Short answer. No. It is a prohibited practice to become an officer or board member of a corporation engaged in the travel agency business, or to be engaged directly or indirectly in the management of a travel agency. The bar catches informal control, not just formal titles.
What the law says
To become an officer or member of the Board of any corporation engaged in travel agency or to be engaged directly or indirectly in the management of a travel agency
Labor Code, Article 34 — Prohibited Recruitment Practices. Read the full provision →
Two separate bars in one clause
The prohibition is to become an officer or member of the Board of any corporation engaged in travel agency or to be engaged directly or indirectly in the management of a travel agency. The first half is formal and easy to check: a name on the board, a corporate office held. The second half is functional and much harder to evade, because it asks who actually runs the travel business. Someone who holds no title but decides what the travel agency does is engaged in its management, and the word indirectly is there to say so.
The separation the Code is trying to keep
This clause is the companion to the outright ban on travel agencies recruiting for overseas employment. That ban would be easy to defeat if the same people simply ran both businesses from the same office — the recruitment side supplies the applicants, the travel side sells them the tickets and collects the money, and the fee that could not be charged for placement reappears as a fare. Keeping the personnel apart is how the separation is made real rather than nominal.
What does not save the arrangement
Three common structures are worth naming. Putting a spouse or relative on the travel agency's board while the recruitment principal continues to direct it is management exercised indirectly. Holding shares without a title, but with the power to appoint and remove the people who do hold titles, is control. And keeping the two businesses in separate registered companies changes nothing if the same person manages both, since the clause attaches to the person, not to the corporate boundary.
The question worth asking before you sign anything
If you are being invited into either business, ask who else sits on both sides and what they actually decide, and get the answer in a document rather than a conversation. If you are an applicant rather than an investor, the practical signal is simpler: the same people handling your job application and your ticket, from one office, is the arrangement this clause exists to prevent. Keep whatever you paid and to whom, and take it to a lawyer before you pay more.