CHANNEL OF ETHICS OF SANT DALMAI, S.A.U.
Sant Dalmai February 16, 2022
I.INTRODUCTION
SANT DALMAI, S.A.U. (hereinafter, SANT DALMAI and/or the “Company”) was founded in 1964 as a project to convert a small delicatessen workshop into what is now, almost 60 years later, a modern factory. that has the most advanced technology in processes, as well as a robust traceability and food safety system. It has a team of more than 200 people focused on detecting and meeting the needs of customers and consumers, continuously adapting the lines and processes for this purpose.
This Code of Ethics includes the principles, criteria and rules of conduct by which all members of the organization must abide in the development of their professional activities, thus constituting a basic pillar of the company's compliance program, which promotes and reflects a positive corporate culture.
Through this Code, the organization intends to establish the principles and values that should govern the actions of the Company and all its employees in order to ensure ethical and responsible professional behavior. Likewise, this Code of Ethics must also be a reference for all those third parties that have a relationship, collaborate or contract with SANT DALMAI.
This Code is based on basic values and principles, improves the entity's reputation, gives unity and coherence to the organization's self-regulatory system, strengthens the sense of belonging to a group in the workforce and points out the Company's corporate culture to third parties. .
This Code takes into account the principle of criminal liability of legal persons and serves as a basis to avoid irregular and improper behavior that may determine the criminal liability of the organization.
This Code will be developed through policies, protocols and other internal regulations.
II.ÁMBITO DE APLICACIÓN
The principles and guidelines of conduct contained in this Code of Ethics are mandatory for all employees, managers and directors of the organization, regardless of their hierarchical level, and even for third parties such as collaborators, suppliers and customers. and any other persons or companies with which SANT DALMAI has strategic, business, commercial or legal relations. External advisors, self-employed workers and temporary staff, who have a contractual relationship with the organization, will also be bound by this Code.
III. ETHICAL PRINCIPLES OF CONDUCT
1.- RESPECT FOR LEGALITY, HUMAN RIGHTS AND ETHICAL VALUES
SANT DALMAI will always maintain ethical and socially responsible behavior in its activities, which must be present in all its decisions and actions, with special respect for human rights, labor rights and personal freedoms, recognized in national and international legislation.
The people included in the scope of application of this Code undertake to comply with the laws in force at all times, the internal procedures of the organization and the values and principles contained in this Code.
Likewise, they undertake to report any non-compliance that they detect around them, through the ethical or complaint channels made available to them and which are detailed in point V of this Code.
For its part, SANT DALMAI undertakes to comply with and integrate as internal regulations the provisions of national or international standards and agreements that, due to the activity carried out by the company, may bind it.
In general, all the personnel of the organization must comply with the laws in force, including the internal regulations of the Company, attending to their spirit and purpose, and observing ethical behavior in all their actions.
Likewise, SANT DALMAI will respect and abide by the judicial or administrative resolutions that affect it, but reserves the right to object and appeal to as many instances as possible and appropriate when it does not agree with them.
2.- PERFORMANCE OF INTEGRATED CONDUCT
The conduct of the Company's staff, management and administration must comply with the following guiding criteria:
a.Diligence: is responsible, informed, efficient, professional action focused on compliance, excellence and quality.
b.Integrity: is the loyal, honorable, honest, objective and aligned action with the interests of the Company and with its principles and values expressed in this Code of Ethics.
c.Respect: implies having an open mind and a flexible and empathic attitude, not judging or discriminating against anyone based on their ideas or beliefs, their race, their religion, their gender, their physical characteristics or their image. Respect implies being proactive and proactive and trying to maintain cordial relations among the staff that generate a quality, healthy and safe work environment. Respect implies trying to solve conflicts in good faith and with common sense and flexibility, trying to understand the position and reasons of others.
3.- RESPECT FOR PEOPLE
The organization will avoid any type of discrimination, harassment, intimidation, abuse or lack of respect, being intolerable any type of physical or verbal aggression. The organization will take timely and appropriate measures in the event that any such situation occurs, including disciplinary measures. Any notification of harassment or discrimination will be subject to a prompt and in-depth investigation, maintaining the maximum confidentiality of the same in any case.
Any retaliation against people who report situations of this type or who collaborate in their investigation will be inadmissible, giving rise to the adoption of disciplinary measures if such a situation occurs.
4.- GENDER EQUALITY
The organization will guarantee equal opportunities, professional development and non-discrimination both in access to work and in its promotion.
In this regard, the organization will ensure the application of gender equality laws in the various functions and responsibilities of its structure and in its dealings with third parties.
5.-RIGHT OF FOREIGN PERSONS
The hiring of foreign people will be done in accordance with current legislation. The organization will not discriminate against foreigners based on their country of origin and will recognize their rights and obligations.
The organization will not promote or favor, directly or indirectly, the illegal trafficking or clandestine immigration of people, nor will it intimidate, deceive or abuse foreigners.
6.- WORK AND FAMILY CONCILIATION
The organization respects the personal and family life of its employees, for which it establishes with its staff the commitment to promote the improvement of their quality of life and that of their families.
In this regard, measures aimed at reconciling the requirements of work with the needs of their personal and family life will be encouraged.
7.- RIGHT TO PRIVACY
The organization respects the right to privacy of its employees, in all its manifestations, and especially with regard to personal, medical and economic data.
For their part, the employees undertake to make responsible use of the means of communication, of the computer systems and, in general, of any other means that the organization makes available to them in accordance with the policies and criteria established below. such effect. Such means are not provided for personal use and are therefore not suitable for private communication. In this sense, they do not generate an expectation of privacy in the event that they had to be supervised by the organization in the proportionate performance of their duties and rights of control.
SANT DALMAI undertakes not to disclose personal data of its employees, except with the consent of the interested parties and in cases of legal obligation or compliance with judicial or administrative resolutions. In no case may the personal data of employees be processed for purposes other than those legally or contractually provided.
Whoever, due to their activity, accesses the personal data of other employees, will commit in writing to maintain the confidentiality of said data.
The Compliance Body and other corresponding bodies will comply with the requirements set forth in the personal data protection legislation regarding the communications sent by the employees.
SANT DALMAI, both in relations with its employees, as well as with its collaborators, as well as in the development of its activity in general, complies and will comply with the European standards for the protection of personal data, contained in the Regulation (EU) 2016/679 of the Parliament and of the Council, of April 27, 2016, regarding the protection of natural persons regarding the treatment and free circulation of personal data, as well as the national regulations in force at any time.
8.- TRAINING
The training of employees will be promoted in all matters related to their activity within the Company and, especially in matters of food safety, safety at work and prevention of occupational risks and self-protection and crime prevention, through training programs in accordance with the achievement of the objectives of the organization.
Employees must commit to permanently update their technical and management knowledge and to take advantage of the organization's training programs.
9.- CONFLICT OF INTEREST
Employees, regardless of their rank or function, will avoid situations that entail a conflict between their personal interests and those of the organization. In this sense, they may not use their position in the organization to obtain advantages or particular business opportunities, nor provide services to competing companies.
10. PREVENTION OF CORRUPTION. GIFTS
SANT DALMAI will establish the necessary controls to avoid corruption in your organization, both in dealings with private entities and in dealings with public administrations and officials.
Employees of SANT DALMAI may not give or accept gifts in the course of their work activity. Exceptionally and as long as the applicable legislation allows it, the delivery and acceptance of gifts will be allowed when the following circumstances occur simultaneously:
a. Are of irrelevant or symbolic economic value;
b.They respond to signs of courtesy or usual commercial courtesies in the market or sector;
c. Are not prohibited by law, internal Company rules, or generally accepted business practices.
When there are doubts about what is permitted or acceptable, employees should consult with their immediate superior, who may refer the query, if deemed appropriate, to the Compliance Body or to the Company's Senior Management, as appropriate.
11.- PREVENTION OF MONEY LAUNDERING
SANT DALMAI will establish internal policies for the knowledge of its clients (KYC), to prevent and avoid, in the course of its operations, the making of irregular payments or collections or the laundering of money originating from illicit or criminal activities. The aforementioned policies will establish specific controls on those economic transactions, both collections and payments, of an unusual amount nature, made in cash or with bearer checks or similar means, as well as on all those payments made to entities with bank accounts opened in tax havens. or all those collections from said bank accounts.
12.- IMAGEN Y REPUTACIÓN CORPORATIVA
All employees, managers and directors of SANT DALMAI must take the utmost care to preserve the good image and reputation of the Company in all their work activities.
IV.COMMITMENTS
A. COLLECTIVE SAFETY AND PUBLIC HEALTH
The organization ensures the prevention and control of activities and actions that may affect public health and collective safety, for which the development of its business activity is focused on the principles of maximum safety and protection of the health of the consumers.
In this regard, SANT DALMAI establishes and will establish controls over any activity or product that may create, directly or indirectly, a risk to collective safety and public health, due to the toxicity of the components or any other threat to people or the environment.
B. RESPECT FOR THE ENVIRONMENT
The organization undertakes to ensure respect for the environment, to minimize the environmental impact in all its activities and to spread among its employees the culture of respect and protection of the environment as a principle of conduct in its actions.
In this regard, the organization establishes and will establish controls on discharges, emissions, residues, gases that are harmful to the ozone layer and/or any other environmental threat.
The organization promotes the adoption of occupational health and safety policies and adopts the preventive measures established by current legislation in order to achieve a high level of safety in its facilities and services.
In this regard, the organization will provide its staff with the necessary resources and knowledge so that they can perform their duties efficiently, safely and in a healthy environment. Consequently, the entire workforce must know and comply with the health and safety protection regulations at work and ensure their own safety, that of their colleagues, customers, suppliers, collaborators and, in general, of all those who could be affected by the development of their activities.
Likewise, it will be promoted that the companies and people with whom it operates and maintains a relationship comply with its regulations and programs in matters of safety and health at work and will coordinate prevention policies and protocols with said companies and people when appropriate.
D.MARKET AND CONSUMERS
The organization puts all its efforts into protecting consumers by producing food for their well-being and health, with the highest quality and safety. The organization incorporates the latest scientific evidence, technology and food safety trends and directs its actions to science-based health claims. The organization is fully committed to the regulations and quality requirements demanded within the sector, consequently, SANT DALMAI has the IFS Food Version 6.1 and 7 Certification, one of the most demanding certifications in food safety, audited annually since 2003 .
The organization's quality policies and management systems are designed to guide and control the activities and processes throughout the supply chain.
Staff members are prohibited from revealing, disseminating or transferring any type of industrial secret, both from SANT DALMAI and from their previous workplaces, nor may they seize any type of written or electronic document or electronic media that are confidential or secrets.
The organization is opposed to all types of behavior, both its own and that of collaborating companies, that are aimed at criminal actions in relation to trade operations and freight transport; as well as any practice of unfair competition or misleading advertising.
E.RELATIONSHIP WITH CUSTOMERS
SANT DALMAI will have a legal, loyal and transparent behavior with its clients, always acting under the principle of good faith and always respecting the terms and conditions of the agreements and contracts.
To attract customers, SANT DALMAI will not use deception, or any unfair or contrary action to current legislation or internal regulations.
F.RELATIONSHIP WITH SUPPLIERS
SANT DALMAI will select its suppliers according to objective and impartial criteria and will avoid any favoritism not justified by business criteria in its selection.
SANT DALMAI will have a legal, loyal and transparent behavior with its suppliers, always acting under the principle of good faith and always respecting the terms and conditions of the agreements and contracts.
The information provided by the employees of the Company to the suppliers will be truthful and without deception.
G.RELATIONSHIP WITH COMPETITORS
SANT DALMAI undertakes to compete fairly in the markets, not illegally using the secrets of other competing companies, nor making misleading advertising about their products or services, nor denigrating the products or services of the competition.
Obtaining information from third parties, including information from the competition, will inexcusably be carried out legally.
In any case, free competition will be respected and promoted, to the benefit of the market and consumers.
RELATIONSHIP WITH PUBLIC ADMINISTRATIONS AND SOCIETY
Relations with the authorities, regulatory bodies and public administrations will be considered under the principles of cooperation and transparency.
The economic-financial information, especially the annual accounts, will faithfully reflect the economic, financial and equity reality, in accordance with generally accepted accounting principles and applicable financial reporting standards.
SANT DALMAI expresses its commitment to the principles of corporate social responsibility as an integrating framework for its programs and actions with employees, customers, suppliers and all the interest groups with which it relates.
Likewise, SANT DALMAI expresses its firm commitment to the principles of the policy for the prevention of crimes, against fraud and, in particular, with the non-performance of practices that may be considered irregular in the development of its relationships with customers, suppliers, competitors , authorities, etc
In any case, the activity of SANT DALMAI will always be governed by a will of regulatory compliance and in no case will behaviors that imply infringement or fraud of the law be tolerated.
V. ETHICAL CHANNEL AND PUNISHMENT PROCEDURE
The body in charge of ensuring compliance and dissemination of this Code among all company personnel is the Compliance Body. This body will be responsible for receiving communications regarding complaints of non-compliance with this Code or queries about its interpretation.
- Email address: canaletico@disbasegrup.com.
- Physical mailbox in the Company's facilities.
All communications made through the Ethical Channel will be protected by the utmost confidentiality. It is preferred and recommended that the authors of the complaints identify themselves, without prejudice to the fact that it will also process anonymous complaints, for the sake of maximum prevention.
VI. KNOWLEDGE, ACCEPTANCE AND COMPLIANCE WITH THE CODE
KNOWLEDGE
This Code will be made known to all members of the organization, who will be obliged to attend the training sessions scheduled for this purpose.
The administration and management of the organization will use all necessary means to spread the values and principles of the Company and to enforce the conduct guidelines contained in this Code of Ethics.
For these purposes, the SANT DALMAI Code of Ethics will be publicly communicated through its website showing the current version indicating the update date.
INTERPRETATION
The Compliance Body will be the body responsible for interpreting this Code of Ethics. Its interpretive criteria will be binding for the employees of the organization.
Any doubt that may arise to the organization's personnel regarding the interpretation of the Code of Ethics, should be consulted with the immediate hierarchical superior according to the organization chart of the Company or, if the circumstances so require, the Compliance Body may be consulted.
ACCEPTANCE
This Code of Ethics must be expressly accepted by each of its recipients, who must expressly commit to its compliance, so that the principles and values that comprise it govern their conduct.
In this sense, each one of the members of the organization will confirm that they have had access to this Code, that they accept it and that they understand what it implies. To this end, a record will be kept of the consents received from the employees.
Employees who join or become part of the organization in the future must also expressly accept the principles and rules of conduct established in this Code of Ethics, which will be published together with the Welcome Manual.
COMPLIANCE
The organization's Code of Ethics is mandatory for all employees, managers and directors of the organization and for those third parties who have voluntarily committed to comply with it.
No member of the organization is authorized to request an employee to contravene the provisions of this Code of Ethics.
VII. APPROVAL, UPDATING AND IMPROVEMENT
This Code of Ethics will enter into force on the day of its approval by the Administrative Body and will be made known to all the members of the organization.
The Code will be reviewed and updated periodically, taking into account the annual report of the Compliance Body, as well as the suggestions and proposals made by the employees and managers of the organization.
Any review or update that entails a modification of the Code of Ethics will require the approval of the Administrative Body of SANT DALMAI, following a report from the Compliance Body.
ANNEX 1: REFERENCE STANDARDS
For a better understanding and interpretation of this Code of Ethics, several reference standards are listed below:
- Universal Declaration of Human Rights: adopted by the General Assembly of the United Nations in its Resolution 217 A (iii) of December 10, 1948.
- Convention on the rights of the child: approved as an international human rights treaty on November 20, 1989 and entered into force on September 2, 1990.
- Global Compact Principles: is a United Nations initiative created in 2001 for the responsible behavior of companies. It includes 10 principles grouped into four blocks: (i) relations with employees, (ii) human rights, (iii) environment and (iv) anti-corruption policy.
- Sustainable Development Goals (SDGs): following the agreement reached by the member states of the United Nations on September 25, 2015, 17 Sustainable Development Goals and 169 goals were defined, with the aim of achieving three major challenges in the next 15 years. years: (i) eradicate extreme poverty, (ii) combat inequality and injustice, (iii) combat climate change.
- National Business and Human Rights Action Plan: The Council of Ministers of the Spanish Government approved on July 28, 2017, an Action Plan with the aim of applying the United Nations Guiding Principles on business and human rights at the national level. .
- Modern Slavery Act 2015: On March 26, 2015, the approval of the Law against modern slavery, servitude, forced or compulsory labor and human trafficking was published in the United Kingdom, becoming a global benchmark.
- ISO 20400: First international standard on sustainable purchasing.
- UNE-ISO 37301:2021 and UNE 19601:2017: international and national standards on criminal Compliance management systems.
Drafting | Approval |
Version |
|||
Responsible body |
Date |
Responsible body |
Date |
Version |
Date |
Compliance Officer |
14/09/21 |
Administration Body |
16/02/22 |
1.0 |
16/02/22 |
HISTORY OF VERSIONS
Version |
Fecha de elaboración |
Author |
Description of the modification |
v.1 |
september 14 2021 |
Compliance Body: Compliance Officer |
Creation of a new Code of Ethics |
HISTORY OF APPROVALS BY THE ADMINISTRATION
Version |
Approval date |
Approved by |
Phisical Person |
v.1 |
Frebrary 14 2022 |
Sole administrator: DISBASE, S.L. |
Èric Panella Matamala |