ENG

ETHICAL 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:

GADISA RETAIL SLU
GRUPO Empresarial Gadisa Retail

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.

Mountain View Invest, S.L.U.
Bienes Inmuebles Corporativos Atlánticos 2008, S.L.U.
GRUPO Empresarial INTASA

Industrias del Tablero, S.A.
Madeiras do Xurés, S.L.U.
Unión de Empresas Madereras, S.A.U.
Eume Maderas, S.L.

GRUPO Empresarial Forestal del Atlántico e Imegasa

Forestal del Atlántico, S.A.
Impregnaciones Melanímicas Gallegas, S.A.U.

GRUPO Empresarial de Transportes

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.
Trapi 2023, S.L.U

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”.

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.

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 GROUPs relations with its employees, clients, suppliers, collaborators, public administrations, and society in general.

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

Mission

Our mission is to sustainably offer the widest variety of products that cater for people`s needs at the best value for money, sharing the value and wealth we generate with the local area.

Vision

GADISA Retail`s vision is to improve people`s well-being in a sustainable and ethical way and to be the retail company of choice for both our customers and employees.

Values

Approachability: We are committed to approachability, honesty and dedication to service in order to satisfy the needs of our one million customers.
Quality: We meet the highest standards in our food distribution and industrial processes while maintaining the highest quality in our products and services.
Environmental Sustainability: We continuously look to contribute towards environmental protection and social welfare, especially in the communities in which we operate. This also safeguards the future of our own operations.
Transparent management: We manage our operations based on an ethical and responsible business model built on the principles of good governance.
Continuous Improvement: We promote the development and retention of talent and knowledge in order to ensure the efficiency and viability of our operations.
Legal Compliance: We respect the environment in which we operate and comply with applicable laws and regulations.
Wealth Creation in Dignified Conditions: We improve quality of life for all our stakeholders. At GADISA Retail, we understand human value as a fundamental part of the organisation`s success and, therefore, ensuring that we contribute to society is part of our company philosophy.
CSR: We aim to meet the needs of society as if they were our own needs, committing ourselves to social, economic, cultural and sporting development, promoting healthy lifestyles and working for a fairer society.
Innovation: We are constantly innovating to improve our service and customer care. Innovation is part of GADISA Retail`s identity.

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.

III. General guidelines of the Code of Ethics

To ensure respectful behaviour at all times, we have developed a Code of Ethics that sets out internal guidelines for behaviour and conduct. It is a fundamental tool as part of our commitment to human rights and is structured around the following principles:

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

Environmental protection

The business carries out activities that respect the principles and criteria of sustainability and environmental protection, with priority being given to responsible management of environmental resources.

Collective Rights

The relationship with workers` representative organisations shall be based on mutual respect in order to promote a climate of dialogue and transparency.

Respect for people in working relationships

The business promotes professional relationships based on mutual respect and collaboration. Harassment, abuse, bullying, intimidation, disrespect or any kind of aggression or undignified treatment will not be tolerated under any circumstances.

Work-Life Balance

GADISA Retail is committed to improving the quality of life of its employees, which is why it promotes a working environment that is compatible with professional and personal development.

Workplace health and safety and the prevention of occupational hazards

GADISA Retail has developed a system to prevent potential occupational hazards and carries out planned preventive activities.

Food safety and quality of the products on offer

GADISA Retail offers top-quality products that pass all applicable health controls and standards.

Compliance and ethical behaviour

All those subject to the Code of Ethics shall act in strict compliance with the law in force, as well as with the GADISA Retail internal procedures that apply to their role in the business.

Confidentiality of information

Any person subject to this Code is obliged to protect confidential or proprietary information and shall not use it outside the scope of their employment relationship.

Integrity in dealing with customers and suppliers

It is understood as an obligation to treat all GADISA Retail customers and suppliers with fairness and integrity by working to understand and meet their needs.

IV. External Relations

Relationships with Suppliers

The relationship with the suppliers of the GADISA GROUP is based on mutual conditions of seriousness, rigor and respect, and 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.

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.

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 GROUPs 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.

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.

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

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.

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.

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.

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 Codes

Such facts must be reported directly to the Supervisory and Control bodies through the whistleblowing channels. GADISA GROUP will protect any employee who raises a concern in an honest manner, although making false or unfounded allegations or failing to cooperate in the investigation of any non-compliance may constitute a violation of this Code.

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. Internal reporting system / Ethics Channel

In order to encourage compliance with the law and the rules of conduct set out in this Code of Ethics, a web platform for the Whistleblowing Channel or Ethical Channel, which can be accessed from the GADISA website, is made available to the Subjects of the Code of Ethics and to any stakeholder with whom the GADISA Group has relations, so that they can report any conduct that may involve the commission of any irregularity.