Ethical code

A. Introduction

A.1 Description and purpose

The code of ethics or conduct is intended to serve as a guide for the actions of all employees of U mes U fan tres SL.
The function of this code of ethics is to provide a frame of reference against which to measure any activity. Employees should seek advice when in doubt about the ethical framework, since each person’s absolute responsibility is to “do the right thing,” a non-delegable and inexcusable responsibility.
U MES U workers must always avoid any conduct that could damage or endanger the company or its reputation, acting legally and honestly.

A.2 Scope of application

The principles and guidelines of conduct contained in the Code of Ethics are applicable in their entirety to all managing members, all employees of the company and/or to all those natural and/or legal persons linked business or professionally with the company (suppliers, clients, advisors or external professionals, etc.)

The senior management of U MES U will use all means at its disposal to enforce the rules contained in this Code of Ethics.

A.3 Obligation to know the ethical code and its application control

All people who fall under its scope of application have the duty to know and comply with the code of ethics, including communicating any non-compliance with it to the human resources department, either directly through the reporting channel compliance@umesu.wine or through the suggestions/complaints box.

The human resources department and the person designated for the good corporate governance function will ensure the correct communication of the code of ethics to all employees and its correct compliance through monitoring with periodic assessments and reviews.

B. Values and principles

B.1 General aspects

Good corporate governance, responsibility, transparency, commitment and excellence, together with dynamism and innovation, form the fundamental pillars of the ethical code of all the people who are part of the company.

All the actions of these people, as a consequence of their relationship with the company U mes U fan tres SL, must be guided by these values.

B.2 Equal opportunities

B.2.1 U mes u fan tres SL will provide the same opportunities for access to work and professional promotion, ensuring at all times the absence of situations of discrimination based on sex or sexual orientation, race, religion, origin, marital status or social conditions.

B.2.2 The company’s workers will adhere to the principle of equality at all times and will not discriminate against colleagues, workers, managers or people with whom they interact during the development of their work activity for any reason.

B.2.3 Consequently, subjects involved in hiring, selection and/or professional promotion processes will be guided objectively in their actions and decisions.

B.2.4 Equal opportunities will be promoted at all times and the fundamental objective will be to identify those people most in line with the profile and needs of the position to be filled, promoting the professional and personal development of all employees.

B.2.5 The employees of U mes U fan tres SL will carry out their tasks based on their professional capacity, carefully following the rules relating to safety and hygiene at work, with the aim of preventing and minimizing occupational risks.

B.2.6 U MES U FAN TRES S.L. is committed to providing adequate training that improves the work skills of all employees and provides the means to increase their chances of future promotion.

B.3 Quality and Sustainability

B.3.1 U mes u fan tres SL is committed to the constant search for excellence in the production of wines and cavas.

B.3.2 This must be based on sustainable practices that minimize environmental impact and promote the conservation of natural resources.

B4. Ethical duties, corruption and bribery

As an expression of the integrity required of the company’s administrators and managers, it is assumed that they must comply with the following ethical duties in the performance of their position:

B.4.1 Do not give or accept gifts or presents in the exercise of your position. Exceptionally, gifts may be accepted or given when the following circumstances apply: they are of irrelevant or symbolic economic value, they respond to signs of courtesy or unusual commercial attention, and they are not prohibited by law.

B.4.2 Not offer, grant, request or accept, directly or through another person, present or future advantages or benefits for themselves or third parties through advantages due to their position in the company. In particular, they may not give or receive any form of bribe or commission from any other party involved such as public officials, personnel from other companies, political parties, authorities, clients, suppliers and shareholders.
B.4.3 Make responsible use of the resources and means made available to you for the exercise of your position or job position.
B.4.4 Avoid any action or decision that may violate the law or the governance and sustainability system in your business, professional or private activities.

B.5. Performance of comprehensive professional conduct

The guiding criteria to which the conduct of the company’s professionals must be adjusted will be professionalism, integrity and self-control in their actions and decisions:
B.5.1 Professionalism is diligent, responsible, efficient action focused on excellence and quality.
B.5.2 Integrity is acting that is loyal, honest, in good faith, objective and aligned with the interests of the company and with its principles and values expressed in this code of ethics.
B.5.3 Self-control in actions and decision-making presupposes that any action carried out is based on four basic premises:

i) that it is ethically acceptable
ii) that it is within the law
iii) A That it is carried out carried out within the framework of the company’s social interest
iv) that it is willing to assume responsibility for it

B.6 Human rights

B.6.1 The company U mes U fan tres SL expresses its commitment and connection with human rights recognized in national and international legislation in accordance with the Guiding Principles on Business and Human Rights and the principles on which the Global Compact is based. United Nations.
B.6.2 The company expresses its total rejection of child labor, forced or compulsory labor and any form of modern slavery and undertakes to respect freedom of association and collective bargaining, the right to move freely within each country, non-discrimination under any condition or circumstance, the rights of ethnic minorities and indigenous peoples in the places where they carry out their activity.

B.7 Conflicts of interest

A conflict of interest occurs when the personal interests of an employee, manager or third party compete with the interests of the company.
B.7.1 People who are subject to the scope of the ethical code will always act in such a way that their private interests, those of their family members or other people linked to them do not take precedence over those of the company.

B.7.2 The contracting of services and supplies must be carried out in accordance with established internal procedures, avoiding subjectivity criteria.

B.7.3 If a conflict of interest occurs, the employee must notify the HR manager or the compliance manager.

C. Law Enforcement

C.1 Compliance with legality and regulatory compliance

The professionals of U mes u fan tres SL will strictly comply with the legislation in force in the jurisdiction in which they carry out their activity, taking into account the spirit and purpose of the regulations. Likewise, the obligations and commitments assumed by the company in its contractual relationships with third parties will be fully respected, as well as the customs and good practices of the countries in which they carry out their activity.

C2. The Company assumes as basic behavioral guidelines, among others, the Universal Declaration of Human Rights, Declaration of Fundamental Principles and Rights at Work and Conventions of the International Labor Organization, the OECD Guidelines for Multinational Companies and the Covenant. United Nations World Cup.

U MES U FAN TRES S.L. Its objective is that all people and entities to which this Code of Conduct applies comply with the principles indicated below in their relations with interest groups:

  • Comply and abide by applicable national and international laws.
  • Respect human rights and public freedoms, contribute to the preservation of the natural environment and collaborate with the development and well-being of communities.
  • Promote honesty, fairness, truthfulness, compliance with commitments, free competition and transparency.
  • Provide good working conditions, respecting labor rights.
  • Contribute actively and from a leadership position to environmental balance and the promotion of a low-carbon economy.

C.2 Competitors

The company undertakes to compete in the markets legally and not to carry out misleading or denigrating advertising of its competition or third parties.
Obtaining information from third parties, including that of competitors, will be carried out within the framework of legality.

C.3 Regulatory bodies

Relations with regulatory bodies and officials will be governed by the principles of legality, transparency, loyalty, trust, professionalism, collaboration, reciprocity and good faith, without prejudice to legitimate controversies that, respecting the above principles and in defense of the social interest , may arise with said authorities in relation to the interpretation or application of the regulations.

The company will respect and abide by the judicial or administrative resolutions that are issued, but reserve the right to appeal them, in any instances appropriate, when they understand that they do not comply with the law and contravene their interests.

C.4 Taxes

The company ensures compliance with applicable tax regulations in any of the countries in which it carries out its business activity.
Adequate coordination of fiscal policy will be sought, within the framework of achieving social interest and supporting long-term business strategy, avoiding fiscal risks and inefficiencies in the execution of business decisions.

C.5 Labor legality

C.5.1 In any case, current labor legislation will be respected for any employee of the company.
C.5.2 Professionals working in or for the company will be paid in accordance with applicable wage laws, including minimum wages, overtime and social benefits.

C.6 Relations with Authorities

Employees will maintain an attitude of respect and collaboration with representatives of the authorities within the framework of their powers. Links, membership or collaboration with political parties, NGOs or other types of entities, institutions or associations, as well as contributions or services to them, must be made in a way that makes their personal nature clear. Professional activities should not be carried out outside of U mes U fan tres SL if they interfere with their usual work or if they are in any way a conflict of interest. If you carry out any activity of this type, you must notify the HR department or the person responsible for Compliance for evaluation.

D. Respect for employees

U MES U FAN TRES S.L. rejects any manifestation of physical, psychological, moral harassment or abuse of authority, as well as any other conduct that may generate an intimidating or offensive environment with people’s rights and promotes working conditions that prevent harassment in all its forms, including the sexual and the one based on sex.

D.1 All subjects with personnel in their charge in the different departments or business areas of the company must promote that situations of discrimination, lack of equality, contempt or lack of respect and/or dignity of people do not occur.

D.2 The company will promote relationships based on respect for the dignity of others and reciprocal collaboration, promoting a respectful work environment in order to achieve a positive work environment, without distinctions based on position within the company. , titles, age, gender or any other condition contrary to the ethical principles of U mes u fan tres SL.

D.3 A respectful work environment without harassment will be promoted. Any manifestation of harassment, abuse of authority, as well as any other conduct that could generate an intimidating, offensive or hostile work environment is rejected.

D.4 The company’s managers will promote a work environment compatible with personal development, ensuring that it is possible to reconcile work requirements with their personal and family life.

D.5 Legally recognized labor rights will be respected, as well as the activities carried out by representative organizations of workers, in accordance with the functions and powers legally attributed to them.

D.6 Any employee who detects the slightest indication of any situation and/or action that could lead to the violation of labor or union rights must immediately notify the HR manager.

D.7 The company U mes U fan tres SL is committed to ensuring the protection of its professionals, avoiding their overexposure to physical, chemical or biological hazards and tasks that require physical overexertion in the workplace. Likewise, it is committed to identifying and evaluating potential risk or emergency situations in the workplace and minimizing their impact through the implementation of prevention measures. The necessary material will be provided to minimize occupational risks through the provisions of the risk assessment.

E. Relationships with suppliers

E.1 The company’s professionals are committed to complying with the internal procedures established for the award processes, including, especially, those referring to the approval of suppliers.

E.2 Professionals will avoid any kind of interference or influence from suppliers or third parties that could alter their impartiality and professional objectivity and will not be able to receive any kind of remuneration from suppliers, whether in cash or in kind.

E.3 The supplier will inform the company of any breach or suspected breach of the code of ethics, using the email address enabled for this purpose in the complaints channel: compliance@umesu.wine.

E.4 All suppliers who work or wish to work with U mes U fan tres SL must comply with the code of ethics and current legislation: regulations, labor, tax, Occupational Safety and Health, environmental, etc. In addition to committing to respect human rights.

E.5 The prices and information presented by the suppliers will be treated confidentially and will not be revealed to third parties except with the consent of the interested parties or by legal obligation, or in compliance with judicial or administrative resolutions.

E.6 U mes U fan tres professionals will ensure compliance with the provisions of this code of ethics by their suppliers and will act accordingly in the event of any violation.

F. Relationships with clients and consumers

F.1 The company U mes u fan tres SL is committed to offering product quality equal to or superior to what is legally established, promoting responsible consumption, competing in the market, and carrying out marketing and sales activities based on the merits of its products. products and services.

F.2 Contracts with clients will be written in a simple and clear manner. In pre-contractual or contractual relationships with clients, transparency will be encouraged, and all points will be clearly reported.

F.3 Professionals will avoid any kind of interference or influence from clients or third parties that may alter their impartiality and professional objectivity and will not receive any kind of remuneration from clients, whether in cash or in kind.

F.4 The confidentiality of client data will be guaranteed, committing us not to reveal it to third parties, except with the client’s consent or by legal obligation or in compliance with judicial or administrative resolutions.

F.5 The collection, use and processing of personal data of clients must be carried out in a way that guarantees the right to privacy and compliance with personal data protection legislation, as well as the rights recognized to users. clients by the legislation on information society services and electronic commerce and other applicable provisions.

G. Use and protection of assets.

G.1 U MES U FAN TRES S.L. makes available to employees the necessary resources to carry out their professional activity.

G.2 The people of U MES U FAN TRES S.L. They must use the company’s resources responsibly, appropriately and with the relevant authorizations, in the context of their professional activity. Likewise, they must protect and preserve them from any inappropriate use that could cause harm to the interests of the company.

G.3 The people of U MES U FAN TRES S.L. They are prohibited from alienating, transmitting, assigning, or hiding any property owned by the Company in order to avoid compliance with responsibilities and commitments to third parties.

G.4 The computer equipment and systems of U MES U FAN TRES S.L. They must be used exclusively for professional use. However, in those cases in which these resources are exceptionally used for personal purposes, their use must be minimal, reasonable, appropriate and in accordance with the principle of contractual good faith. All people in the Company must know and accept the rules established by the company. Technological resources cannot be used to:

  • Express personal opinions on behalf of the group or access forums or social networks for the same purpose, unless expressly consented to this effect.
  • Store or distribute, or visit Internet sites with, inappropriate material that violates human rights, privacy, honor, self-image, religious freedom; or against the dignity of people such as racism, xenophobia, advocacy of violence or terrorism, and pornographic material or sexist advocacy.
  • Use, introduce, download, copy, transmit, reproduce, distribute or store any type of software, edited work or invention protected by intellectual or industrial property without the corresponding license or authorization.
  • Send or participate in mass email sending with chain messages, jokes, or inappropriate images.

H. Measures against bribery, fraud and corruption

H.1 U MES U FAN TRES S.L. declares itself opposed to influencing the will of people outside the Company to obtain any benefit using unethical practices. Nor will it allow other people or entities to use these practices with their employees.

H.2 Employees, by reason of their position or responsibility, may not accept any type of gift, attention, service, or any other type of favor from any person or entity that exceeds the limits established in the company’s integrity policy and that may affect your objectivity in decision-making or influence your commercial, professional or administrative activity within the company. Likewise, all employees are strictly prohibited from participating directly or indirectly in any type of activities that involve corrupt practices, such as, for example, bribery, illegal commissions or influence peddling.

I. Prevention of money laundering

I.1 U MES U FAN TRES S.L. applies the greatest rigor to prevent and avoid the laundering of money from criminal or illicit activities, and has internal control procedures for its prevention, detection and, where appropriate, eradication.

I.2 All the people of U MES U FAN TRES S.L. They must comply with the applicable legal provisions and pay special attention to those cases in which there are indications of lack of integrity of the people or entities with whom commercial relations are maintained, such as, among others, payments that are unusual considering the nature of the transaction, payments made to or by third parties not mentioned with the contract, payments to persons or entities resident in tax havens or to bank accounts opened in offices located in tax havens, payments to entities in which it is not possible to identify the partners or ultimate beneficiaries, extraordinary payments not provided for in the contracts.

I.3 Except in exceptional cases, with express authorization and with traceable documentary support, U MES U FAN TRES S.L. does not allow cash payments. Consequently, it is the obligation of workers to immediately report, through their hierarchical superiors or by email sent to compliance@umesu.wine, any violation of laws or internal codes in any of the aspects indicated in this section.

J. Sustainability and environment

J.1 Communication

U MES U FAN TRES SL is committed to transmitting the company’s commitment to the production of high-quality wines and cavas, based on principles of sustainability and respect for the environment.
Environmental awareness will be promoted among our employees and clients, providing information on sustainable practices.

J.2 Commitment to Sustainability

We will constantly seek to reduce the carbon footprint in all stages of the production and distribution process. Minimize waste and encourage recycling in all operations. Prioritize sustainable practices, such as the responsible use of water and the promotion of biodiversity. Implement technologies and practices that promote energy efficiency.

J.3 Protección del Medio Ambiente

Se garantiza el cumplimiento con todas las leyes y regulaciones ambientales aplicables en nuestras actividades.
Se propondrá adoptar medidas preventivas para proteger el suelo, el aire y el agua de posibles contaminaciones.

J.4 Responsible Innovation

Se fomenta la investigación y la innovación en prácticas sostenibles para mejorar continuamente nuestra gestión ambiental. Buscar constantemente reducir el impacto ambiental de nuestros envases y materiales de embalaje.

J.5 Responsible Relationships with Suppliers

Collaboration with suppliers that share our values of sustainability and respect for the environment must be prioritized. Promote responsible purchasing practices that consider the environmental impact of the products and services we acquire.
We must listen to the concerns of customers, employees and other interested parties regarding our environmental actions and respond appropriately.

K. Social responsibility

K.1 The company U MES U FAN TRES SL contributes, with its business activity and its sustainable development strategy, to the progress of the community that surrounds it, both from an economic point of view and from the perspective of business ethics, promotion of equality and social justice, the protection of vulnerable groups, the promotion of innovation and care of the environment, the generation of quality employment based on diversity, inclusion and the sense of belonging, as well as the leadership in the fight against climate change.

K.2 All contributions of social, cultural or any other nature that are made on behalf of the company must comply with the following requirements: Not be anonymous, have a legitimate purpose and when monetary, be made by any means of payment that allows the recipient of the funds to be identified and the contribution to be recorded.

L. Confidentiality and data protection

L.1 In general, employees must maintain professional secrecy with respect to data or information, public or non-public, that they become aware because of the exercise of their professional activity, whether they come from or refer to clients, suppliers, the company or others. employees or managers or anyone else.

L.2 Workers will refrain from using the information they know in connection with the performance of their work, for any purpose other than the same, and under no circumstances may they retain or duplicate it.

M. Report and irregularities

M.1 Any report regarding an irregularity or unethical behavior can be established through secure channels, either through the email compliance@umesu.wine, or by going directly to the person responsible for HR and corporate social responsibility, or through the company suggestion box.

M.2 U mes u fan tres SL guarantees that there will be no retaliation against those who truthfully report non-compliance with the code of ethics by any of its employees or administrators.

M.3 Anonymous notifications will not be allowed, only confidential ones. For this reason, the reporting system can only be used after identifying the reporting person. The company will preserve the anonymity of the person who has reported legitimate concerns about compliance with this Code in good faith and will ensure the confidentiality of the entire process.

M.4 The person in charge of ensuring corporate social responsibility is responsible for supervising and guaranteeing compliance with this code of ethics.

M.5 U MES U FAN TRES SL assumes the responsibility of promptly correcting any violation of this code.

N. Review and update

N.1 U mes u fan tres SL undertakes to periodically review the code of ethics and update it as necessary.

N.2 Any review and modification of the code of ethics will be informed to employees and administrators.

O. Compliance and consequences

O.1 Employees and administrators will comply with both the general provisions (laws, regulations, etc.) and the company’s internal regulations that are applicable to their activity.

O.2 In any complaint or investigation regarding irregularities in the behavior of staff, the rights to privacy, defense and the presumption of innocence will be guaranteed

O.3 The termination of contracts with suppliers will be assessed and made effective in case of suspicion of irregularities or incompatibilities with the company’s code of ethics.

O.4 Failure by any natural person to comply with said Code will entail the corresponding punishment according to the severity of his or her actions. Those behaviors that are considered minor will result in a disciplinary file and a suspension of employment and salary. Conduct that is considered serious or very serious will lead to the termination of the employment relationship and, if appropriate, the corresponding authority will be informed.

P. Approval and validity of the code of ethics

The present text of the Code of Ethics is the one currently in force. The Administrative Body approved the code on July juliol de 2023