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What are the requirements for tourism services in the European market?

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European tour operators are bound by strict regulations. These ensure that their customers are protected financially and safe when travelling overseas. If you want to do business with tour operators in Europe, you need to make sure that your business meets their standards. The most important legal statute for them is the European Package Travel Directive.

1. What are the mandatory requirements for tourism services?

You need to be aware of several statutes and requirements. They are the European Package Travel Directive, business insurance and General Data Protection Regulation (GDPR).

European Package Travel Directive

The European Package Travel Directive protects European travellers’ rights when they book package holidays. These rights include cancellation, liability, repatriation and refunds. In 2018 the Directive was updated to reflect changes in how holidays are booked. The update expanded the definition of “package travel” to include customised packages and linked travel arrangements.

Although the United Kingdom has left the European Union (“Brexit”), British tour operators still have to comply with the Directive. That is because it has been written into UK law. It is known there as the Package Travel and Linked Travel Arrangements Regulations 2018.

The Directive covers the following types of “package travel”.

  • A package holiday is defined as a combination of at least two different types of travel services. There are four types of travel service: (1) transport (flights, trains, buses, etc.); (2) accommodation (hotels, lodges, apartments, etc.); (3) car rental; and (4) other tourist services like attraction tickets and excursions. All elements of the package holiday are booked and paid for through one agent at the same time.
  • Customised packages are two or more travel services bought in a single booking process at one “point of sale” (by phone, in a shop, online, etc.). For example, when a customer buys a flight, books a hotel room and rents a vehicle over the phone with a travel agent.
  • Linked travel arrangements (LTAs) are travel services bought in different contracts within a 24-hour period and linked to the same package. For example, a customer buys a flight on one day from a travel agent. The next day, he or she calls the same travel agent and adds a room booking to the same order.

The European Package Travel Directive aims to provide travellers with clear information about the travel product they are buying, and the protection they are entitled to. The concept of LTAs ensures that payments are protected if the seller goes bankrupt. The Directive also covers cancellation rights and liability. And it applies to online bookings as well as other types. Figure 1 shows how the current Directive protects buyers of package travel, compared with the original version.

Figure 1: Extension of the 1990 European Package Travel Directive, 2018

Extension of the 1990 European Package Travel Directive, 2018

Source: European Union (EU)

If you want to sell travel services to European tour operators, they will expect you to have adequate liability insurance and insolvency protection so that they comply with the European Package Travel Directive. You must be able to supply them with full details of your insurance policies.

The Directive is likely to be amended again in the next few years. The pandemic and the collapse of Thomas Cook, one of Europe’s largest travel agents, highlighted issues around insolvency and customer protection. So you need to stay aware of any changes that might affect your business. Read the article Thomas Cook and Covid-19 spur EU review of the Package Travel Directive for more details.

Tips:

Business insurance

Insurance for tour-operator businesses can cover many different risks. The most important are:

  • liability;
  • professional indemnity; 
  • financial failure.

European tour operators have a responsibility to provide the holiday the customer has paid for. They take out liability insurance to protect themselves in the event that they are held liable for accidents or injury. If you supply European tour operators, you must have liability insurance in case one of their customers suffers an accident or injury during an activity you have provided.

Your liability insurance should also cover tours that you sell directly to independent travellers. Although most take out their own personal travel insurance to cover them in the event of an accident, you cannot rely on that being the case. Independent travellers will be more confident in your services if you tell them that you are fully insured in the case of accidents.

Professional indemnity insurance covers businesses in the event of professional mistakes or negligence. Liability and indemnity insurance are often provided together in an insurance policy.

Financial failure insurance protects your customers’ money if your business fails. The European Package Travel Directive requires European tour operators to have an certain level of financial protection in place.

If you are already insured, check that your policy and cover are adequate. Ask your broker exactly what risks are covered, and what amounts. If you are in any doubt, ask them to send you your policy documents again.

Tips:

  • Identify what insurance cover you require. In other words, what European tour operators need you to have. You may also want to insure against other risks, like employers’ liability and/or business interruption.
  • Look into suitable insurance providers for tour operators in your country or region. Make sure that all aspects of the tourism services you provide are covered by your policy.
  • Communicate clearly to your buyer that you have this insurance in place, and make sure that you include details in a “Terms of reference” section on your website. Take a look at this example of a local tour operator with detailed terms and conditions posted online: Outstanding Costa Rica (see section 6, Mandatory insurance requirements).
  • Check that customers taking your tours have their own personal travel insurance. This does not mean you will not be liable if anything goes wrong, but they are more likely to contact their own insurance company first. Some tour operators make this a mandatory condition when booking with them – for example, Much Better Adventures.
  • Do not include international flights in your packages. This means you will not be responsible for repatriation or accommodation in the event of disruptions and/or cancellations.

General Data Protection Regulation (GDPR)

The EU adopted the General Data Protection Regulation (GPDR) in 2016. Replacing the 1995 Data Protection Directive, it became law across the EU in May 2018. The UK continues to comply with GDPR, even though it has left the EU. The Data Protection Act 2018 came into force there at the same time as the GDPR, and imposes very similar rules.

The GDPR is designed to protect customers’ privacy. In particular, it covers the storage, processing and sharing of personal data. That includes everything from a person’s name, address and e-mail address to their, bank details, social media data, passport information and biometrics, as well as online identifiers such as an IP addresses.

Figure 2: What is personal data?

What is personal data?

Source: TechTarget

The GDPR has had a significant impact on all European travel businesses, because they handle the personal data of travellers who book with them. But it also affects any company worldwide that processes information about people who live in the EU or the UK. If you sell directly to European consumers, it will affect you too.

Under the GDPR, the main (but not all) rules you must comply with include…

  • Clarity. Privacy policies need to be written in clear, straightforward language.
  • Consent. The user must give permission before their data can be used. This means that they must actively “opt in”. Listing only “opt-out” options is no longer permitted.
  • Transparency. Businesses must clearly inform users if their data will be transferred outside the EU or the UK. Businesses are allowed to collect data only for a well-defined purpose and must tell users if that purpose changes. 
  • Right of access. Users have full rights to access their data and to request that it be deleted. Businesses must inform users without delay in the event of a data breach.
  • Enforcement. The European Data Protection Board has the power to impose fines for non-compliance of up to €20 million, or 4% of the company’s worldwide turnover.

Tips:

  • Find out more about GDPR. Make sure that you understand what you are (and are not) allowed to do with customers’ personal data.
  • Audit your current data to determine whether it is compliant with GDPR. Use a checklist to help, such as the GDPR checklist for data controllers.
  • Check your privacy policy and ensure that it states clearly how you collect and store customers’ personal data. Take a look at Travel Talk’s policy and see how it compares with yours.
  • Draw up clear consent request forms. For more information about obtaining and managing consent, read ICO’s GDPR consent guidance. Make sure that you keep records of consents obtained.

For additional support and information about trading with European businesses, regularly consult these websites.

2. What additional requirements and certifications do buyers ask for in the tourism sector?

Sustainable business practices are an important requirement for European buyers. A good business plan is essential for all responsible tourism businesses and a professional suppliers of tourism services.

Sustainable business practice

Sustainability is becoming normal practice throughout the tourism industry. If you do not make it part of everything you do, European tour operators will not do business with you. More and more tourists, too, are concerned about their carbon footprint when they travel. And they want to minimise their impact on the environment, and maximise benefits to local people and places. Sustainability certification is not yet compulsory in the tourism industry, but it may be in a few years’ time.

The best thing you can do, then, is to be certified as a sustainable tourism business. That shows European tour operators that you share their values and understand the urgent need to work sustainably. There are many certification schemes for you to consider. These include global schemes like Travelife, used all over the world, and regional or national ones like CST in Costa Rica.

Many of these schemes are recognised by or accredited by the Global Sustainable Tourism Council (GSTC). Accredited schemes are the top level. The GSTC establishes and manages global sustainable standards, known as GSTC Criteria. Industry Criteria are for tour operators and hotels, in the form of guiding principles and minimum requirements that they should observe in order to protect and sustain natural resources.

Table 1: Examples of GSTC-recognised sustainable certification schemes

Title Details and approximate cost (if available) Main European markets Further information

EarthCheck

 

EarthCheck supports tourism businesses, accommodation providers, tour operators and destinations to become more sustainable through certification, consulting and training.

Cost: from €3,800.

Global scheme, widely used across Europe. EarthCheck certification
Good Travel Seal

A more affordable scheme, aimed at small and medium-sized enterprises (SMEs) and family-run businesses. Part of the Good Travel Guide sustainable travel platform, which promotes destinations and businesses to responsible travellers. The seal has three levels, based on compliance score.

Cost:

Micro (1-5 employees) – from €100 per year;

Small (6-10) – from €250;

Medium (11-30) – from €400 per year.

Global scheme, particularly widely recognised in the Netherlands and Slovenia. Good Travel Seal – Affordable seal of approval
Green Key

Aimed at accommodation providers of all sizes.

Cost: from €500.

Global scheme, widely used in Europe – especially Belgium, Denmark, Finland, France, Greece, the Netherlands, Portugal and Sweden. Green Key global criteria

TourCert

 

Promotes responsible tourism and operates an affordable sustainable certification scheme for tourism businesses and destinations.

Cost: €250-450 to become qualified; from €900 to become certified.

Germany and, Austria; now expanding into Latin America and beyond. TourCert certification

Travelife

 

Affordable scheme with three levels of sustainability commitment: Engaged, Partner and Certified. It has two variants, one for tour operators and the other for accommodation providers.

Cost for tour operators: 

Engaged – €200-400 per year; Partner – €200-400 per year; Certified – €400-2,000 per year.

Cost for accommodation providers:

€640-2,150, depending upon size of business.

Global scheme, particularly widely recognised in the UK, Germany and the Netherlands.

Travelife for tour operators

Travelife for accommodation providers

Source: Acorn Tourism Consulting

European tour operators know that certification can be expensive for small businesses. But they still want to be sure that the suppliers they work with are doing all they can to be sustainable. If you cannot afford to be certified at the moment, you should still be as sustainable as you can. The actions you take must be measurable, and you should tell everyone what you are doing.

Tips:

A good business plan

A business plan is a useful tool for any company, small or large. So you should have one. The plan is a written document that outlines your business objectives and states how you intend to achieve them. Essentially, it is your three to five-year plan of action. You should keep it under constant review.

A good business plan has seven main sections.

  1. Executive summary. A brief digest of the plan. Although it comes first in the document, you should write it last – once the rest of the plan is in place. This is the most important section, because sometimes potential investors or partners use it to decide whether to work with you.
  2. Company overview. What your business does. This is like the “About” section of your website. Describe your vision and/or mission for your business, who owns and manages it, where it is based and, briefly, its current assets and debts.
  3. Operations plan. Information about your day-to-day operations: the tours/experiences you offer, where they go, what they include and so on.
  4. Market analysis. Details of your target market and major competitors. Plus information relevant to the local market, such as new developments or emerging trends.
  5. Implementation plan. How you bring your product(s) to the market. Include a SWOT analysis (strengths, weaknesses, opportunities, threats), a marketing plan (online and offline) and pricing strategies.
  6. Team summary. Your current and future staffing needs and training processes.
  7. Financial plan. Your income statement, cashflow forecast and balance sheet.

Tips:

Practise responsible tourism

Responsible tourism is closely linked to sustainable tourism. It is all about adopting responsible (or ethical) business practices, particularly when it comes to the protection and welfare of children, wildlife preservation, environmental protection and overtourism. Draw up – and implement – a responsible tourism policy to reassure customers that you are an ethical tour operator. See this example from Msafiri Tours in Uganda.

Many European tour operators have signed up to The Code. This is an industry-driven initiative to fight the sexual exploitation of children in tourism. One example of the Code’s effect in practice is a ban on orphanage tourism. Visits to orphanages in developing countries are increasingly seen as a form of child exploitation. There are many reported cases of children being kept in poor conditions and denied food, clothing and other essentials in order to extract more money from visitors. Many European tour operators have removed trips to orphanages from their itineraries altogether.

Conserving wildlife is another important issue for the tourism industry. Wildlife attractions that promise close animal interactions, such as touching or riding wild animals, are considered harmful for the animals’ welfare and species conservation. So do not offer experiences of this kind. Responsible European tour operators expect their suppliers to adhere to this rule.

Overtourism occurs when too many people visit a particular destination. That harms its environment and the quality of life for local people. European tour operators are very aware of the negative effects of overtourism. In any case, more and more travellers are choosing to avoid very touristy places.

You need to understand the impact of overtourism on your destination, and take measures to prevent it. They can include encouraging tourists to visit other sites and to come in different seasons.

Tips:

Adopt a code of conduct

In tourism, a supplier code of conduct is a set of guidelines that state what tour operators expect from their suppliers. It is closely linked to responsible tourism. Tour operators use their code when assessing new suppliers, to ensure that they are able to meet the required standards. And you should have a code of your own, setting out your commitment to being a responsible and sustainable business. It should include the following topics.

  • Ethical business practices. How you support local people and locally owned businesses. How you prevent the exploitation of vulnerable people like children and indigenous populations. And how you promote responsible wildlife tourism practices.
  • Environmental sustainability practices. How you protect the natural environment.
  • Social responsibility. How you work with your own staff to improve their health and well-being, be inclusive, promote diversity and avoid discrimination.
  • Health and safety. How you manage the safety of both your guests and your staff.

Tips:

  • Study TUI’s Supplier Code of Conduct to help develop yours. That document is very detailed and gives you a good idea what European buyers expect from local suppliers.
  • You can include your code of conduct in your responsible tourism policy.

Promote your business as a professional supplier

European tour operators have to meet their customers’ needs in a professional way. They always monitor satisfaction through feedback surveys. Tourists travelling overseas want to feel protected and safe when they book a trip or excursion. They rely heavily on “word-of-mouth” recommendations on social media and review platforms like Tripadvisor. Many European tourists like to share their experiences, whether good or bad. A negative review can affect the tour operators’ reputation.

Many European tour operators work with destination management companies (DMCs). They are responsible for ensuring that all their local suppliers comply with the client’s requirements. If you sell your tours through a DMC, it will help you build your professional profile.

Being a member of a national and/or international tourism association also helps to boost your reputation, with both DMCs and European tour operators. Your national tourist board or association is a good place to start. The Adventure Travel Trade Association (ATTA) is a global membership organisation for adventure travel companies, including tour operators. Joining an organisation like this can help you promote your business to a wider audience.

Like other associations of this kind, the ATTA has several membership levels. The most basic is Community Membership, which is free. That gives you access to some free research and webinars. Professional Membership costs US$150 (€139), but provides more benefits. They include discounts on training courses. Explore the available options to see which suits you best.

Membership of associations can bring other benefits, too.

  • Networking opportunities with similar operators, other professionals in the industry and potential clients.
  • Access to industry intelligence and events to keep up with new trends.
  • Added recognition through awards programmes.

Tips:

  • Research tourism associations in your country and internationally, and decide which are most suitable for your business. Contact them to find out how you can become a member.
  • Be sure to promote your membership(s) on your website.
  • Ask for customer testimonials, reviews, photos and videos, and share them on your website.
  • Conduct regular customer satisfaction surveys.

3. What are the requirements and certifications for tourism niche markets?

A number of standards, certification schemes and best practices cover the tourism sector. Although none of these are mandatory for local tour operators, complying with as many as possible puts you be in a better position to do business with the European market.

ISO standards

Niche tourism segments like adventure tourism, diving, sailing and wellness can benefit from complying with internationally recognised standards. ISO (the International Organisation for Standardisation) is an independent non-governmental body. It publishes more than 19,500 standards, all of which have been agreed internationally by experts. Their purpose is to help businesses develop their product or service in the best way possible. Standards can help small businesses to:

  • build confidence that their product is safe and good quality;
  • comply with regulations at a lower cost;
  • reduce costs;
  • reach new markets all over the world.

Standards are developed with a focus on different factors, like quality management, environmental management, social responsibility and sustainability. Each standard is given a number (e.g. ISO 20410) followed by the year it was published (e.g. 2017), so that you can see how recently it was created. Consult the table below to see if any of the listed standards are relevant to your business.

Table 2: Standards relating to tourism

Standard Type and price Details
ISO 3021:2023 Adventure tourism - Hiking and trekking

Requirements and recommendations

Price: €149.

Requirements for tourism activities involving hiking and trekking, concerning:

  • the safety of participants, leaders and assistants;
  • criteria for classifying difficulty of routes.
ISO 21101:2014 Adventure tourism – Safety management requirements

Requirements

Price: €127.

Requirements needed to:

  • enhance safety performance;
  • meet safety expectations;
  • demonstrate safe practices;
  • support legal compliance.
ISO 21101 Adventure tourism – Safety management systems – A practical guide for SMEs

Practical guide

Price: €41.

Step-by-step guidance and examples for SMEs in adventure tourism to implement a safety management system.
ISO 21103:2014 Adventure tourism – Information for participants

Requirements

Price: €41.

  • Minimum requirements for participant information to be provided before, during and after an adventure tourism trip.
  • Suitable for all types of provider, small and large, in different geographical, cultural and social environments.
ISO 20611:2018 Adventure tourism – Good practices for sustainability

Requirements and recommendations

Price: €63.

  • Requirements and recommendations for adventure tourism providers concerning good practices for environmental, social and economic sustainability.
  • Suitable for all types of provider, small and large, in different geographical, cultural and social environments.
ISO 24803:2017 Requirements for recreational diving providers

Requirements

Price: €63.

Requirements for providers of recreational scuba diving and snorkelling excursions, concerning:

  • introductory diving activities;
  • snorkelling excursions;
  • training and education;
  • organised and guided diving for qualified divers;
  • rental of diving and snorkelling equipment.

ISO 13810:2022 Visits to industrial, natural, cultural and historical Sites

 

Requirements and recommendations

Price: €63.

  • General requirements and recommendations for providers of guided or self-guided visits to learn:
  • about the characteristics of cultural, historical or natural value of a site;
  • how a product/activity is developed now or was developed in the past.

                       

  • Applies to visits, equipment and operations that can affect the quality and safety of the experience.
ISO 18065:2015 Tourist services for public use provided by Natural Protected Areas Authorities

Requirements

Price: €94.

Requirements for tourist services provided by an NPAA to be suitable for visitors and also satisfy NPA conservation objectives.
ISO 13009:2016 Beach operation

Requirements and recommendations

Price: €149.

  • General requirements and recommendations for beach operators providing tourist and visitor services.
  • Includes guidance around sustainable management and infrastructure, beach safety, cleaning and waste.

ISO 20410:2017 Bareboat charter

 

Minimum service and equipment requirements

Price: €94.

 

Minimum service level and equipment requirements for providers of bareboat charters on inland, coastal and offshore waters.

ISO 22876:2021 is a supplementary standard covering additional services and experiences offered by boat providers with on-board accommodation facilities.

ISO 17679:2016 Wellness spa

Service requirements

Price: €94.

Service requirements for a wellness spa, supporting processes and quality of service.  
ISO 21902:2021 Accessible tourism 

Requirements and recommendations

Price: €213.

Requirements and guidelines to help create “accessible tourism for all”. 

Source: ISO 2023

ISO standards can be expensive to comply with. After buying the standard itself and implementing its requirements, if you choose to become ISO certified you will have to pay to be audited. This can cost €4,500 or more. Certification is not obligatory, however. The benefit of buying a standard is that you know what is required and can adjust your business practices accordingly. Once you are ready, you can tell your buyers that you comply with or follow the standard. Being audited and certified as a next step will add trust and provide additional benefits to your company.

Standards for adventure tourism in the UK

Many countries have their own standards organisations, which publish local standards in collaboration with the ISO. ISO 21101:2014, for example, has been adapted for the UK market by the BSI, the UK’s national standards body. It is known there as the British Standard for Adventure Tourism (BS8848:2014). This was established to minimise the risks of adventure travel. It is specifically aimed at UK tour operators and providers of adventure holidays abroad.

Many UK adventure tour operators comply with BS8848. They want to give their customers peace of mind across all the activities they offer, so that adventure travellers feel safe and well-looked after. British adventure tour operators usually expect their suppliers to conform with BS8848 as well.

Sustainability standards for adventure tourism

In 2022 Travelife and its partners, including the Adventure Travel Trade Association (ATTA), released 38 activity sustainability standards for the tour operator industry. These are a compilation of best practices for activities including community-based tourism (CBT), wildlife tourism, mountain biking, hiking and trekking, plus many more. The aim is to make it easier for tour operators to be sustainable businesses that help the tourism sector globally meet its sustainability commitments.

The best practices are arranged by topic in the form of useful, practical tips, and they are free to all. But you do have to sign up as a member of ATTA to download the standards (membership is also free!).

Figure 3: Volunteer tourism – example from ATTA’s Sustainability Code of Best Practice

A picture containing text, screenshot

Description automatically generatedSource: ATTA

Green Fins membership for diving businesses

Diving businesses, including dive centres, snorkelling centres and liveaboards, should be responsible and sustainable suppliers. Green Fins is a membership organisation that promotes sustainable diving. It encourages divers, snorkellers, the diving industry and coastal communities to implement environmentally friendly practices to reduce the negative impact on coral reefs.

Figure 4: Benefits of Green Fins membership

Benefits of Green Fins membership

Source: Green Fins

Green Fins has two types of certification.

  • Certified membership – for dive businesses based in countries where Green Fins operates. Currently these are Antigua and Barbuda, Costa Rica, the Dominican Republic, Egypt, Indonesia, Japan, Malaysia, the Philippines and Thailand. Dive businesses are assessed in person every year. Businesses pay what they can afford.
  • Digital membership – for dive businesses in other countries, where there is no Green Fins operation. Digital membership involves annual online self-evaluation. You pay a US$140 initial fee to join and an annual renewal fee of US$60.

Animal Protection Network for wildlife tourism businesses

The Animal Protection Network (APN) operated by ANIMONDIAL helps wildlife tourism businesses to protect animals and to restore and enhance nature. If you have a wildlife tourism experience and comply with the regulations, you can apply to join the network. It is free at the basic level, and you can display the seal on your website. Membership will impress and reassure European buyers, both tour operators and independent travellers.

Figure 5: Animal Protection Network seal

Animal Protection Network seal

Source: ANIMONDIAL

Tips:

Practical tips to ensure duty of care in adventure tourism

Adventure tourism involves an element of risk. Participants like experiences that are thrilling and exciting. But operators of these experiences must take reasonable care during potentially dangerous activities. If you fail to comply with this duty of care, you may be held liable for negligence. In practice, this means that you must:

  • maintain and replace equipment regularly, so that it is always in good condition;
  • host the activity or tour in a place appropriate for the experience;
  • make sure that the activity is appropriate for the participants’ level of skill ;
  • make sure that activities are well-supervised;
  • make sure that your staff are properly qualified;
  • make sure that you have staff qualified in first aid, and that you have the correct certifications and medical assistance;
  • restrict access to dangerous areas or activities that are not within the scope of your tour.

Tips:

  • Conduct an honest assessment of your compliance with the requirements above. How many of them are you fulfilling to a high level? Make changes where you can.
  • Read the CBI study How to manage risks in tourism?

Understand customer needs across niche tourism segments

The tourism industry comprises many niche segments that attract travellers with different needs, wishes and expectations. Understand what your customer wants so that you can take steps to meet these needs. Here are some examples.

  • Community-based tourism (CBT) customers are looking for an authentic experience and enjoy an immersive experience with local communities. They need to feel that they are making an important contribution to local people’s lives. This includes financial benefits, but also mutual bonding and each learning something about the other.
  • Volunteer tourists are keen to make a positive impact on the communities they are supporting. Examples include building amenities, conservation and teaching.
  • Adventure tourists are keen to have a fulfilling experience. What that is can vary widely, from physical challenges to nature and wildlife experiences to cultural activities. Adventure tourism packages usually involve at least two activities of this kind.
  • Wildlife tourists like to see positive animal welfare and habitat conservation in practice.
  • Bird watchers choose destinations where bird life is plentiful and varied, especially specific bird groups and endemic species.
  • Divers like to visit pristine sites with plenty of marine life. They do not want places that are overcrowded with other divers. They appreciate sustainable diving practices like no touching and taking care around coral.

Tips:

This study was carried out on behalf of CBI by Acorn Tourism Consulting.

Please read our market information disclaimer.

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Suppliers that have international representation or affiliations in relation to their niche market offering will better differentiate themselves. These partnerships give travel agents like us reassurance that a product or experience is suitable for that the specific market. The use of international representation can also help you build better relationships within the specific target countries and build greater awareness.

Molly Kinnaird

Molly Kinnaird, Head of Europe, True Travel

 

A sustainable destination aims to create an attractive destination for visitors, residents and local businesses that is respectful of local culture, traditions, heritage and the environment. This cannot be achieved without collaboration between the different stakeholders of the destination. In the best examples, the destination is a synergy between the leadership provided by the destination management and the engagement from local businesses, so both are working together towards the same goals.

Louise de Hemmer

Louise de Hemmer, Green Destinations Top 100