SANT DALMAI, S.A.U. (hereinafter, SANT DALMAI and/or the "Company") was founded in 1964 as a project to convert a small delicatessen products workshop into what today, more than 50 years later, is a modern factory with the most advanced process technology, as well as a robust traceability and food safety system. It has a team of more than 150 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 sets out the principles, criteria and rules of conduct by which all members of the organisation must be governed in the development of their professional activities, constituting, consequently, a basic pillar of the company's compliance programme, which promotes and reflects a positive corporate culture.
Through this Code, the organization intends to establish the principles and values that must govern the actions of the Company and all its employees, in order to ensure professional, ethical and responsible behavior. Likewise, this Code of Ethics must also be a reference for all third parties who have a relationship, collaborate or contract with SANT DALMAI.
This Code is based on basic values and principles, improves the reputation of the entity, gives unity and coherence to the organization's self-regulation system, strengthens the sense of belonging to a group in the workforce and signals 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 for preventing irregular and improper conduct that may give rise to the criminal liability of the organization.
This Code will be developed through policies, protocols and other internal rules.
The principles and guidelines of conduct contained in this Code of Ethics are mandatory for all employees, directors and administrators of the organization, regardless of their hierarchical level, and even for third parties such as collaborators, suppliers and customers and any other person or company with which SANT DALMAI has strategic relations. business, commercial or legal. External advisors, self-employed workers and temporary staff who have a contractual relationship with the organisation will also be bound by this Code.
1.- RESPECT FOR LEGALITY, HUMAN RIGHTS AND ETHICAL VALUES
In its activity, SANT DALMAI will always maintain an ethical and socially responsible behaviour, which must be present in all its decisions and actions, with special respect for human rights, labour rights and people's freedoms, recognised in national and international legislation.
The persons 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 reporting channels made available to them and 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 the spirit and purpose of the same, and observing ethical behavior in all their actions.
Likewise, SANT DALMAI will respect and abide by the judicial or administrative decisions that affect it, but reserves the right to oppose and appeal to as many possible and appropriate instances as it may be when it does not agree with them.
2.- PERFORMANCE OF AN UPRIGHT CONDUCT
The conduct of the Company's staff, management and administration must conform to the following guiding criteria:
3.- RESPECT FOR PEOPLE
The organization will avoid any type of discrimination, harassment, intimidation, abuse or lack of respect, and any type of physical or verbal aggression is intolerable. The organization will take appropriate and appropriate action in the event of any such situation, including disciplinary action. Any notification of harassment or discrimination will be subject to a prompt and thorough investigation, maintaining the utmost confidentiality.
Any retaliation against persons who report such situations or who cooperate in their investigation will be inadmissible, resulting in the adoption of disciplinary measures in the event of such a situation.
The organization will guarantee equal opportunities, professional development and non-discrimination in both access to and promotion in work.
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.
The hiring of foreigners will be carried out in accordance with current legislation. The organization will not discriminate against foreigners on the basis of their country of origin and will recognize their rights and obligations.
The organization shall not promote or encourage, directly or indirectly, the illegal trafficking or clandestine immigration of persons, nor shall it intimidate, deceive or abuse foreign persons.
The organization respects the personal and family life of its employees, which is why 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.
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, employees undertake to make responsible use of the media, computer systems and, in general, any other means that the organization makes available to them in accordance with the policies and criteria established for this purpose. 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 control rights.
SANT DALMAI undertakes not to disclose the 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 decisions. Under no circumstances may the personal data of employees be processed for purposes other than those provided for by law or contract.
Anyone who, as a result of their activity, accesses the personal data of other employees undertakes in writing to maintain the confidentiality of such data.
The Compliance Body, the Head of the Internal Information System (Ethics Channel) and other corresponding bodies will comply with the requirements set forth in the regulations on the protection of personal data and the protection of reporting persons with respect to communications sent to them by employees.
SANT DALMAI, both in its 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 Regulation (EU) 2016/679 of the Parliament and of the Council of 27 April 2016, on the protection of natural persons with regard to the processing and free movement of personal data, as well as the national regulations in force at any given time on data protection.
The training of employees will be promoted in all matters related to their activity within the Company and, especially, in terms of food safety, occupational safety and prevention of occupational risks and self-protection and crime prevention, through training programs in line with the achievement of the organization's objectives.
Employees must commit to continuously updating their technical and managerial knowledge and taking advantage of the organization's training programs.
Employees, regardless of their rank or function, will avoid situations that conflict their personal interests with those of the organization. In this sense, they may not use their position in the organization to obtain particular advantages or business opportunities, or provide services to competing companies.
10. CORRUPTION PREVENTION. GIFTS & GIVEAWAYS
SANT DALMAI will establish the necessary controls to prevent corruption in its organization, both in dealing with private entities and in dealing with public administrations and civil servants.
Employees of SANT DALMAI may not give or accept gifts or gifts in the course of their work. Exceptionally, and as long as the applicable legislation permits, the delivery and acceptance of gifts or gifts will be permitted when the following circumstances occur simultaneously:
When there are doubts about what is permissible 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 customers (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, made in cash or with bearer cheques or similar means, as well as on all payments made to entities with bank accounts opened in tax havens or all those collections from such bank accounts.
12.- CORPORATE IMAGE AND REPUTATION
All employees and managers of SANT DALMAI must take the utmost care to preserve the good image and reputation of the Company in all their work activities.
A. COLLECTIVE SAFETY AND PUBLIC HEALTH
The organisation ensures the prevention and control of activities and actions that may affect public health and collective safety, so the development of its business activity is focused on the principles of maximum safety and protection of consumer health.
In this regard, SANT DALMAI establishes and will establish controls on 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.
The organisation is committed to ensuring respect for the environment, minimising the environmental impact in all its activities and disseminating 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, waste, gases 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 functions efficiently, safely and in a healthy environment. Consequently, all staff must be aware of and comply with the rules for the protection of health and safety at work and ensure the safety of themselves, their colleagues, customers, suppliers, collaborators and, in general, of all those who may be affected by the development of their activities.
Likewise, it will promote that the companies and people with which it operates and maintains relations comply with its standards and programs in the field of safety and health at work and will coordinate prevention policies and protocols with such companies and individuals when appropriate.
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 demands. The organization is fully committed to the regulations and quality requirements demanded within the sector, consequently, SANT DALMAI has the IFS Food 7 Certification, one of the most demanding certifications in food safety, audited annually since 2004.
The organization's quality policies and management systems are designed to drive and control activities and processes throughout the supply chain.
The members of the staff are forbidden to reveal, disseminate or transfer any type of industrial secret, either of SANT DALMAI or of their previous workplaces, nor may they seize any type of written or electronic document or electronic media that are confidential or secret.
The organisation is opposed to all types of behaviour, both its own and those of collaborating companies, that are aimed at criminal actions in relation to trade and transport of goods; as well as any unfair competition or misleading advertising practices.
SANT DALMAI will behave legally, loyally and transparently with its clients, always acting under the principle of good faith and always respecting the terms and conditions of agreements and contracts.
To attract customers, SANT DALMAI will not use deception, or any unfair action or action contrary to current legislation or internal regulations.
SANT DALMAI will select its suppliers according to objective and impartial criteria and will avoid any unjustified favoritism based on business criteria in their selection.
SANT DALMAI will behave legally, loyally and transparently 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 Company's employees to the suppliers shall be truthful and without misrepresentation.
SANT DALMAI undertakes to compete in the markets fairly, not illicitly using the secrets of other competing companies, or misleading advertising about its products or services, or denigrating the products or services of competitors.
Obtaining information from third parties, including competitor information, will inexcusably be done in a lawful manner.
In any case, free competition will be respected and promoted, for the benefit of the market and consumers.
Relations with authorities, regulatory bodies and public administrations will be based on the principles of cooperation and transparency.
The economic and financial information, especially the annual accounts, shall 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 programmes and actions with employees, customers, suppliers and all stakeholders with whom it interacts.
Likewise, SANT DALMAI expresses its firm commitment to the principles of the policy for the prevention of crimes, against fraud and, in particular, to the non-performance of practices that may be considered irregular in the development of its relations with customers, suppliers, competitors, authorities, etc.
In any case, SANT DALMAI's activity will always be governed by a desire to comply with regulations and in no case will behaviour that implies infringement or fraud of the law be tolerated.
V. ETHICS CHANNEL AND SANCTIONING PROCEDURE
The body responsible for ensuring compliance and dissemination of this Code among all the company's 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.
SANT DALMAI, as a sign of its culture of compliance and its desire to prevent all types of risks, has equipped itself with a criminal risk prevention system, with a Compliance Manual (Compliance Policy) and internal regulations that develop it, as well as a Compliance Body to supervise its effectiveness.
SANT DALMAI will train and raise awareness among its employees on the use of the Ethics Channel and on the need to report and report any conduct contrary to the Code of Ethics or the internal regulations that develop it, for the improvement of the Company and society.
Failure to comply with this Code of Ethics may lead to employment consequences, regardless of the administrative or criminal consequences that may be involved.
Any member of the organization, as well as employees, suppliers and customers, must report, in good faith and without fear of reprisals, any irregularity, non-compliance or unethical conduct of which they are aware, carried out by an employee, director or administrator of the organization.
To this end, the communication channels of the Ethics Channel are as follows:
In any investigation procedure of communications made through the Ethics Channel, compliance with the principles of objectivity, confidentiality of communications, independence, good faith and protection of personal data will be especially monitored, as well as the right to defense, honor and presumption of innocence of the persons under investigation will be guaranteed. In addition, the procedure will be transparent and will guarantee the right to information of the persons involved in it.
All communications made through the Ethics Channel will be protected by the utmost confidentiality.
KNOWLEDGE
This Code will be made known to all members of the organization, who will be obliged to attend the training sessions that are scheduled for this purpose.
The administration and management of the organization shall use all necessary means to disseminate the values and principles of the Company and to enforce the guidelines of conduct contained in this Code of Ethics.
To this end, SANT DALMAI's Code of Ethics will be publicly communicated through its website, showing the current version indicating the date of update.
INTERPRETATION
The Compliance Body shall be responsible for the interpretation of this Code of Ethics. Its interpretative criteria will be binding on the employees of the organization.
Any doubts that may arise among the organization's personnel regarding the interpretation of the Code of Ethics must be consulted with the immediate hierarchical superior according to the Company's organizational chart or, if 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 make it up govern their conduct.
In this sense, each 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 register will be kept with the conformities received from 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 solicit an employee who contravenes the provisions of this Code of Ethics.
This Code of Ethics shall enter into force on the day of its approval by the Board of Directors and shall be made known to all 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 employees and managers of the organization.
Any revision or update that involves a modification of the Code of Ethics will require approval by the Board of Directors of SANT DALMAI, following a report from the Compliance Body.
For a better understanding and interpretation of this Code of Ethics, several reference standards are listed below: