will form an investigation committee led by the Head of HR/Operations, with balanced gender representation where possible. The committee will conduct a prompt, fair, impartial, and confidential investigation, including interviews with the complainant, the alleged harasser, and witnesses, and a review of relevant evidence.
• We will acknowledge receipt within no more than 5 business days and begin the investigation, which we will conclude as promptly as possible.
• Precautionary measures: These will be applied immediately when the integrity, safety, or well-being of the reporting person, victim, or witnesses is at risk.
• Consequences of non-compliance: If harassment is confirmed, disciplinary action will be taken in proportion to the severity and frequency of the conduct, up to and including termination of the employment or contractual relationship with the organization, pursuant to Article 54.2(g) of the Workers’ Statute.
• Legal actions: This policy does not limit any person’s right to file a complaint with the Labor Inspectorate, Labor Courts, or criminal jurisdiction. The organization will not obstruct the exercise of any legal action.
• Prevention: Ciconia Pathways will take steps to prevent further harassment and ensure a safe environment for all.

6.- ENTRY INTO FORCE AND REVIEW. This Policy has been reviewed and formally adopted by the Board of Directors of Ciconia Pathways on the date listed above, entering into force on the date of its approval and outlined in superseding any previous policy on the same matter. All Ciconia Pathways departments, staff, and stakeholders are obligated to comply with the standards and obligations outlined in this document. The Foundation commits to distributing this Policy to all persons connected to the organization, incorporating it into the onboarding process, and publishing it in internal documentation spaces accessible to all staff.

The Policy will be incorporated into relevant procedures and training, and reviewed at least once a year, or immediately upon relevant regulatory changes, judicial decisions materially affecting its content, incidents requiring it, or significant changes to organizational operations or international best practices.

ILO Convention No. 190 on Violence and Harassment in the World of Work (2019), ratified by Spain on May 25, 2023. Article 1 defines violence and harassment as “a range of unacceptable behaviors and practices, or threats thereof, whether a single occurrence or repeated, that aim at, cause, or are likely to cause physical, psychological, sexual, or economic harm.”

Workers’ Statute (RDL 2/2015) Art. 4.2.e): Right to respect, dignity, and protection against harassment. Art. 54.2.g): Harassment as grounds for disciplinary dismissal.

Art. 23: Guarantees migrants’ right to equal treatment and prohibits discrimination based on race, national origin, ethnicity, religion, or other personal conditions. Organizations serving this population must extend anti-harassment protections to their beneficiaries

Organic Law 3/2007, of March 22, for the Effective Equality of Women and Men (BOE No. 71). Art. 7.1: defines sexual harassment. Art. 7.2: defines sex-based harassment. Art. 48: requires all employers to establish specific prevention procedures, regardless of staff size.

Law 31/1995 on Occupational Health and Safety

EU Regulation 2016/679 (GDPR), Article 9: Data from harassment complaint procedures may contain special categories of data (health, sexual orientation, ethnic origin). Organic Law 3/2018 (LOPDGDD), Article 24: Regulates internal reporting systems and guarantees whistleblower confidentiality.

GENDER EQUALITY POLICY

NON-DISCRIMINATION AND PSEA PROTECTION POLICY

Approved by the Board of Directors

Effective Date: 1 July 2026

“Gender equality is not only a fundamental human right, but a necessary foundation for a peaceful, prosperous and sustainable world.”

UN Women, Sustainable Development Goal 5 (2015)

1. INSTITUTIONAL COMMITMENT. Ciconia Pathways recognizes that gender equality is essential to human and community development. It is not merely an institutional value but a fundamental human right, recognized and protected under international law. The organization also acknowledges that gender inequality is among the principal causes of exclusion, violence, and restricted opportunities, whose respect and promotion are vital to ensuring dignity, justice, and the full enjoyment of all human rights.

This Policy affirms the organization’s commitment to promoting, respecting, and effectively implementing gender equality across all areas of its activities. It mandates the elimination of all forms of discrimination based on sex, gender identity, or sexual orientation; the prevention of and response to sexual exploitation and abuse (SEA) and workplace harassment; and the integration of a gender equality perspective throughout institutional programs and operations. This Policy complements the organization’s Sexual Harassment Prevention Policy.

2.- SCOPE OF APPLICATION. This Policy is mandatory for all individuals working for or acting on behalf of Ciconia Pathways, without distinction and regardless of their legal status, type of contract, place of assignment, or duration of engagement. The Foundation requires the same level of commitment and compliance from its partners, contractors, and any other third parties with whom it collaborates.

• Contracted staff: regardless of contract type, hours, seniority, or hierarchical level. 
• Volunteers and interns: pursuant to Law 45/2015 on Volunteering and the organization’s commitments. 
• Board of Directors: with enhanced responsibility under Article 31 bis of the Criminal Code. 
• Suppliers, consultants, and external collaborators must formally adhere to this Policy as a contractual condition. 
• Beneficiaries: individuals entitled to access the organization’s services and programs under conditions of equality and without any form of discrimination.

3.- GUIDING PRINCIPLES.

A) Substantive equality: The organization promotes the full and effective enjoyment of human rights and fundamental freedoms. Our vision goes beyond formal equality before the law, aiming instead to achieve substantive equality by removing structural barriers that prevent women and other vulnerable individuals from exercising their rights on an equal basis.

B) Zero Tolerance: The organization upholds a zero‑tolerance policy toward sexual abuse, harassment, and exploitation. No level of abusive behavior is acceptable; every incident will be investigated and sanctioned in accordance with established procedures, regardless of rank, position, or role of the person involved.

C) Do No Harm: All actions, programs, and activities of the organization must be designed and implemented with a gender‑sensitive approach to identify, prevent, and eliminate any potential risk of harm to women, girls, LGTBI+ persons, or other groups in vulnerable situations.

D) Intersectionality: Individuals may face multiple and compounded forms of discrimination when various protected conditions intersect, such as sex, nationality, migration status, sexual orientation, gender identity or expression, disability, or age. Accordingly, the organization shall adopt differentiated and rights‑based measures to respond promptly and effectively to these situations.

E) Access to Justice: The organization ensures open, safe, and accessible reporting channels; impartial investigations; and transparent communication of monitoring and evaluation results.

F) Shared Responsibility: Gender equality and safeguarding are shared responsibilities across the organization, from senior leadership to beneficiaries, in accordance with the ILO Convention No. 190 on Violence and Harassment (2019).

4.- ROLES AND RESPONSIBILITIES. To make its implementation more practical, the organization has developed the following table detailing the responsibilities of each person within the organization.

3.- PROHIBITED CONDUCT.

A) Bribery and Corruption.  Any offer, delivery, or receipt of advantages to induce improper actions. Both active and passive forms are prohibited, regardless of amount: 

Improper payments to public officials. 

• Accepting payments, gifts, or favors influencing organizational decisions. 
• Facilitation payments to expedite procedures. 
• Using intermediaries to channel prohibited payments.

B) Fraud and Misappropriation. Deception of obtaining funds or misuse of resources: 

• Falsifying or altering accounting documents. 
• Concealing or inflating unjustified expenses. 
• Diverting subsidized funds (Law 38/2003).

C) Money Laundering. Prohibited legitimizing illicit funds (Law 10/2010).

D) Conflict of Interest.   Personal interests clashing with organizational ones. Obligation: Disclose immediately and recuse from decisions.

E) Trafficking of Influence.  No one may use Ciconia Pathways’s position, reputation, or privileged information for personal gain, favoritism, or influencing public decisions.

4.- GIFTS, HOSPITALITY, AND ENTERTAINMENT POLICY.

Ciconia Pathways recognizes that institutional relationships involve courtesies and hospitality, but these can become corruption if their value, frequency, or context are inappropriate.

Permitted (with mandatory registration):

• Low-value gifts from suppliers (<€30): declare in Gifts Register within 5 business days.
• Proportionate business meals with legitimate purpose.
• Professional events/training with prior Executive Director approval.

Prohibited:

• High-value gifts, regardless of origin or recipient.
• Payments or gifts to public officials on behalf of the organization (Law 9/2017).

Control: All gifts received or given are recorded in the Gifts and Hospitality Register, reviewed quarterly by Executive Management, and included in the annual transparency report (Law 19/2013).

5.- PRE-VERIFICATION PROCEDURE. Ciconia Pathways shall be obligated to execute a written contract and conduct mandatory documentary verification before receipt of any donation, contribution, or strategic partnership equal to or exceeding €10,000, which verification shall include: 1. Verification of the counterparty’s legal identity and reputation; 2. Screening against sanctions lists (OFAC, EU, UN, and Spanish Ministry of Treasury); 3. Assessment of the source of funds (sworn declaration together with banking documentation); 4. Review of criminal records and confirmation that the counterparty is not a Politically Exposed Person (PEP); and 5. For European Union funds, confirmation of anti-fraud systems compatible with AMIF/ESF+. The Compliance Officer shall implement said procedure, the Integrity Committee shall approve high-risk cases, and all documentation shall be retained in the records for a minimum period of five years in accordance with Law 10/2010 on the prevention of money laundering and Law 2/2023 on the protection of whistleblowers.

6.- ACCOUNTING RECORDS. The work of this organization is based on accuracy, traceability, and full transparency of all our accounting and documentary records. Therefore, we categorically reject any conduct contrary to financial laws or that causes harm to third parties. Therefore:

• All economic operations must be supported by original, legible, and verifiable documentation.
• Accounting documentation shall accurately describe the goods and services received, reflecting their actual market price.
• Cash payments exceeding €1,000 shall not be made, in accordance with Spanish legislation on the limitation of cash payments (Law 11/2021).
• Supporting documentation for accounting records shall be retained for a minimum period of six years, and ten years for projects funded by European Union funds.
• The organization shall submit its accounts to an annual external audit, whose results will be communicated to the Board of Trustees and published in the transparency report.

7.- Whistleblowing and Investigation Procedure. In commitment to legality and good practices, Ciconia Pathways makes available a confidential whistleblowing channel for all persons subject to this Policy to report suspicions or knowledge of conduct that may constitute acts of corruption, fraud, bribery, or other violations of this Policy. Reports may be submitted anonymously, and all whistleblowers are protected against any form of retaliation. Reports may be submitted via email to info@ciconia.org.es or in a sealed envelope addressed to Ayman Hannoun, Managing Director.

The reporting person shall receive acknowledgment of receipt within a maximum period of seven business days and shall be informed of the actions taken by the Organization.

• Data Protection: The processing of personal data within the framework of reports and investigations shall be carried out in accordance with the GDPR and the Spanish Data Protection Act (LOPDGDD), ensuring the confidentiality of the whistleblower’s identity.
• Non- Compliance. Failure to comply with this Policy will result in consequences proportionate to the severity of the misconduct. Depending on the circumstances, measures may range from a written warning to contract termination, with no possibility of future collaboration. Where the facts may constitute a criminal offense, the relevant authorities will be notified immediately, and the Ciconia Pathways will fully cooperate with them.

It is worth noting that the implementation and effective application of this Policy constitute a mitigating circumstance for the criminal liability of the legal entity, in accordance with Article 31 bis of the Spanish Criminal Code.

8.- DISSEMINATION. Ciconia Pathways, as an organization committed to the rule of law, recognizes that for this Policy to be effectively implemented, all individuals to whom it applies, as well as those who wish to engage with us, must know it, understand it, and commit to complying with it.

This Anti-Corruption Policy will be communicated to all employees through ordinary channels (Human Resources Department, email, etc.). It will remain permanently published on the Foundation’s website to demonstrate transparency and commitment.

9.- VALIDITY. This Anti-Corruption Policy is approved by the Board of Directors of the Ciconia Pathways and enters into force on the date of its publication, replacing any previous policy on the same subject. It shall remain in force until its amendment or repeal is approved.

The Policy will be reviewed at least annually, or earlier if applicable legislation or the Foundation’s circumstances change. It is complementary and must be read together with the policies established by this organization.

Convention on the Elimination of All Forms of Discrimination against Women (CEDAW), Art. 5.

Inter‑Agency Standing Committee (IASC) Minimum Operating Standards for Protection from Sexual Exploitation and Abuse (PSEA); United Nations Policy on Sexual and Gender‑Related Conduct; UN Women and UN Global Compact Women’s Empowerment Principles (WEPs); and UNHCR Gender‑Sensitive Humanitarian Action Framework.

Child Protection Policy

1st January 2026

Introduction

“We shall protect the child from all forms of physical or mental violence, injury or abuse, neglect, maltreatment, or exploitation, including sexual abuse.” – UN Convention on the Rights of the Child (1989), Article 19.

As committed members of Ciconia Pathways, we share a common dedication to preventing child abuse and safeguarding children. Recognizing the prevalence of child abuse and exploitation worldwide, this policy establishes our shared values, principles, and beliefs, outlining the steps to fulfill our commitment to protecting children.

This policy is endorsed by the Board of Directors of Ciconia Pathways, a non-profit registered in Spain under registration number G93761971.

Our commitment to protect children

Our values, principles, and beliefs

1. All child abuse violates children’s rights.
2. Every child is entitled to equal protection from abuse and exploitation.
3. The situation of all children should be improved by promoting their rights, including freedom from abuse and exploitation.
4. Child abuse is unequivocally unacceptable.
5. We are committed to protecting children with whom we work.
6. We bear the responsibility to uphold minimum standards of protection for children in our programs.

What we will do In meeting our commitment to protect children, we will implement the following measures:

Awareness:

Ensure all staff and stakeholders are aware of the issue of child abuse and associated risks.

Prevention:

Minimize risks to children through awareness and best practices.

Reporting:

Clearly outline steps for staff and stakeholders when concerns arise regarding children’s safety.

All staff must adhere to this Code of Conduct, pledging to never:

Staff and others must never:

1. Physically assault or abuse children.
2. Develop physical or sexual relationships with children.
3. Engage in relationships with children deemed exploitative or abusive.
4. Act in ways that may place a child at risk of abuse.
5. Use inappropriate, offensive, or abusive language.
6. Behave inappropriately or provocatively.
7. Have unsupervised overnight stays with children.
8. Sleep in the same room or bed as a child they are working with.
9. Perform personal tasks for children that they can do for themselves.
10. Condone or participate in illegal, unsafe, or abusive behavior by children.
11. Act in ways that shame, humiliate, belittle, degrade, or emotionally abuse children.
12. Discriminate against or show favoritism towards particular children.

Important Guidelines for Staff and Stakeholders:

1. Be aware of situations presenting risks and manage them effectively.
2. Plan and organize work and workplaces to minimize risks.
3. Be visible while working with children.
4. Foster a culture of openness for addressing concerns.
5. Encourage accountability among staff to challenge poor practice or potentially abusive behavior.
6. Communicate with children about their rights, acceptable behavior, and avenues for reporting problems.

Inappropriate Actions:

1. Spend excessive time alone with children away from others.
2. Take children to your home, especially where they will be alone with you.

This policy emphasizes the importance of maintaining a safe and protective environment for children, promoting their well-being and upholding their rights. Any breach of this policy will result in appropriate disciplinary action, including legal consequences if warranted.

Adoption Statement

This Policy has been reviewed and formally adopted by the Board of Directors of Ciconia Pathways on the date listed above. All Ciconia Pathways departments, staff, and stakeholders are expected to comply with the standards and obligations set forth in this document.

The policy will be incorporated into relevant procedures and training, and reviewed following any significant changes to organizational operations or international best practices.