SCANDIC CARS – COMPLIANCE STATEMENT

Introduction

This Compliance Statement describes how SCANDIC CARS – a brand of the international brand alliance – conducts its business in accordance with legal and ethical requirements. The brand alliance consists of:

Legal Notice:
SCANDIC ASSETS FZCO and LEGIER Beteiligungs mbH act as non-operational service providers. All operational activities of SCANDIC DATA are carried out by SCANDIC TRUST GROUP LLC. SCANDIC ASSETS FZCO is the holding company and owner of the brands; operational and all responsible activities are performed by SCANDIC TRUST GROUP LLC.

SCANDIC ASSETS FZCO acts within the group as the holding company and owner of the brands; operational activities – including the brokerage of luxury rental vehicles under the SCANDIC CARS label – are undertaken by SCANDIC TRUST GROUP LLC.

Our goal is to foster a corporate culture of integrity, transparency, and legal compliance. To provide customers and partners with a reliable foundation, SCANDIC CARS consolidates legal, operational, technological, and reputational risks and manages them through a binding compliance management system.

Overview Library

1. Compliance Organization
2. Legal and Regulatory Obligations
3. Customer Due Diligence and Know-Your-Customer (KYC)
4. Marketing and Advertising
5. Sanctions Screening and Prohibited Transactions
6. Whistleblower System
7. Training and Awareness
8. Monitoring and Continuous Improvement

1. Compliance Organization

The management of SCANDIC TRUST GROUP LLC has established a structured compliance management system. It includes the departments of Legal, Data Protection, Risk Management, Information Security, and Internal Audit. A binding policy stack governs Corporate Governance, Data Protection, Digital Services, Supply Chain and Human Rights Policy, Modern Slavery Statements, Cookie Policies, and the Protection of Vulnerable Persons. Responsibilities are clearly defined; risk and control processes are regularly evaluated.

2. Legal and Regulatory Obligations

SCANDIC CARS is subject to various legal systems and regulations:

Passenger Transport Act (PBefG):
As a broker of luxury rental vehicles, we do not require our own passenger transport license, provided that we merely establish contact between passenger and driver. We monitor compliance with the return-to-base obligation, ensure that pricing and working hours are managed by partner companies, and assist in the transmission of legally required mobility data.

Trade Law and Rental Car Law:
Our partner companies must hold commercial vehicle rental insurance. For self-drive rental vehicles, a special self-drive rental insurance policy is required. Customers are advised to take out additional insurance (e.g., fully comprehensive).

Data Protection & Information Security:
We process personal data in accordance with the requirements of the GDPR and respect the rights of data subjects. Data protection impact assessments and a zero-trust infrastructure ensure the confidentiality and integrity of data.

Supply Chain Due Diligence:
Although SCANDIC CARS is below the legal thresholds of the Supply Chain Due Diligence Act, we voluntarily adhere to human rights and environmental due diligence obligations throughout the entire supply chain.

Anti-Corruption and Sanctions Law:
Transactions with sanctioned individuals or organizations are excluded; we maintain mechanisms for sanctions screening and reporting of suspicious activities.

3. Customer Due Diligence and Know-Your-Customer (KYC)

Before accepting new customers, we conduct risk analyses. For the brokerage of luxury rental vehicles, we collect identification documents, driver’s license verification, and payment information. Transactions are monitored to detect indications of money laundering, terrorist financing, or fraud. In cases of suspicion, we report the matter to the competent authorities and reserve the right to refuse the business relationship.

4. Marketing and Advertising

Our marketing follows the principle of transparency: advertising statements must be clear, non-misleading, and supported by facts. This particularly applies to information about rental prices, vehicle classes, and services. We refrain from aggressive cross-selling and take into account the interests of vulnerable customers. Sister brands are identified as part of the brand alliance; synergies are disclosed to maintain transparency.

5. Sanctions Screening and Prohibited Transactions

We screen customers, projects, and transactions against national and international sanctions lists. Transactions with sanctioned persons, organizations, or regions are rejected. We do not work with suppliers or service providers that support child labor, forced labor, or other human rights violations. For high-risk business relationships, we conduct enhanced due diligence checks.

6. Whistleblower System

SCANDIC CARS maintains confidential whistleblowing systems. Employees, customers, or external partners can report violations of laws, internal policies, or human rights without fear of retaliation. Reporting channels are:

• Online Portal: Anonymous reports via a secure whistleblower portal.
• Email: compliance@ScandicCars.com
• Phone: +49 (0)30 99211-3469
• External Compliance Officer: Attorney Axel Kapust (compliance@kapust.law)

Reports are investigated, documented, and appropriate corrective measures are implemented. Whistleblowers acting in good faith are protected from discrimination.

7. Training and Awareness

All SCANDIC CARS employees receive regular training in the areas of compliance, data protection, anti-money laundering, due diligence, and human rights. New employees complete a structured onboarding program. Training content is continuously updated to reflect legal changes and emerging risks.

8. Monitoring and Continuous Improvement

The compliance department continuously monitors adherence to internal and external regulations. Internal audits, external reviews, and feedback mechanisms ensure transparency. Insights are incorporated into the ongoing development of our compliance management system. Policies are adapted, processes improved, or technical measures implemented as needed.