Code of ethics – Costers del Sió Winery

Index

1. Introduction

2. Objectives of the Code of Conduct

3. Scope and Application

4. Fundamental principles and values

5. Commitment to sustainability

Environmental Management

Sustainable Innovation

6. Labor relations and human rights

7. Relationship with the community and suppliers

8. Actions against corruption, extortion and embezzlement

9. Complaint and compliance mechanisms

10. Review and update of the code of conduct

1. Introduction

At Costers del Sió we recognize the importance of operating with the highest ethical and sustainable standards. This Code of Conduct is our guide to act with integrity in all our activities related to the production and marketing of wines. We are committed to guaranteeing a positive impact on the environment, both environmental and social, while maintaining the quality and tradition that characterizes the wines of our region.

We want every worker, supplier and business partner to understand and apply these principles, ensuring that we all act consistently with our core values.

2. Objectives of the Code of Conduct

  • Promote a culture of ethics and respect in all areas of the winery.
  • Ensure compliance with applicable laws and regulations, both locally and internationally.
  • Prevent and combat corruption, extortion and embezzlement of funds.
  • Promote honesty and transparency.
  • Promote an inclusive, safe and healthy work environment, based on equity.
  • Promote respect and coexistence within the winery.
  • Develop the professional ethics of all workers.
  • Protect privacy and confidentiality.
  • Consolidate the reputation of Costers del Sió as a reference in the Lleida wine industry.

3. Scope and Application

This Code is mandatory and must be followed by all employees and organizations that maintain a relationship with the Costers del Sió winery. Its application covers all areas of the company, guaranteeing that the winery’s decisions and actions are aligned with its principles. Specifically, the obligation to:

  • All workers and owners of Costers del Sió, without distinction of hierarchy. This includes permanent staff and possible temporary or contracted workers for specific projects, without distinction of departments. All operations must follow this code.
  • Suppliers and other business partners involved in distribution, marketing or other related activity.
  • Costers del Sió’s practices must also align with the expectations of the environment. This includes respect for local and regional laws and commitment to the well-being of the community.

Compliance and Responsibility:

Compliance with the Code is the responsibility of all the persons and entities mentioned, who must act in accordance with the principles of ethics, integrity and responsibility that govern this document. Any violation of the Code must be reported in accordance with established procedures and could imply corrective or disciplinary measures, as the case may be.

In addition, external parties that collaborate with Costers del Sió, such as suppliers or contractors, must also adhere to the principles of this Code in all their interactions with the winery, which guarantees a value chain consistent with the company’s ethical and quality standards.

4. Fundamental principles and values

The Costers del Sió Code of Conduct is based on ethical principles that guide all decisions and behaviors within the winery. These principles reflect the commitment to a transparent, sustainable and respectful operation, both in the workplace and with the environment and communities.

1. Integrity: Work with honesty and transparency. Integrity is the basis of all our actions. This implies maintaining truthfulness in communication with employees, clients, suppliers and authorities; as well as avoiding any form of fraud or conflict of interest, ensuring that decisions are made based on ethical and professional criteria.

2. Respect for Regulations: Strictly comply with current laws. Compliance with local, national and international laws and regulations is essential to guarantee legality and ethics in all winery activities.

3. Sustainability: Minimize environmental impact and preserve natural resources. This principle guides all our decisions, from the management of the vineyards to the production and marketing of our products, ensuring that our activity has the least possible impact on the environment.

4. Respect for Human Rights: Guarantee equality and fair treatment. Costers del Sió is committed to absolute respect for human rights and promoting a work environment in which all people are treated with dignity and respect. This principle covers:

  • Equal opportunities for all employees, without discrimination based on gender, race, age, religion, sexual orientation or origin.
  • The right to decent work, guaranteeing safe, fair and equitable working conditions.
  • Respect for freedom of association and expression, allowing employees to express their concerns and opinions freely and without fear of reprisals.
  • Combat any form of labor exploitation, including child or forced labor, both in our warehouse and in supply chains.

5. Excellence: Seek continuous improvement in all processes. Innovate and adapt to the best practices and technologies, seeking creative and efficient solutions. Improve the quality of our products through rigorous and constant control processes, ensuring that the wine we produce always lives up to the expectations of our customers. Promote continuous learning among our employees, supporting their continuous training and the development of new skills.

6. Responsibility: Comply with our obligations in a professional manner. At Costers del Sió, we take our responsibility seriously, recognizing that each action and decision has an impact on the winery, our collaborators and society in general.

7. Confidentiality: Protect the sensitive information of the winery and its partners. The principle of confidentiality is fundamental to guarantee trust in all our commercial and labor relationships. We establish clear policies for the management and disclosure of confidential information, avoiding any leak that could harm the winery or its business partners.

5. Commitment to sustainability

Sustainability is an essential pillar that guides our way of operating, reflecting our commitment to the preservation of the environment and the well-being of future generations. Through our actions, we seek to minimize environmental impact, promote responsible practices and contribute to sustainability in all stages of our operation.

5.1 Environmental Management

Environmental management at Costers del Sió is focused on reducing our ecological impact while preserving and respecting the natural environment that surrounds our winery in the Lleida region. To do this, we adopt sustainable practices that align with the principles of environmental responsibility.

  • Reduction in the use of energy resources and waste generation: We implement measures to optimize the use of energy and natural resources in all stages of wine production, storage and distribution.
  • Protection of local biodiversity in the Lleida region: We recognize the natural wealth of our environment
  • Promotion of reuse and recycling at all stages of production: We are committed to a full life cycle approach to minimize waste

5.2 Sustainable Innovation

Innovation is a fundamental tool to achieve our sustainability goals. Therefore, we integrate innovative technologies and models that allow us to optimize resources and reduce our environmental impact.

6. Labor relations and human rights

Our labor policy is based on promoting an inclusive, safe and conducive environment for the personal and professional development of each individual.

1. Fair working conditions:

Inclusive and safe work environment: We strive to create an environment where all employees can do their jobs free from harassment and discrimination. This includes:

  • Establish clear policies and effective processes to prevent, identify and address any form of harassment, discrimination, violence or intimidation.
  • Fairness and equity in compensation and benefits: Offer competitive and fair salaries and benefits, aligned with legal regulations and industry best practices. This includes prompt payment and recognition of additional work hours.
  • Work-life balance: We respect our employees’ personal time and promote reasonable work schedules, as well as conciliation measures such as family leave.

2. Promotion of development: Invest in the training and professional growth of employees.

Continuous training: At Costers del Sió, we believe that education and skill development are essential to the success of our employees and the winery.

  • Regular technical and professional training programs, adapted to the needs of each area.
  • Professional development plans.
  • Support in obtaining certifications or degrees related to the wine industry.

3. Diversity and inclusion: Respect cultural differences and promote equal opportunities.

At Costers del Sió, we value and promote diversity as a fundamental pillar of our organizational culture. We are committed to creating an inclusive and respectful environment where each person is valued for their contributions and abilities, regardless of their individual differences.

  • Commitment to diversity: We promote respect for cultural, religious, gender and sexual orientation differences, creating an environment where everyone feels valued and respected.
  • Equal opportunities: All employees, regardless of origin or condition, will have access to the same employment, training and promotion opportunities.
  • Inclusion of vulnerable groups: We are committed to the inclusion of people in vulnerable situations, thus contributing to their personal and professional development.

7. Relationship with the community and suppliers

Positive impact on the community: contribute positively to the autonomous community of Catalonia and the province of Lleida:

  • Participate in cultural and social projects in Lleida. In addition, make sponsorships and donations to social, cultural, sports activities, etc.
  • Social initiatives: collaborate with local suppliers that benefit society.
  • Promotion of local employment: Prioritize the hiring of local talent. Also encourage the incorporation of intern students from the University of Lleida.

Ethical collaboration: Our relationship with suppliers and business partners is based on principles of transparency, ethics and respect for the values ​​we promote. This includes:

  • Responsible supplier selection: through questionnaires
  • Promotion of sustainable practices
  • Relationships based on mutual respect: being the basis of fair and equitable commercial relations, beneficial for both parties.
  • Fight against corruption

Promotion of wine tourism: Promote activities that value the cultural and natural heritage of the region. This commitment includes:

  • Quality wine tourism experiences
  • Sustainability in wine tourism
  • Generating benefits for the community: through wine tourism, attracting visitors to the region, which boosts the local economy and encourages other businesses.

8. Actions against corruption, extortion and embezzlement

1. Corruption and Bribery

Corruption and bribery are incompatible with our values ​​and ethical standards. Therefore, we establish the following guidelines:

Strict prohibition of bribery: No employee, officer or business partner may accept, offer or solicit bribes in any form. This includes, but is not limited to:

  • Cash, expensive gifts, improper favors, or any benefit intended to influence business or government decisions.
  • Actions that may be perceived as an attempt to obtain unfair or inappropriate advantages

Gifts and hospitality: We only allow details that do not compromise the ethics or objectivity of the decisions. These include:

  • Low-value promotional material (such as pens, notebooks or calendars).
  • Reasonable invitations as long as they are transparent and in accordance with the winery’s policies.
  • Other related ones, as long as they comply with the winery’s policy.

Awareness and training

2. Extortion and Coercion

We reject any form of pressure, threat or coercion in business operations or labor relations.

Zero tolerance policy against extortion: We do not accept or practice any type of extortion or coercion, whether in our internal or external relationships. This includes:

  • Threats of retaliation against employees, suppliers or business partners who refuse to engage in illegal activities.
  • Improper use of influence or power to obtain personal or business advantages.

Confidential reporting channels: To ensure a safe and transparent environment, we have established reporting channels that allow employees to report any situation of coercion or extortion.

Reports can be made anonymously, and the winery is committed to guaranteeing the confidentiality and protection of complainants through email: [email protected].

Immediate Action on Reported Cases: We will investigate all allegations of extortion or coercion thoroughly and take disciplinary or legal action against those responsible.

3. Embezzlement of Funds

Responsible resource management is essential to maintaining the trust of our employees, business partners and the community.

Appropriate use of resources: The funds, assets and resources of the winery must be used only for authorized purposes and in line with the legitimate business objectives of Costers del Sió.

Misuse of company resources is strictly prohibited.

Documentation and traceability: All financial transactions must be clearly documented and recorded, ensuring that they are verifiable and comply with legal regulations. We avoid opaque or suspicious operations that could compromise the reputation of the winery.

9. Complaint and compliance mechanisms

At Costers del Sió, we have implemented a Complaints Channel through an exclusive email, designed to facilitate confidential communication of any irregularity or breach of the Code of Conduct: [email protected]. This channel is available to all employees, suppliers and business partners, guaranteeing the privacy of those who use it and ensuring that their concerns are addressed in an impartial and professional manner.

Each complaint received will be analyzed with rigor and objectivity to guarantee a fair and transparent process. Throughout the process, the confidentiality of the information will be maintained and the identity of the complainant will be protected.

If a violation of the Code of Conduct is confirmed, disciplinary measures proportional to the seriousness of the infraction will be applied. These can include everything from formal reprimands to the termination of employment or commercial contracts. Likewise, when the situation warrants it, the pertinent legal authorities will be notified to ensure that they act in accordance with the applicable laws and the corresponding sanctions are adopted.

10. Review and update of the code of conduct

The Costers del Sió Code of Conduct is a living document that reflects the values, principles and commitments of the winery. We recognize that regulations, ethical standards and organizational needs evolve over time, so we are committed to reviewing and updating it regularly to ensure its relevance and effectiveness.

We will conduct periodic reviews, at least annually, or more frequently if there are significant changes in the regulatory, social or business environment.

During the review process, the participation of employees, managers and other relevant groups will be encouraged, who may provide suggestions or point out areas for improvement.

Any updates will be communicated clearly and timely to all employees, suppliers and business partners. In addition, training or information sessions will be offered to ensure understanding and compliance with the new provisions.

REVIEW DATE RESPONSIBLE (Name and surname) SIGNATURE