Code of Ethics CaviarEat (a trademark of the company LuxurEat)

INTRODUCTION

Code OF Ethics

The Code of Ethics of Luxureat and Caviareat is a fundamental document that establishes standards of ethical behaviour for directors, managers, employees, collaborators and suppliers. The Code not only aims to ensure high ethical standards in company activities but is also an integral part of an Organisation, Management and Control Model in accordance with current regulations. Including general ethical principles and specific behavioural guidelines, the Code of Ethics is an essential tool to ensure transparency, integrity and accountability in all business operations. It also includes mechanisms for communication, training and monitoring, ensuring that all parties involved adhere to the established standards.

Recipients

The Code of Ethics of Luxureat and Caviareat is aimed at all those who contribute to the company’s activities, including members of the corporate bodies, managers, employees and external parties such as agents, intermediaries, consultants, suppliers and customers. These subjects, defined as “Recipients”, are required to comply with the principles and rules of conduct of the Code. Violations can compromise trust with the company and result in disciplinary action or claims for damages, in compliance with applicable labor laws and regulations.

General Principles

Human Rights

Luxureat and Caviareat place respect for the human person at the centre, condemning all forms of discrimination and exploitation. Individual freedom is a fundamental value.

Compliance with Laws

The company undertakes to comply with all laws and regulations in force in each country in which it operates, with particular attention to international regulations.

Integrity, Honesty and Fairness

Recipients are required to maintain high standards of integrity, always acting honestly and fairly, avoiding conflicts of interest and illicit gains.

Transparency and Verifiability of Operations

All transactions must be transparent, verifiable and correctly recorded, ensuring the accuracy and completeness of accounting information.

Excellence, Innovation and Performance

Luxureat and Caviareat adopt excellence as a cornerstone principle, leveraging advanced technical know-how to ensure product quality. Innovation is a key pillar, encouraging staff to develop creative solutions and continuous improvements. The Company maintains a strong focus on performance, ensuring that it meets customer expectations in terms of performance and safety.

International Trade and Relations with International Operators

Luxureat and Caviareat are committed to complying with international trade-related laws and regulations, including import and export regulations, and interact with global partners in accordance with local and international laws.

Protection of Confidentiality and Privacy

The company guarantees the protection of personal data, complying with privacy regulations and preventing unauthorised use.

Correct Use of Computer Systems

The appropriate use of information technologies is promoted, ensuring the security and integrity of data.

Prohibition of Disclosure of Sensitive Information

Recipients are required not to disclose sensitive or confidential information to which they have access.

Correct Use of Corporate Assets

The Recipients are responsible for safeguarding company assets, avoiding improper or harmful uses.

Behavior Style

The Recipients of Luxureat and Caviareat must base their relations with customers on fairness, transparency, listening, availability, courtesy, honesty, loyalty and professionalism, respecting the principles of the Code of Ethics. It is forbidden to accept or offer non-negligible benefits, gifts or acts of courtesy of significant value. The company promotes transparency in commercial transactions and is committed to combating money laundering and receiving, terrorism and organised crime, avoiding relationships with parties involved in such activities.

TITLE I – PRELIMINARY PROVISIONS AND GENERAL PRINCIPLES

Art. 1 – Purpose of the code

Luxureat and Caviareat, companies specializing in the marketing of luxury products, in particular caviar, adopt this code of ethics with the aim of:

  • Promote a commitment to excellence, quality and sustainability in caviar and luxury products.
  • Ensure that all business operations are conducted with integrity, transparency and compliance with laws.

Art. 2 – Respect for the principles

In conducting their business, Luxureat and Caviareat are committed to scrupulously respecting national and international regulations, both in the agri-optical and luxury goods sectors. The company ensures that its employees adhere to these standards.

Art. 3 – General rules of conduct

In their work, Luxureat and Caviareat adhere to the principles of loyalty, honesty and fairness towards all stakeholders, including customers, suppliers, partners and competitors. The company promotes a work environment that respects these core values.

Art. 4 – Updating and Disclosure of Ethical Standards

The Board of Directors of Luxureat and Caviareat is responsible for updating this Code of Ethics and is committed to ensuring its constant dissemination among all employees and stakeholders. The company will ensure that the Code is easily accessible and understandable.

Art. 5 – Accession Clause

Membership in Luxureat and Caviareat implies full acceptance of and compliance with this Code of Ethics. Violations of the Code may result in penalties as provided for in the Company Articles of Association. In addition, the company is committed to providing a clear understanding of the Code to all new employees upon entry.

TITLE II – GENERAL RULES OF CONDUCT

Art. 6 – Compliance with the Requirements of Fairness, Loyalty, Impartiality and Transparency

Luxureat and Caviareat are committed to operating with maximum clarity, truthfulness and transparency in contractual relationships.

In particular, the following are always accurately highlighted to the customer:

a) the type of product and service being provided;

b) the methods and times;

c) the price of the product purchased, its technical data sheets, the methods and terms of payment.

Art. 7 – Compliance with Rules and Canons of Fairness, Competence, Professionalism, Care and Diligence

The company undertakes to:

  • Identify customer needs and adapt the services offered.
  • Ensure the conformity of the services to the customer’s specifications and their satisfaction.
  • Maintain accuracy and security in information management.
  • Continue to improve internal processes and staff training.
  • Select suppliers and external resources that meet the same ethical standards.

Art. 8 – Compliance with the Confidentiality Rules and Correct Processing of Personal Data

Luxureat and Caviareat are committed to operating in full compliance with privacy and personal data protection laws. The company ensures that it collects, uses and stores the personal data of customers and other parties in a lawful, correct and secure manner. Luxureat and Caviareat facilitate access to personal data by data subjects and delete outdated or unnecessary data.

Art. 9 – Safeguarding the Environment

Luxureat and Caviareat recognise the crucial importance of the environmental impact of their activities and are actively committed to reducing negative effects on the environment. The company encourages sustainable practices throughout its operations and supply chain, promoting initiatives that have a positive impact on the socio-economic and territorial environment. In addition, Luxureat and Caviareat invest in technologies and systems that minimise environmental impact, from waste management to the creation of integrated environmental management systems

TITLE III – OBLIGATIONS RELATING TO RELATIONS WITH THE MAIN STAKEHOLDERS IN CARRYING OUT THE ACTIVITY.

Art. 10 – Fairness of Contractual Clauses

Luxureat and Caviareat are committed to adopting contracts with balanced and clear clauses, avoiding abusing economic dependence and creating significant imbalances in rights and obligations.

Art. 11 – Contract Execution Fees

In the execution of contracts, the company adheres to the principle of good faith with both suppliers and customers, ensuring fairness and transparency in contractual relations.

Art. 12 – Conciliation and Arbitration

Luxureat and Caviareat prefer non-judicial methods for dispute resolution, such as conciliation or arbitration, using the services offered by Chambers of Commerce or other similar institutions.

SECTION I – CUSTOMERS

Art. 13 – Obligation of Loyalty

Luxureat and Caviareat are dedicated to understanding and satisfying customers’ needs, aiming to exceed their expectations. Customer satisfaction is a primary objective, and the company employs systems to know its customers and measure their satisfaction. Staff are trained to support these systems and to ensure high customer satisfaction.

Art. 14 – Conflict of Interest

Luxureat and Caviareat agents avoid assignments that could create a conflict of interest with clients or between different clients. The company ensures that every operation is conducted with the utmost integrity and transparency.

SECTION II – SUPPLIERS

Art. 15 – Relations with Suppliers

Luxureat and Caviareat adopt supply control systems appropriate to the sector and management efficiency. Relations with suppliers are based not only on aspects such as quantity, quality and price, but also on factors such as the consistency of quality, the evolution of the supplier, the ability to collaborate in designs and developments, attention to quality and the implementation of corrective actions.

Art. 16 – Advertising

Luxureat and Caviareat inform customers about the existence, contents and effects of this Code, ensuring transparency and ethical awareness in their operations.

SECTION III – EMPLOYEES/AGENTS/COLLABORATORS

Art. 17 – Occupational Safety

Luxureat and Caviareat are committed to complying with all regulations relating to safety at work, ensuring the continuous updating and training of employees and collaborators in the field of safety and health.

Art. 18 – Involvement in Company Policies

The company actively involves employees, agents and collaborators in the pursuit of company objectives, promoting training and transparent communication initiatives. A work environment based on mutual respect, esteem and professional ethics is promoted, where each team member is valued and informed about company policies and performance.

Art. 19 – Instructions and Orders on Compliance with the Code

Luxureat and Caviareat ensure that employees’ actions are in line with the principles of the Code of Ethics, both in terms of correctness and quality standards. The company requires active involvement, commitment and effective interaction from all staff, aware that individual behaviour and performance directly affect the quality perceived by customers. Careful selections are made for the hiring of new staff and training and education plans are established to ensure the achievement of business objectives.

SECTION IV – COMPETITORS

Art. 20 – Prohibition of Unfair Competition Practices

Luxureat and Caviareat undertake to respect the principles of commercial loyalty, refraining from any act of unfair competition. The company avoids making judgments about the professionalism of competing companies and, in comparisons with competing services, relies exclusively on truthful and objective elements. In the event of collaboration with other companies in the sector, the company undertakes to cooperate loyally, aiming at customer satisfaction. Furthermore, Luxureat and Caviareat do not share information about their customers with other companies, even in collaborative situations.

Art. 21 – Misleading Advertising

Luxureat and Caviareat are committed to ensuring that all advertising communications are truthful and correct, avoiding any form of misleading advertising. The company is aware of the legal liabilities and financial implications arising from misleading advertising. The company’s advertising campaigns aim to provide accurate information about the services, their costs, and the benefits for customers, ensuring effective and accessible communication.

TITLE IV – FINAL PROVISIONS

Art. 22 – Disciplinary Relevance of Violations of the Code

Violations of this Code of Ethics by Luxureat and Caviareat employees, agents or associates may result in disciplinary action. These may include written warnings, suspensions or, in the most serious cases, expulsion. Such measures are taken to maintain a high level of integrity and compliance with ethical principles.

Art. 23 – Reports of Violations

Customers or other stakeholders who believe a provision of the Code of Ethics has been violated may report it to the company. Luxureat and Caviareat provide clear and accessible channels for such reports, ensuring constant evaluation and updating of the application of the Code.