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  • Address: Polígono de Piadela s/n, 15300 Betanzos - A Coruña

Ethics Code

I. Scope of Application of the Ethics Code

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:

  • Gallega de Distribuidores de Alimentación, S.A.
  • Gadisa Retail Business GROUP:
    • Gadisa Retail, S.L.U.
    • Mercartabria, S.L.U.
    • Pontevicus, S.L.U.
    • Lucus Market, S.L.U.
    • Atlántica Saga Ourense, S.L.U.
    • Ecomás Supermercados, S.L.
    • Hipermercados y Economatos, S.A.U.
    • Ezequiel Arribas, S.A.U.
    • Pescarmar, S.L.U.
  • Bienes Inmuebles Corporativos Atlánticos 2008, S.L.U.
  • INTASA Business GROUP:
    • Industrias del Tablero, S.A.
    • Madeiras do Xurés, S.L.U.
    • Unión de Empresas Madereras, S.A.U.
    • Eume Maderas, S.L.
    • Servicios Cogeneración Piadela, S.A.
  • Forestal del Atlántico e Imegasa Business GROUP:
    • Forestal del Atlántico, S.A.
    • Impregnaciones Melanímicas Gallegas, S.A.U.
  • Transportation Business GROUP:
    • Transportes Piadela, S.L.
    • Servicios Polígono Piadela, S.L.
    • Servicios de Alimentación Piadela, S.A.
    • Tojeiro Transportes, S.A.
    • Cisternas de Mugardos, S.L.U.

1. Liable Persons

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:

  • The Managing Directors of the referred companies and the Management.
  • The Boards of Director of all GADISA GROUP companies
  • Employees of all GADISA GROUP companies, including internship staff members

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".

2. Obligation to Know and Comply with 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.

3. Objectives

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.

4. Scope

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.

II. Mission, Vision and, Values

1. Mission

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.

2. Vision

GADISA GROUP cares about the innovation of its products, environmental sustainability, transparency in management, support to society, and disadvantaged groups.

3. Values

  • Closeness: GADISA GROUP works committed to the philosophy of closeness to the client, honesty, and a vocation for service, to better satisfy the needs of clients by offering professional service and the best value for money.
  • Quality: In the GROUP, the highest quality products prevail. Besides food distribution, GADISA GROUP complies with the highest standards in the rest of its industrial processes.
  • Environmental Sustainability: GADISA GROUP promotes the continuity of its activities over time, reinforcing its commitment to protecting the environment and social well-being, especially in the communities where it is operative. This explains why the GROUP carries out actions aimed at improving efficiency in its logistics, industrial processes, and points of sale, promoting recycling and reuse.
  • Transparency in Management: GADISA GROUP holds a strong commitment to the importance of managing the activity based on an ethical and responsible model, according to the principles of good governance, which is accountable with transparency.
  • Corporate Social Responsibility: GADISA GROUP maintains a firm commitment to the needs of the existing society, which translates into an important commitment to social, economic, and cultural development.
  • Law Enforcement: Respect for the environment in which it operates, in compliance with applicable laws and regulations, based on the highest ethical standards and paying attention to the consequences that decisions may have on the people surrounding the environment.
  • Creation of Wealth in Dignified Social Conditions: From its launch, GADISA GROUP has conceived the creation of wealth in decent social conditions, improving the quality of life of clients, employees, suppliers, and society in general. The GROUP is aware of human value as a fundamental part of the success of the organisation and, therefore, the contribution to society is part of the GROUP’s philosophy.
  • Continuous Improvement: GADISA GROUPS promotes the development and talent and knowledge retention in order to carry out its activities efficiently and reliably.
  • Innovation: Constant innovation is a distinctive sign of GADISA GROUP.

4. Guidelines to Identify Non-Ethical Behaviours

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.

II. Mission, Vision and, Values

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.

Equal Opportunities and Non-Discrimination

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

Respect for People holding a Professional Relationship within the GADISA GROUP

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.

Work-Life Balance

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.

Collective Rights

In order to promote a climate of dialogue and transparency, the relationship with representative organisations of employees shall be based on mutual respect.

Occupational Risk Prevention, Safety, and Health of Employees

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

Food Safety and Product Quality

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.

Environmental Protection

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:

  • Respect for the environment, making appropriate use of natural resources.
  • Promoting sustainable use of raw material and energy sources.
  • Compliance with current legislation related to the environment, and, if applicable, commitments taken on voluntarily.
  • Collaboration with the corresponding Administrations and Bodies

Compliance with Regulations and Ethical Behaviour

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:

  1. The latter hold irrelevant, symbolic value, or are promotion objects of low value.
  2. Respond to forms of courtesy or common business courtesies
  3. Are delivered or received with transparency and occasionally
  4. They are not forbidden by law or generally accepted business practice.

When such requirements are not met, they must be turned away or returned.

Information Confidentiality

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.

Integrity when Dealing with Clients and Suppliers

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.

IV. External Relations

1. Relationships with Suppliers

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.

2. Relationships with Clients

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.

3. Relationships with the Community

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.

4. Competition and Price Changes

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.

5. Relationships with Public Administrations and Authorities

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.

V. Application and Compliance

1. Code Application Control and Competences

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.

2. Communication, Dissemination, and Assessment of the Code

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.

3.Non-Compliance of the Code and Disciplinary Regime

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.

4. Irregularities

All individuals Subject to the Code are obliged to report the following irregularities:

  • Non-compliance of the Ethics Code;
  • Non-compliance of GADISA GROUP’s policies and procedures;
  • Other actions or behaviour that could translate to the violation or breach of the Ethics Code.

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.

5. Approval of the Code and Entry into Force

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.

VI. Supervisory and Control Bodies

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.

VII. Reporting Channels

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 canaldedenuncias@gadisa.es, 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.