CODE OF ETHICS OF SANT DALMAI, S.A.U.
SANT DALMAI, S.A.U. (hereinafter, SANT DALMAI and/or the "Company") was founded in 1964 as a project to convert a small workshop of products for the delicatessen into what, today, almost 60 years later, is 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 be governed in the development of their professional activities, constituting, consequently, 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 must 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 reputation of the entity, gives unity and coherence to the self-regulation system of the organization, strengthens the sense of belonging to a group in the workforce and points out to third parties the corporate culture of the Company.
This Code takes into account the principle of criminal liability of legal persons and serves as a basis for avoiding irregular and improper conduct that may determine the criminal liability of the organization.
This Code will be developed through policies, protocols and other internal standards.
The principles and guidelines of conduct contained in this Code of Ethics are mandatory for all employees, directives and managers and administrators of the organization, regardless of their hierarchical level, and even for third parties such as collaborators, suppliers and customers and any other people or companies with which SANT DALMAI has strategic relationships, business, commercial or legal. External advisors, self-employed workers and temporary staff, who have a contractual relationship with the organization, will also be linked to this Code.
1.- RESPECT FOR LEGALITY, HUMAN RIGHTS AND ETHICAL VALUES
SANT DALMAI in its activity will always maintain an ethical and socially responsible behavior, which must be present in all its decisions and actions, with special respect for human rights, labor rights and freedoms of people, recognized 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 breach that they detect around them, through the ethical or complaint 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 in all their actions an ethical behavior.
Likewise, SANT DALMAI will respect and abide by the judicial or administrative resolutions that affect it, but reserves the right to file opposition and appeal to as many instances as possible and appropriate when it does not agree with them.
2.- PERFORMANCE OF AN INTEGRAL CONDUCT
The conduct of the staff, management and administration of the Company must comply with the following guiding criteria:
- Diligence: is responsible, informed, efficient, professional and focused on compliance, excellence and quality.
- Integrity: is the loyal, honest, honest, objective and aligned with the interests of the Company and with its principles and values expressed in this Code of Ethics.
- Respect: implies having an open mind and a flexible and empathetic attitude, not judging or discriminating against anyone because of their ideas or beliefs, their race, their religion, their sex, their physical characteristics or their image. Respect implies being proactive and proactive and trying to maintain cordial relationships between 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 shall take timely and appropriate measures in the event of any such situation, including disciplinary measures. Any notification of harassment or discrimination will be subject to a prompt and thorough investigation, maintaining in any case the maximum confidentiality of the same.
Any retaliation against persons who report such situations or who cooperate in their investigation shall be inadmissible, leading to disciplinary action if such a situation occurs.
The organization will guarantee equal opportunities, professional development and non-discrimination both in access to work and in promotion in it.
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 done in accordance with current legislation. The organization shall not discriminate against foreigners in the country of origin and shall recognize their rights and obligations.
The organization shall not promote or encourage, either 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, so 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 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 case 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 foreseen.
Whoever, due to their activity, accesses personal data of other employees, will undertake in writing to maintain the confidentiality of such data.
The Compliance Body, the Head of the Internal Information System (Ethical 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 the 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 of protection of personal data, contained in Regulation (EU) 2016/679 of the Parliament and of the Council, of April 27, 2016, on the protection of individuals with regard to the processing and free movement of personal data, as well as the national legislation in force at any 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, safety at work and prevention of occupational risks and self-protection and crime prevention, through training programs in line with the achievement of the objectives of the organization.
Employees must commit to continuously updating their technical and managerial knowledge and to taking advantage of the organization's training programs.
Employees, whatever their rank or function, will avoid situations that involve a conflict of their personal interests with those of the organization. In this sense, they will not be able to use their position in the organization to obtain particular advantages or business opportunities, nor provide services to competing companies.
10. PREVENTION OF CORRUPTION. GIFTS AND GIFTS
SANT DALMAI will establish the necessary controls to avoid corruption in its organization, both in dealing with private entities, and in dealing with public administrations and officials.
The employees of SANT DALMAI will not be able to give, nor accept gifts or gifts in the development of their work activity. Exceptionally and as long as permitted by applicable law, the delivery and acceptance of gifts or gifts will be allowed when the following circumstances occur simultaneously:
- Are of irrelevant or symbolic economic value;
- Respond to signs of courtesy or usual commercial attention in the market or sector;
- Are not prohibited by law, the Company's internal rules or generally accepted business practices.
When there are doubts about what is allowed or acceptable, employees should consult with the immediate superior, who may refer the query, if he deems appropriate, to the Compliance Body or to the Senior Management of the Company, 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 realization of irregular payments or collections or the laundering of money originating in illicit or criminal activities. The aforementioned policies will establish specific controls on those economic transactions, both collections and payments, of an unusual 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.- CORPORATE IMAGE AND REPUTATION
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 actions.
A. COLLECTIVE SECURITY AND PUBLIC HEALTH
The organization ensures the prevention and control of activities and actions that may affect public health and collective security, 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 security and public health, due to the toxicity of the components or any other threat to people or the environment.
The organization is committed to ensuring respect for the environment, minimizing 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 know and comply with the rules of protection of health and safety at work and ensure the safety of themselves, their colleagues, customers, suppliers, collaborators and, in general, all those who may 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 standards and programs in the field of safety and health at work and will coordinate prevention policies and protocols with said companies and people 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 conduct and control activities and processes throughout the supply chain.
The members of the staff are prohibited from disclosing or disseminating or transferring any type of industrial secret, both of SANT DALMAI and its previous workplaces, nor may they seize any type of written or electronic document or electronic supports that are confidential or secret.
The organization is against all types of behavior, both its own and that of collaborating companies, that are aimed at criminal actions in relation to trade and transport of goods; as well as any practice of unfair competition or misleading advertising.
SANT DALMAI will behave legally, loyally and transparently with its customers, 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 contrary to current legislation or internal regulations.
SANT DALMAI will select its suppliers according to objective and impartial criteria and will avoid any favoritism not justified in business criteria in its 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 agreements and contracts.
The information provided by the Company's employees to suppliers will be truthful and without deception.
SANT DALMAI undertakes to compete in the markets in a fair manner, not using illegally secrets of other competing companies, nor making misleading advertising about its products or services, nor denigrating the products or services of the competition.
The obtaining of information from third parties, including information from the competition, will be done inexcusably in a legal manner.
It will be respected in any case and free competition will be promoted, for the benefit of the market and consumers.
Relations with authorities, regulatory bodies and public administrations will be raised under the principles of cooperation and transparency.
The economic-financial information, especially the annual accounts, will faithfully reflect the economic, financial and patrimonial reality, in accordance with the generally accepted accounting principles and the financial reporting standards that are applicable.
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 stakeholders with whom 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 desire for regulatory compliance and in no case will behaviors that imply infringement or fraud of law be tolerated.
V.ETHICAL CHANNEL AND SANCTIONING PROCEDURE
The body responsible for ensuring compliance with and dissemination of this Code among all company personnel is the Compliance Body. This body shall be responsible for receiving communications relating to complaints of non-compliance with this Code or consultations on its interpretation.
SANT DALMAI, as a sign of its culture of compliance and its willingness 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 sensitize its employees on the use of the Ethical Channel and on the need to communicate 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 entail labor consequences, regardless of the administrative or criminal consequences that may imply.
Any member of the organization, as well as collaborators, suppliers and customers, must report, in good faith and without fear of reprisal, any irregularity, breach or unethical conduct of which they are aware, carried out by an employee, manager or directive or administrator of the organization.
For these purposes, the communication channels of the Ethical Channel are the following:
- Via the email address: canaletico@disbasegrup.com
- Via postal mail to the following address: Afores s/n, 17183 Sant Dalmai (Vilobí d'onyar), Girona (to the exclusive attention of the System Manager (Ethical Channel) of DISBASE) or;
- By requesting a face-to-face meeting with the Head of the System (Ethical Channel) of DISBASE.
In any investigation procedure of communications made through the Ethical 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 shall be transparent and shall guarantee the right to information of the persons involved in it.
All communications made through the Ethical 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 will put all the necessary means to disseminate the values and principles of the Company and to enforce the guidelines of conduct contained in this Code of Ethics.
For these purposes, the Code of Ethics of SANT DALMAI will be publicly communicated through its website showing the current version indicating the date of update.
INTERPRETATION
The Compliance Body will be the body responsible for the interpretation of this Code of Ethics. Its interpretative criteria will be binding for the employees of the organization.
Any doubt that may arise to the personnel of the organization about the interpretation of the Code of Ethics, should be consulted with the immediate superior according to the organization chart of the Company or, if the circumstances require it, 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. For this purpose, a register will be kept with the conformities received from employees.
Employees who in the future join or become part of the organization must also expressly accept the principles and rules of action established in this Code of Ethics, which will be published together with the Welcome Manual.
COMPLIANCE
The Code of Ethics of the organization is mandatory for all employees, managers and directives 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.
This Code of Ethics will enter into force on the day of its approval by the Board of Directors and will 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 and directives of the organization.
Any revision or update that involves a modification of the Code of Ethics will require approval by the Management Body of SANT DALMAI, after a report from the Compliance Body.
For the 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: adopted as an international human rights treaty on 20 November 1989 and entered into force on 2 September 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 targets were defined, with the aim of achieving three major challenges in the next 15 years: (i) eradicate extreme poverty, (ii) combat inequality and injustice, (iii) combat climate change.
- National Action Plan on Business and Human Rights: The Council of Ministers of the Spanish Government approved on July 28, 2017, an Action Plan with the aim of applying at the national level the United Nations Guiding Principles on Business and Human Rights.
- Modern Slavery Act 2015: On March 26, 2015, the United Kingdom published the approval of the Law against Modern Slavery, Servitude, Forced or Compulsory Labour and Human Trafficking, becoming a global reference.
- ISO 20400: First international standard on sustainable purchase
- UNE-ISO 37301:2021 and UNE 19601:2017: international and national standards on criminal compliance management systems .
Sant Dalmai, 5 June 2023