The Ethics Code (hereinafter, the “Code”) sets out the rules of conduct and general action guidelines that must establish the behaviour of all of the employees at GADISA GROUP (hereinafter “GADISA GROUP” or the “GROUP”). For the purposes of this Code, GADISA GROUP shall be deemed to be the companies and business groups with their corresponding companies, provided below:
This Code is applicable to all dependent corporations and companies of the GADISA GROUP. It also includes, without exceptions, any person of the GROUP, regardless of the position and role they hold, and specifically to the following:
Compliance must also be fostered among external collaborators and suppliers in operations carried out with the GADISA GROUP.
Such persons shall be referred to, hereinafter, as "Subject to the Code".
Individuals Subject to the Code have the obligation to know and comply with the Code and to cooperate in making its implementation within the GADISA GROUP easier, including the notification of any breach of the latter they may be aware of to the Supervisory and Control bodies, as established in GADISA GROUP’s Compliance Manual.
The purpose of this Code is to provide the GADISA GROUP and its employees with a fundamental instrument that serves as a basis for its actions and establishes the principles of conduct to be identified both in professional development and in the GROUP's relations with its employees, clients, suppliers, collaborators, public administrations, and society in general.
The principles of conduct set in this Code establish a list of guidelines for action that guide GADISA GROUP personnel during the execution of their professional activity, based on the values and vision of the GROUP, its corporate strategy, its commitment to clients as well as with third-party collaborators, companies of the sector and the company.
With the application of this Code, GADISA GROUP intends to establish an ethical-business reference framework that contributes to reinforcing trust in relationships with clients, suppliers, stakeholders and with the associated companies, as to make GADISA GROUP one of the benchmark entities in ethical-business behaviour within its sectors of activity.
GADISA GROUP cares about the innovation of its products, environmental sustainability, transparency in management, support to society, and disadvantaged groups.
Those Subject to the Code who have doubts as to whether or not a certain action complies with the GROUP’s ethical model may ask any questions to their hierarchical superior or before the Supervisory and Control bodies.
The general guidelines of the Code of Ethics constitute the pillars on which GADISA GROUP’s activity is based. Such principles are the subject of a specific development for the area of criminal risk prevention in GADISA GROUP’s Criminal Risk Prevention Manual.
The GADISA GROUP offers the same opportunities of access to employment and career development, fostering a corporate culture based on merit. In the GADISA GROUP, people are hired for their aptitudes, skills, experience, and capacity. Discrimination based on gender, ethnic, national, cultural, or social background, marital status, sexual orientation, religious, or political beliefs is not allowed
The GROUP's human resources are a key factor for business growth and success, thus, the GADISA GROUP, all those Subject to the Code and, especially, those who perform management tasks, shall promote relationships based on respect for others and mutual collaboration.
Any behaviour of harassment, sexual harassment, abuse, intimidation, disrespect, violence, threatening actions of harassment or bullying, intrusion into personal or family privacy or any type of aggression or attack against dignity or integrity in professional relationships within the GADISA GROUP.
AIn order to strengthen GADISA GROUP's commitment to improving the quality of life of employees, the subjects of the Code shall promote a work environment compatible with personal development, favouring the balance of the performance of the activity among its professional team members of GADISA GROUP with the needs of personal and family life.
In order to promote a climate of dialogue and transparency, the relationship with representative organisations of employees shall be based on mutual respect.
The GADISA GROUP has developed the protection of its companies related to occupational risk prevention based on the activity carried out by each company, in addition to planning the preventive activity, which includes all the prevention matters that must be undertaken in the exercise of continuous improvement
The GADISA GROUP, within food sector activities, provides food of the highest quality, which passes all the controls and sanitary standards for this purpose.
In this regard, the GROUP is committed to offering high-quality food products, following the regulations for safety, food preservation and expiration of products, carrying out an exhaustive control of all processes in terms of safety and food health.
The GADISA GROUP carries out its activity according to the principles and criteria of sustainability and protection of the environment, with proper management of its resources being a priority. Specifically, through the following actions:
All those Subject to the Code shall act at all times under strict adherence of current legislation, as well as the internal procedures of the GADISA GROUP applicable to their activities.
Those Subject to the Code shall notify the company, through the corresponding hierarchical channels, of any conduct contrary to legality, human rights, or the ethical values defended by said Code.
Those subject to the Ethics Code may not give or accept gifts that could influence decision-making; as an exception, they will be allowed when the following circumstances take place simultaneously:
When such requirements are not met, they must be turned away or returned.
All employees subject to this Code are obliged to protect the confidential or reserved information of which they are aware given their position (whether it be technical, financial, commercial, or of any other nature) and not to use it outside the scope of their employment relationship, nor reveal it to third parties without the prior written consent of the company, except for those requests for information that are required by judicial or administrative authority in legal terms.
Employees who, due to their responsibilities, have access to especially sensitive information may be required by the Company to sign specific confidentiality commitments as an Annex to their main employment contract.
The Company shall guarantee its employees, suppliers, clients, and anyone related to it, faithful compliance with the regulations on data protection, adopting the corresponding measures in its Organisation so that said regulations are fully effective.
Those Subject to the Code have the obligation to treat all the GROUP's clients and suppliers with fairness and integrity, working to understand and satisfy their needs based on high quality and demanding standards.
The relationship with GADISA GROUP's suppliers is based on mutual conditions of seriousness, rigour, and respect, and they ensure effective collaboration for both parties.
This relationship is established as a key element in achieving GADISA GROUP’s objectives in such a way that, in any case, an ethical and lawful relationship with suppliers of goods and services must be fostered.
All the efforts of the GADISA GROUP are aimed at providing a better service to its clients. This allows the GROUP to have a permanent adaptation of supplies, families and shelves, introducing new references, always under the highest quality parameters.
In the industrial sectors of activity, GADISA GROUP is committed to the highest quality standards.
The GADISA GROUP agrees to compete in the market fairly, not admitting in any case deceptive, fraudulent, or malicious conduct, not even when they lead to obtaining advantages for the company.
The GADISA GROUP promotes participation in social initiatives or projects that contribute to improving the environment in which it is operative.
An essential element of management is to do things impeccably within the areas in which GADISA operates. The GROUP's commitment is summarised in trying to give back to society part of what it has given to the GROUP by putting their trust in the company.
The GADISA GROUP believes in the need for fair competition and a competitive market that contributes to innovation and continuous improvement of the GROUP and of the different sectors in which it operates, in such a way that it is committed to compliance with legislation and regulations on competition.
The relationships established between the GADISA GROUP and any public or official body or its representatives must be governed by the principle of institutional respect, collaboration, legality, and ethics, consequently complying with the arising resolutions from the latter.
Acts of bribery shall be expressly prohibited, including the offer or promise, directly or indirectly, of any type of improper advantage, any instrument for its concealment, as well as influence peddling.
The supervision of compliance with the Code corresponds to the Supervisory and Control bodies, which shall report to the corresponding Board of Directors of the GADISA GROUP.
The Supervisory and Control bodies shall include in their review models the controls necessary to verify compliance with the provisions of the Ethics Code, make the necessary proposals for improvement, and shall periodically inform the corresponding Board of Directors of the GADISA GROUP on the degree of compliance and breaches detected.
It is the responsibility of the Supervisory and Control bodies to make the Code of Ethics available to all employees and obliged subjects, organise training for the corresponding learning period, and interpret and respond in general any queries that may arise.
The GADISA GROUP shall implement the appropriate measures in order to disseminate and communicate the content of said Ethics Code to all employees. This task will be carried out by the Supervisory and Control bodies.
No one, regardless of their rank or position, is authorised to request a professional to commit an illegal act, or contravening the provisions of the Code.
Failure to comply with the Code may give rise to the application of the sanctioning regime established in the current occupational regulations or in the applicable collective agreements, without prejudice to the administrative or criminal sanctions that, where appropriate, may be applicable, and may also give termination of the employment relationship.
All individuals Subject to the Code are obliged to report the following irregularities:
Such cases must be reported directly to the Supervisory and Control bodies through the due complaint channels.
The GADISA GROUP shall preserve any employee who presents a concern honestly, although the making of false, unfounded accusations, or the absence of cooperation in the investigation of any breach may constitute a violation of this Code.
This Code shall enter into force once it is approved by the corresponding Boards of Directors of the GADISA GROUP.
This is version 2 of the Ethics Code that was approved by the Board held on the 29 of June of 2018.
Within the framework of this Code, the Supervisory and Control bodies shall be in charge of the control and management of queries or complaints, and those in charge of compliance with the Code of Ethics.
In order to promote compliance with the legality and standards of conduct established in this Ethics Code, reporting channels are created in the form of e-mail addresses email@example.com, so that those Subject to the Code can communicate those behaviours that may involve the commission of an irregularity.
GADISA GROUP employees who have reasonable indications of the commission of any irregularity or act contrary to the law or the rules of action of this Code, must communicate it through its Reporting Channel.
In any case, such notifications must always meet criteria of truthfulness and proportionality. The identity of the person who communicates an anomalous action shall be considered confidential information, therefore, it will not be communicated to the accused, thus guaranteeing the reservation of the identity of the complainant.
The GROUP agrees not to adopt any form of retaliation, direct or indirect, against employees who have communicated, through the reporting channels, an action of those referred to above.