The operating network standard
What KAIROS requires of a counterparty before it receives a single client detail

Full identity: registered company name, tax identification number or VAT number, registered address, beneficial ownership and the individual who signs. We do not work with trading names that cannot be traced back to an identified company.

Good standing: current certificates from the Spanish tax authority and from social security.

A named point of contact, with real authority to bind the company, and a deputy. KAIROS requires that any change of contact be notified: silent rotation is grounds for reviewing the accreditation, because the judgment of a counterparty usually lives in one particular person.

Insurance evidenced, not asserted. A certificate issued by the insurer or the broker, showing the policyholder, the policy number, the cover, the limits and the period of validity.

Screenshots, premium receipts and the provider's own declarations are not accepted: a document not issued by the party carrying the risk evidences nothing. Validity must cover the whole window of the operation, not only its first day.

Nobody offers what they cannot evidence. The principle runs across every sector and each one gives it a concrete form: registration and AOC holder in aviation, authorisation by airport and by category in ground handling, the vehicle's attachment to the authorisation in chauffeur services, an instruction signed by the registered owner in real estate, and an allocation from the rights holder in hospitality.

Subcontracting declared. If the provider is going to execute through a third party, it says so beforehand and that third party is subject to this same standard. No engagement is subcontracted in silence: discovering on the apron, at the venue gate or in the doorway of a building that the party executing is not the party contracted invalidates the whole operation, even when it ends well.

The confidentiality agreement is signed before any of the principal's information circulates.

Where the provider processes personal data on behalf of KAIROS, the data processing agreement required by Article 28 of the General Data Protection Regulation is signed, and the principle of least access applies: each third party receives only the detail it needs for its part.

No commission. The provider declares in writing that it pays KAIROS nothing in any form and that its quotation includes no amount intended for KAIROS.

And there are behaviours that do not open a review of a file: they close it. Offering KAIROS a commission, a rebate or an incentive, because whoever proposes it is telling us how they work with everyone else. Presenting a published asset as off-market, or a mandate that is not held as exclusive. Being unable to identify the operator holding the air operator certificate under which the flight would be made. Producing an insurance certificate that has expired, is not named, or refers to a vehicle, aircraft or venue other than the one on offer. Asking for the client's name before the standard is closed and confidentiality is signed. Approaching the client on your own initiative at any moment, before, during or after the engagement. None of these six is negotiable, and none is offset by price.

If the counterparty operates: a current air operator certificate (AOC). Regulation (EU) 965/2012, in Annex III (Part-ORO, ORO.AOC.100), requires it to be obtained before starting any commercial air transport operation, and Union air carriers additionally need an operating licence under Regulation (EC) 1008/2008. An operator from a third country flying to, within or from the Union needs a TCO authorisation issued by EASA under Regulation (EU) 452/2014, and that requirement draws no distinction between scheduled flights and charter.

The specific aircraft, not the fleet. We require the operations specifications showing the registration that is going to be flown. Where the aircraft is leased, ORO.AOC.110 makes every lease agreement subject to prior approval by the competent authority: we ask for that approval, not for the operator's word.

If the counterparty is a broker or an intermediary rather than an operator, there is no equivalent certification to produce. That is why KAIROS requires what the law does not: that it identify itself as a broker in writing and name the AOC holder and the registration before we confirm anything. An intermediary who cannot say who is flying is not offering a flight.

Cover under Regulation (EC) 785/2004, which sets the minimum insurance requirements for air carriers and aircraft operators: at least 250,000 SDR per passenger in passenger liability, and third-party cover per accident and per aircraft that scales with maximum take-off mass. Minimums are minimums; on long-haul operations we expect cover above them and we say so beforehand.

Above the law, KAIROS requires a named insurance certificate, showing the registration that is going to be flown and with validity covering the whole window of the operation, outbound and return included, and not only the date of the first sector. A certificate that expires between the outbound and the return is a certificate that is of no use.

The question is not what you can offer, but what you have the right to operate. For each aircraft it puts on the table, the provider evidences: the registration, the holder of the AOC under which it is operated, and the title by which it has the aircraft available, whether ownership, a management agreement or a lease with the prior approval required by ORO.AOC.110.

We do not accept availability without a registration. We do not accept an option that rests on an unnamed third party confirming later. And we pass no offer to the client whose operator is not identified: if the quotation goes across in full view, as it always does, it has to withstand being read in full.

The chain, where there is one, is documented. A broker consulting another broker who consults the operator is not a problem in itself; the problem is not saying so. It is said, it is put in writing, and it is accepted or ruled out with the fact in plain sight.

Before KAIROS shares the first client name, the following is put in writing:

The quotation itemised and firm, with what it includes and what it does not: handling, taxes, catering, crew, crew overnight, overflight permits and positioning. Currency and price validity period.

The cancellation terms and the aircraft substitution policy, including what happens if the aircraft offered ceases to be available and what counts as an acceptable substitution.

Who answers to the client for the execution of the flight. Operational responsibility belongs to whoever operates, and that is put in writing before booking.

The single channel of contact and the contact rule: the operator does not approach the principal on its own initiative at any moment.

An express declaration that the price includes no remuneration whatsoever for KAIROS. Our fee is identified and separate, and the provider's quotation is passed on exactly as it arrives.

The handling of the passenger list, which is disclosed to the minimum the operation requires and to nothing else.

In Spain, the provision of airport ground handling services at airports of general interest is governed by Real Decreto 1161/1999 and requires prior authorisation, processed before the Spanish Aviation Safety and Security Agency (AESA). AESA itself gives a warning worth retaining: obtaining the authorisation is not enough to begin providing the service, because a contract with the airport managing body is also required. For ramp services, and at airports above the traffic thresholds the rule sets, the number of suppliers is limited.

We require the authorisation with its real scope: the specific airport and the specific category of service. Outside Spain, the equivalent authorisation from the relevant State and the airport managing body's approval.

Above the law, KAIROS requires that the staff attending the operation hold current access accreditation for the restricted areas in which they are going to work, and that we are told who will physically be there on arrival.

KAIROS requires current operating and airport liability cover, expressly covering damage to aircraft on the ground, to baggage and to third parties on the apron, and covering operations in the restricted areas in which the provider actually works.

The certificate must name the airports covered. A policy that covers one base and is presented as though it covered a network is not a policy: it is an expectation.

Here the mandate is the authorisation, and it is not presumed. The provider evidences that it is authorised at the specific airport and for the specific category it offers. A supplier authorised at Madrid-Barajas is not automatically authorised at Torrejón, and a party authorised for passenger assistance is not thereby authorised for ramp services.

If it turns to an authorised third party for part of the service, it declares this beforehand and by name. Coordinating a discreet arrival does not allow for finding out on the apron that the party receiving is not the party contracted.

Before the first client name, the following is put in writing:

The real hours of cover and what happens outside them, with named escalation: who is called, not which switchboard.

The arrival and departure protocol: who receives, through which route, what is communicated, to whom and at what moment. The house rule applies: zero operating contact with the client between confirmation and boarding. The principal receives route, FBO time and operator name, and nothing else.

The procedure for a delay, a diversion or a change of terminal, and who informs whom.

The confidentiality agreement, with an express prohibition on photography, on comment and on any record of the client's passage through the facility.

A current autorización VTC, the Spanish authorisation for vehicle hire with driver, domiciled in the autonomous region from which the service begins. Real Decreto-ley 13/2018 amended article 91 of Ley 16/1987, the Spanish Land Transport Act: the authorisation became intercity in scope and the service must begin within the territory of the region in which the authorisation is domiciled, the beginning being the place where the passenger is actually picked up. The regime governing urban service depends on the rules of each region and, where applicable, of the municipality: KAIROS requires the licence that matches the real route of the engagement, not the one that happens to be convenient.

Pre-booking and prior notification. The service is contracted in advance and notified in accordance with the applicable rules: Orden FOM/36/2008, as amended by Orden FOM/2799/2015, established electronic notification of the route sheet data before the service begins. We do not work with street hailing, nor with services regularised afterwards.

A licensed driver. In the regions that have established a specific professional permit or licence to drive vehicles attached to VTC authorisations, and the Comunidad de Madrid has developed one through Decreto 5/2024 and the Orden of 28 March 2025, KAIROS requires the assigned driver to hold it where it is enforceable.

For vehicles of nine seats or more, the corresponding authorisation for discretionary passenger transport.

Compulsory motor third-party liability insurance, at the minimum amounts set by Real Decreto Legislativo 8/2004: 70 million euros per claim for personal injury, whatever the number of victims, and 15 million euros per claim for damage to property.

For vehicles of nine seats or more, additionally the compulsory passenger insurance governed by Real Decreto 1575/1989, whose scope does not extend to means of public passenger transport with a capacity below nine seats.

Above the law, KAIROS requires the company's operating liability cover and an insurance certificate referring to the specific vehicles that will be assigned to the engagement.

The provider evidences that the vehicle offered is attached to the authorisation it invokes and that the assigned driver is registered as an employee of the company holding that authorisation. This is checked against the vehicle registration certificate, the technical data sheet and the driver's social security registration, referring to the specific vehicle and the specific person.

Subcontracting is declared beforehand and in writing, and the third party is subject to this same standard. A transfer passed to another company without notice stops being a vetted transfer the moment it is passed on, even if it arrives on time.

Where prior notification of the service is compulsory, the provider evidences that it has been made.

Before the first client name, the following is put in writing:

A fixed rate per journey or per hour, with waiting time, tolls, parking and supplements defined in advance. Nothing that is not there appears on the invoice afterwards.

Vehicle, registration and driver confirmed before the service, and the substitution regime: what counts as an equivalent substitution and with how much notice.

The procedure for a delayed flight, a change of terminal or a change of destination en route.

Confidentiality, with an express prohibition on photographing, recording, publishing or commenting on the passenger, their destination or their party, and a prohibition on approaching the principal to offer them services directly.

This is worth stating precisely, because almost nobody states it correctly: in Spain there is no compulsory state register of estate agents. Real Decreto-ley 4/2000 liberalised the activity and since then intermediation has required neither a qualification nor membership of a professional body as a general rule. What does exist are regional registers, and in the regions that have created one, registration is a requirement in order to practise there: Catalonia, with Llei 18/2007 and Decret 12/2010, which created the Register of Estate Agents of Catalonia; the Comunitat Valenciana, with Decreto 98/2022; and Andalusia, whose Ley 5/2025 of 16 December on Housing creates a register of estate agents specialising in the residential sector, pending implementing regulations.

KAIROS therefore requires registration and its number wherever the region in which the asset is located imposes it. Where no register exists, the absence of one does not lower the standard: KAIROS runs the file on its own account and requires the same elements.

Money laundering prevention. Property developers and those who professionally carry on agency, brokerage or intermediation activities in the purchase and sale of real estate are obliged entities under article 2.1.l) of Ley 10/2010 on the prevention of money laundering and terrorist financing. KAIROS requires the counterparty to declare its status as an obliged entity and to have in place the internal procedures that fall to it.

What KAIROS is here, said without ambiguity. KAIROS is not a registered estate agency and does not act as one, and it is not registered with the Register of Estate Agents of Catalonia. It acts as the buyer's adviser: it searches, filters, verifies and accompanies the decision. It does not represent the seller, it does not market third-party portfolios and it is not paid by the selling side. Where the transaction requires a registered agent, the client engages that agent directly and KAIROS stays alongside.

Current professional indemnity insurance. In the regions that regulate access to the activity, at the amounts and with the guarantees, insurance and, where applicable, a bond or equivalent security, that the applicable regional rule sets, evidenced by a certificate and a policy number. KAIROS asks for the insurer and the policy number, and asks for them before seeing the first asset.

And one rule of our own that depends on no legislation: the provider does not handle funds belonging to a KAIROS client. No holding deposits, no reservation payments, no earnest money in its account. Payments run through the channels set out in the transaction, with the involvement of a notary or of whichever institution applies.

This is the point for which this standard exists.

A written, current mandate. Before any conversation about an asset, the counterparty evidences the instruction: a document signed by the registered owner or by a party with sufficient authority, with a date, a subject matter, a scope, an exclusivity regime and an expiry. If the party offering is not the direct mandate holder, the chain is documented in full, with names, all the way to the ownership. A chain that cannot be written down is a chain that does not exist.

Ownership verified. An up-to-date Land Registry extract for the asset. We check it ourselves; we do not take it on trust because the selling side produced it.

What off-market means at KAIROS. It means the asset is not published and has not been published on portals, in a window display, on social media or on circulation lists, and that whoever offers it can demonstrate as much. We always check it, and we check it ourselves. A published asset does not stop being workable, and often it is: what it is not is off-market, and it is presented under its real name. Presenting as confidential and exclusive what anyone can find published is not a commercial imprecision. It is a false statement about the property being offered, and it disqualifies the counterparty for everything else.

Without an evidenced mandate there is no viewing, no name and no conversation with the ownership. No exception, not even for urgency on the selling side.

Before KAIROS shares the first client name, the following is put in writing:

The confidentiality agreement, with a reciprocal non-circumvention clause: neither party approaches the other's counterparty on its own account, during the engagement or afterwards.

Who represents whom. KAIROS acts on the buyer's side. If the counterparty represents the ownership, it is said and it is written down.

Who pays whom. KAIROS is paid by the client, never by the selling side nor by its agent. We take no share of whatever the selling side pays anyone, we accept no fee splits and we do not accept our recommendation being paid for from the other side of the table.

What may be done with the principal's name: nothing. It is not disclosed to the ownership without express authorisation, it is not used to evidence interest to third parties, and it is not added to any list or register.

Identification of the beneficial owner and of the source of funds where the transaction requires it, with the procedure and the moment at which it is provided.

Evidence from the rights holder. KAIROS requires a written document from the promoter, club, federation or organiser, or evidenced status as an official operator of the hospitality programme, with the concrete scope: event, edition, zone or product and number of places. This is not a legal requirement: it is the KAIROS requirement, and it admits no exception.

Where the counterparty is the organiser or the establishment, the authorisation or licence for the event under the applicable regional rules. In the Comunidad de Madrid, Ley 17/1997 on public entertainment and recreational activities makes the granting of the authorisation conditional on organisers evidencing that they hold third-party liability insurance for harm to attendees and to third parties, and requires premises and establishments to hold fire and liability insurance contracts.

Where the provider packages access together with transport or accommodation, the transaction may constitute a package travel arrangement or a linked travel arrangement within the meaning of the consolidated text of the Spanish Consumers and Users Act, approved by Real Decreto Legislativo 1/2007, which transposes Directive (EU) 2015/2302. In that case the trader organising or facilitating it must provide security against insolvency, in the form of a bond, insurance or guarantee fund, for the refund of payments and, where it is responsible for transport, for repatriation. KAIROS requires the guaranteeing institution to be identified.

The third-party liability insurance required by the event authorisation, in the amount the applicable rules determine, evidenced by a current certificate and referring to the specific venue and edition.

Operating liability cover for the provider delivering the hospitality service.

And, where the transaction constitutes a package travel arrangement or a linked travel arrangement, security against insolvency evidenced with the name of the guaranteeing institution and the reference of the security. Asserting that it exists is not enough.

The origin of every place has to be nameable. KAIROS requires a documented allocation from the rights holder or from the official operator, with its reference. If the provider cannot say where the places come from, there is nothing to assess.

KAIROS does not buy on the secondary market. This is not a reading of the law, it is a decision: a place whose origin cannot be evidenced is a place that may not exist on the day of the event, and the cost of that is not borne by the provider, it is borne by the client at the gate. It is worth recalling that the Spanish General Regulation on the Policing of Public Entertainment and Recreational Activities, approved by Real Decreto 2816/1982, strictly prohibits in its article 67.2 the sale and resale of tickets in the street or by itinerant means, and that regional rules penalise it: in the Comunidad de Madrid, Ley 17/1997.

Issuer conditions. The provider evidences that the tickets or accreditations are transferable under the conditions of issue and, where they are named, how and when they are issued in the attendee's name.

Before the first client name, the following is put in writing:

The confirmation with event, date, zone, exact number of places and, if the issuer requires it, the procedure for naming attendees and its deadline.

What is included exactly: access, catering, parking, transfers, host, and what is not.

What happens if the event is postponed, cancelled or held behind closed doors, and who is responsible for the refund and within what period.

The policy on substitution of zone or product, and what counts as equivalent.

The confidentiality agreement, with an express prohibition on using the client's name or their company's name in promotional material, circulated guest lists, press releases or social media, and on photographing or identifying them at the venue. A client's attendance at an event is nobody's marketing content.