Code of Ethics

CODE OF ETHICS LA CAVEJA SRL

PREAMBLE

The La Caveja srl Corporate Code of Ethics is a set of principles, values, norms, and guidelines that establish the company’s expectations regarding the ethical behavior of its employees, as well as the rights, duties, and responsibilities of the company towards its stakeholders.

La Caveja is a recognized association structured as a limited liability company. Within this document, the company is to be understood as the legal entity responsible for rights and obligations as per the applicable regulations (Legislative Decree No. 231/01).

Since 1997, the company has grown, boasting a long and solid reputation for integrity and impartiality, which are arguably its most important assets. The Code of Ethics is the reference document that inspires all decisions and guides daily operations. This document has been approved and is fully supported by the Legal Representative and Administrator of La Caveja.

The company respects the legitimate expectations of its stakeholders, both internal and external. Through this mission, it explicitly defines the common purpose that regulates all activities of individuals and groups collaborating within the organization and interacting with it. The primary stakeholders include employees, internal and external collaborators, clients, suppliers, and consultants. Thus, this Code is based on an ideal of cooperation aimed at achieving mutual benefits for all parties involved.

The recipients of the Code of Ethics are all employees, without exception, and all those who, directly or indirectly, permanently or temporarily, establish relationships or connections with La Caveja and operate to pursue its objectives. The Code of Ethics must be respected by all involved parties and is valid both in Italy and abroad.

La Caveja employees and collaborators are required to be aware of the regulations, refrain from behaviors contrary to them, seek clarification or report concerns to the designated authority or management, cooperate with the structures responsible for verifying violations, and not conceal the existence of this Code from third parties. Compliance with the Code’s rules is an essential part of the contractual obligations of all employees under Article 2104 of the Civil Code.

Management, in carrying out projects, actions, investments, and setting corporate objectives, must be guided by the principles of the Code of Ethics. Those in leadership positions are required to set an example for their employees and collaborators, direct them toward compliance with the Code, and carefully select employees and collaborators who demonstrate maximum commitment to adherence to the rules. Each employee must also report to the designated authority any useful information about deficiencies in controls or behaviors, aiming to improve management systems and ensure correct conduct.

La Caveja srl is committed to promoting awareness of the Code of Ethics and enforcing its behavioral standards. The Governance and the responsible parties are tasked with monitoring its implementation, compliance, and updating as needed.

La Caveja also commits to continuously updating and improving the Code of Ethics to adapt to evolving civil awareness and relevant regulations.

 

ETHICAL PRINCIPLES OF REFERENCE

Legality, Honesty, and Fairness: Transparency, opposition to illegality, conflict of interest, anti-money laundering.

Relationships with stakeholders at all levels must be developed based on principles of honesty, moral integrity, fairness, transparency, and cooperation in pursuing corporate objectives.

Under the principle of transparency, La Caveja commits to clearly and transparently informing all employees and collaborators about the overall management of resources in their areas of competence, thereby safeguarding and potentially increasing the organization’s value. Additionally, it strictly complies with the rules issued by supervisory bodies and does not deny, conceal, or delay any information requested by authorities and other regulatory bodies during inspections.

Activities that could involve the company in unlawful practices are strictly prohibited. La Caveja demands a level of moral conduct that exceeds the minimum legal requirements and distances itself from any form of corruption or conflict of interest.

La Caveja adopts all appropriate measures and precautions to ensure transparency and fairness in commercial transactions, in compliance with the principles outlined in its anti-money laundering and crime prevention policies.

Employee Health and Safety

La Caveja is committed to ensuring safe and healthy working conditions that respect individual dignity and guarantee the physical and moral integrity of its employees and collaborators. It adopts and maintains appropriate management systems aimed at identifying, preventing, and responding to potential risk situations, ensuring the health and safety of all personnel.

Consumer Health and Safety

In all processes of procurement, production, packaging, and storage of its products, La Caveja is committed to complying with all national and international laws and regulations, as well as generally recognized best practices. Its decisions and behaviors are also inspired and regulated by Quality and Food Safety standards according to international IFS Food management principles.

Protection of Individual Freedom and Equal Opportunities

La Caveja avoids any discrimination based on age, gender, sexuality, health status, race, nationality, political opinions, or religious beliefs in all decisions affecting its stakeholder relationships.

Protection of People and Enhancement of Human Resources

La Caveja is committed to creating conditions in which employee participation in decision-making is carried out in an informed work environment that promotes equality and completeness of information while safeguarding their interests. It promotes freedom of association and respect for interpersonal relationships. Specifically, it values and enhances human resources to improve and expand the knowledge and skills of each collaborator.

Environmental Sustainability

La Caveja raises awareness about sustainable development and is committed to improving the environmentally responsible management of its activities, considering the rights of future generations. It is aware of the effects of its operations on the local environment, economic and social development, and overall community well-being. Therefore, it operates with respect for local and national communities and supports initiatives of environmental and social value.

Confidentiality, Privacy, and Protection of Company Assets

La Caveja ensures the confidentiality of information in its possession, complies with data processing regulations, and commits to not using confidential information for purposes unrelated to its business activities. It protects its intellectual property by allowing access only to authorized personnel and prevents the misuse of confidential information by collaborators. Furthermore, it ensures the conservation and protection of physical assets, educating employees and collaborators on the correct use of entrusted resources.

Relationships with Third Parties and Clients

La Caveja directs its activities towards customer satisfaction and protection, listening to requests that may lead to improvements in product and service quality.

 

RULES OF CONDUCT

Legality, Honesty, and Fairness: Transparency, opposition to illegality, conflicts of interest, anti-money laundering.

Employees and collaborators must act loyally to fulfill their contractual obligations and comply with this Code of Ethics, ensuring the required performance.

No false or artificial accounting entries may be included in the company’s records for any reason. No employee may engage in activities leading to such misconduct, even if instructed by a superior. The responsibility for an effective internal control system lies with the entire organizational structure. Employees must report in writing to their superior or the Ethics Committee any omissions, falsifications, or accounting irregularities they become aware of.

In alignment with its values of honesty and transparency, La Caveja undertakes all necessary measures to prevent and avoid unlawful conduct. It strictly prohibits the payment of bribes or other forms of corruption to obtain direct or indirect advantages for the company. Employees must avoid situations of conflict of interest and refrain from deriving personal benefits from opportunities that compete with the company’s interests. Any apparent or actual conflict of interest must be reported to management.

Gifts, favors, or other benefits for personal or others’ gain from individuals who benefit or may benefit from company decisions are strictly prohibited.

All individuals must operate in full compliance with anti-money laundering regulations, ensuring they are not involved in activities facilitating money laundering, self-laundering, or the use of illegally obtained funds or assets.

 

This document serves as a comprehensive and enforceable ethical framework for La Caveja srl and all its stakeholders.