GRAU JEWELRY CODE OF ETHICS
This Code of Ethics includes the ethical principles on which the activity of Grau Lloret, SL is based, contains a description of the behaviors that must be promoted and the behaviors that must be avoided.
2. SCOPE OF APPLICATION OF THE CODE OF ETHICS
The code of ethics includes the catalog of standards that are applicable to the administrators and all employees of Grau Lloret, SL, including trainees and interns. With the application of the Code, it is intended that the people who carry out their activities within Grau Lloret, SL demonstrate upright and professional behavior at all times and contribute to a good environment and the commitment of Grau Lloret, SL, denouncing conduct that may harm your image and/or reputation.
The scope of application of this Code of Ethics will be extended, to the extent possible, to suppliers, customers and any other natural or legal person who may affect Grau Lloret, SL with their actions.
3. GENERAL PRINCIPLES OF THE CODE OF ETHICS
3.1. Respect for people
Grau Lloret, SL will promote at all times, relationships based on respect for others and reciprocal collaboration. Grau Lloret, SL assumes the commitment to ensure that there is a work environment free of any type of violence and/or harassment, with the consequent prohibition of all types of discrimination, intimidation and offensive or improper conduct, lack of respect or any type of physical or verbal aggression in professional relationships within the Company.
3.2. Principle of equality and non-discrimination
Grau Lloret, SL's basic principle is to maintain a work environment in which the dignity of all people is respected and any type of conduct that violates the fundamental rights protected by the Spanish Constitution and the legal system is avoided. general.Grau Lloret, SL expresses its firm commitment to the principle of promoting equal opportunities in access to work and professional promotion, avoiding at all times situations of discrimination or inequality based on gender, race, social or sexual condition , marital status, religion, union affiliation, illness or disability or any other circumstance.
3.3. Safety at work
At Grau Lloret, SL, the preventive measures applicable to occupational health and safety will be respected at all times. To this end, they have the obligation to know and use the resources that Grau Lloret, SL puts at your disposal in matters of safety and occupational risk prevention and, where appropriate, ensure that the members of its teams carry out their activities in safe conditions.
3.4. Labor rights
Under no circumstances will Grau Lloret, SL be imposed labor or Social Security conditions that harm, suppress or restrict the rights that workers have recognized by legal provisions, collective agreements or individual contracts. Neither will workers be hired without notifying their registration in the corresponding Social Security regime.
In relation to foreign workers, they will not be hired without having obtained the corresponding work authorization. Nor will contract or placement simulation techniques be applied in any case.
In the personnel selection processes, a methodology will be used that guarantees the veracity of the job offers and in no case will misleading or false working conditions be offered. In the case of contracting with foreign suppliers, Grau Lloret, SL will ensure that in none of them are cases of child exploitation.
3.5. Reconciliation of work and personal life
Grau Lloret, SL will promote a work environment compatible with personal development, facilitating access among the people in its teams to measures that facilitate the reconciliation of the performance of professional activity in Grau Lloret, SL with the needs of their personal life, in order to improve the quality of life of employees and their families.
3.6. Protection of the environment
Grau Lloret, SL, within the scope of its powers, must respect the legal requirements and internal procedures established at all times, to respect the natural environment, minimize the consumption of resources, promote sustainability and control the environmental impact of its activities.
4. GUIDELINES OF CONDUCT FOR SPECIFIC SITUATIONS
4.1. Conflicts of Interest
The administrators and workers will always act in such a way that their particular interests, those of their relatives or other people related to them do not prevail over those of Grau Lloret, SL or its clients. This guideline of conduct will be applied both in relations with Grau Lloret, SL, as well as with clients, suppliers or any other third party. The administrators and workers will identify and report situations of both potential and real conflict of interest, including those derived from kinship or other related relationships.
4.2. Privileged Information
The administrators and workers who have privileged information will not carry out operations on their own behalf or on behalf of others, directly or indirectly, on the securities or instruments to which it affects. Neither will they promote, support or recommend that others carry them out. Privileged information is considered to be any information of a specific nature that has not been made public, and that, if made public, could significantly influence the organized system Grau Lloret, SL
4.3. Duty of Confidentiality
Administrators and workers must keep professional secrecy regarding any data or information they learn as a result of the exercise of their professional activity, whether they come from or refer to Grau Lloret, SL, its workers, customers and suppliers or any other third party. They must comply with the obligation of secrecy even after their relationship with Grau Lloret, SL has ended.
4.4. Relations with suppliers
Supplier selection processes are characterized by the search for competitiveness and quality, guaranteeing equal opportunities among all of them. Administrators and workers and, especially, those involved in decisions on the contracting of supplies or services or In setting their economic conditions, they will avoid any kind of interference that may affect their impartiality or objectivity in this regard.
4.5. Relationships with customers
Efforts will be made to avoid an exclusive relationship with a customer that may lead to excessive personal ties or restrict the customer's access to other employees or channels of Grau Lloret, SL
Customers must be made aware of any financial or of another nature that could entail a conflict of interest with them, adopting the necessary measures to prevent it from interfering in the client's relationship with Grau Lloret, SL
4.6. Protection of Personal Data
Administrators and workers are obliged to respect the right to data protection, the right to honor and personal privacy of all persons whose data they have access to due to the performance of their activity within Grau Lloret , SL Said respect must be applied to any information concerning a person: identification data, affiliation, family, economic, audiovisual or any other type that allow their identification. Personal data will be treated in accordance with the principles established in the data protection regulations.
4.7. Regulations of the Manual for the Prevention of Money Laundering
Administrators and workers will strictly comply with the regulations established in the Manual for the Prevention of Money Laundering and Terrorist Financing.
4.8. Use of Information and Communication Technologies
Administrators and workers will ensure the prevention and control of crimes that may be committed through the use of information technologies, the most notable of which are:
· Unauthorized access to computer systems of competitors, customers or any other company or public or private organization.
· Spread of viruses or programs that may cause damage to tangible or intangible assets.
· Any other type of computer damage, including sabotage or the simple alteration of data or information contained in a third-party computer system.
· Electronic scams and any type of deception based on the use of information technology.
· Dissemination of rumours, criticism and boycotts through the Internet and social networks, retweets and forwarding of messages of any kind.
· Infringement of intellectual or industrial property of technological assets.
· Industrial espionage through the Internet.
· Unauthorized transfer of databases.
4.9. Intellectual and industrial property rights of the
Grau Lloret, SL Group is the owner of the property and rights to use and exploit computer programs and systems, equipment, manuals, videos, projects, studies, reports, advertising campaigns and other works and rights created, developed, perfected or used by its employees, within their work activity or based on the computer facilities of Grau Lloret, SL Administrators and workers:
· They will respect the intellectual property and the right of use that corresponds to Grau Lloret, SL in relation to computer programs and systems; equipment, manuals and videos; knowledge, processes, technology, "know-how", advertising campaigns, and in general, other works and works developed or created in the Company. Therefore, their use will be made in the exercise of professional activity and all the material on which they are supported will be returned when required.
· They must also respect the principle of strict confidentiality in terms of the characteristics of the rights, licences, programs, advertising campaigns, systems and technological knowledge, in general, whose ownership or exploitation or use rights correspond to Grau Lloret, SL
· They must not exploit, reproduce, replicate or assign the computer systems and applications of Grau Lloret, SL for purposes unrelated to it, whether said activity is remunerated or not, and even if said activity is carried out using any system, medium or computer application of the Company even outside the employee's working hours.
· They will not use the image, name, trademarks or logo of Grau Lloret, SL, except for the proper development of their professional activity in it.
· They will respect the intellectual and industrial property rights held by third parties outside Grau Lloret, SL In particular, the use in the Company of any content belonging to third parties will require prior authorization from said third parties.
4.10. Corporate image and reputation
Grau Lloret, SL considers its corporate image and reputation as a very valuable asset to preserve the trust of its shareholders, employees, customers, suppliers, authorities and society in general. The administrators and workers must take the utmost care to preserve the image and reputation of Grau Lloret, SL in all their professional actions.
4.11. Tax and Social Security Obligations
Grau Lloret, SL will promptly comply with its tax and Social Security obligations. The administrators will be informed of the tax policies applied by Grau Lloret, SL Grau Lloret, SL's accounting will faithfully reflect the economic situation of the same, all those practices that involve the illegal avoidance of the payment of taxes to the detriment of the Public Treasury will be avoided and of the Social Security. Grau Lloret, SL will be attentive to any client or supplier that tries to use the structure of Grau Lloret, SL for a money laundering operation or related to the financing of terrorist activities. Any suspicion of a risk situation in this matter will be immediately reported to the Ethical Channel. Payments will not be made to natural or legal persons other than those that appear on the invoice or in the contract that regulates their relationship with Grau Lloret, SL, except in in the event that there is a legal justification (seizure, assignment of credits, etc.) that authorizes making said payment. No charges will be received from natural or legal persons other than those that appear on the invoice or in the contract that regulates their relationship with Grau Lloret, SL, except in the event that there is a legal justification (seizure, assignment of credits, etc.) that authorizes said collection.
5. SPECIFIC RULES TO AVOID CORRUPTION BEHAVIORS
5.1. Compliance with the law
Grau Lloret, SL bases its relations with the public and private sectors, both nationally and internationally, on the principles of transparency and equal opportunities, and rules out any action aimed at achieving an advantage over competitors, in the market or in public or private contracts based on an illegal act. Consequently , Grau Lloret, SL:
· It rejects any conduct, practice or form of corruption, expressly prohibiting any action of this nature.
· All professionals must observe ethical behavior in all their actions and avoid any conduct that, even without violating the law, could harm the reputation of Grau Lloret, SL and negatively affect its interests and/or its public image.
5.2. Guidelines to avoid engaging in corrupt behavior of public officials
The delivery or acceptance, promise or offer of any kind of payment, commission, gift or compensation to any authorities, public officials or employees or directors of companies or public bodies is absolutely prohibited. both in Spain and abroad. In the event that Grau Lloret, SL contracts with agents, intermediaries or advisers to carry out transactions or contracts in which a public Administration, a public body or a public company, both national and international, is involved. Spanish as a foreigner, the following measures will be adopted:
· Entities of well-known prestige in the market or sector in question will be used as agents, intermediaries or advisors.
· Due diligence will be adopted in the selection of the persons involved and their collaborators, to ensure that they are trustworthy and do not carry out activities that may imply risks, economic damages or compromise the reputation and good image of Grau Lloret, SL
· In general, a special precaution will be taken in those cases in which the remuneration of the agent, intermediary or adviser is linked to the success of the transaction or contract.
5.3. Guidelines to avoid incurring in private corruption conduct
The delivery or acceptance, promise or offer of any kind of payment, commission, gift or remuneration to any employees, directors or administrators of other companies so that they favor Grau Lloret, SL is prohibited with respect to other competitors. The subject persons must reject and inform the Management of any request by third parties both in Spain and abroad for payments, commissions, gifts or compensation of the aforementioned in favor of Grau Lloret, SL and to the detriment of from third parties.
6. APPLICATION OF THE CODE OF ETHICS
6.1. Prevention and control model
Grau Lloret, SL has a Prevention and Control Policy that describes a prevention and control model aimed at avoiding crimes in the company. This policy contains a description of the key elements that Grau Lloret, SL applies to avoid violations of the law and acts that may be classified as a crime in the Penal Code.
Administrators and workers have the obligation to communicate risk situations that may occur inside or outside the company, which may cause damage or harm to any natural or legal person. In addition to situations of non-compliance with the law, the Code of Ethics or the regulations that develop it. Grau Lloret, SL has an Ethical Channel to which communications that alert about the existence of a situation of risk or non-compliance can be directed, as well as any proposal to improve the prevention and control model. The Ethics Committee will be responsible for managing the channel and dealing with the communications that are sent to it.
Supervision of compliance with the Code of Ethics corresponds to the Ethics Committee, which will include in its review model the necessary controls to verify that the provisions of the Code of Ethics are complied with, will make the necessary proposals for its improvement, and will periodically inform Grau Lloret, SL about its application.
6.3. Non-compliance and sanctions
The behavior of all professionals must comply with this Code of Ethics; they will maintain a collaborative and responsible attitude in the identification of situations of real or potential non-compliance with the ethical principles and rules of conduct contained in this Code, and they will communicate them to the instances in charge of resolving them. Failure to comply with the Code of Ethics may lead to the application of the sanctioning regime established in the corresponding Collective Agreement, without prejudice to the administrative or criminal sanctions that, where appropriate, may be applicable. The sanctioning procedure will begin from a communication, as a result of an investigation or as a result of any other in a manner that allows the Ethics Committee to learn about the alleged infringement. The investigation protocol for the alleged infringement will be that established in the Prevention and Control Policy of Grau Lloret, SL and will be confidential.
7. COMPLAINTS CHANNEL
The objective of the Complaints Channel is the reception, retention and treatment of complaints about irregularities or breaches of the regulations, committed by employees or companies.
To send us your complaint, please fill in the information requested through the Grau Jewelry Complaint channel, which you will find in the following link: https://joieriagrau.factorialhr.es/complaints