INTRODUCTION
Code of Ethics
The Code of Ethics of LuxurEat and CaviarEat is a fundamental document that establishes ethical standards of conduct for directors, managers, employees, collaborators, and suppliers. The Code not only aims to ensure high ethical standards in business activities but also forms an integral part of an Organizational, Management, and Control Model in compliance with current regulations.
Including both general ethical principles and specific behavioral 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 stakeholders comply with the established standards.
Recipients
The CaviarEat and LuxurEat Code of Ethics applies to all individuals involved in company activities, including members of governing bodies, managers, employees, and external parties such as agents, intermediaries, consultants, suppliers, and clients. These individuals, referred to as “Recipients,” are required to comply with the principles and rules of conduct of the Code.
Violations may undermine trust with the company and lead to disciplinary measures or claims for damages, in accordance with applicable labor laws and regulations.
GENERAL PRINCIPLES
Human Rights
LuxurEat and CaviarEat place respect for human dignity at the core of their values, condemning all forms of discrimination and exploitation. Individual freedom is considered fundamental.
Compliance with Laws
The company is committed to complying with all applicable laws and regulations in every country where it operates, with special attention to international standards.
Integrity, Honesty, and Fairness
Recipients must maintain the highest standards of integrity, acting with honesty and fairness, avoiding conflicts of interest and unlawful gains.
Transparency and Verifiability of Operations
All operations must be transparent, verifiable, and properly recorded, ensuring accuracy and completeness of accounting information.
Excellence, Innovation, and Performance
Excellence is a core principle of LuxurEat and CaviarEat, leveraging advanced technical know-how to guarantee product quality. Innovation is a fundamental pillar, encouraging staff to develop creative solutions and continuous improvements. The company maintains a strong focus on performance, ensuring customer expectations are met in terms of quality and safety.
International Trade and Global Relations
LuxurEat and CaviarEat comply with international trade laws and regulations, including import/export controls, and interact with global partners in accordance with local and international laws.
Confidentiality and Privacy
The company ensures the protection of personal data, respecting privacy regulations and preventing unauthorized use.
Proper Use of IT Systems
Recipients must use IT systems responsibly, ensuring data security and integrity.
Prohibition of Disclosure of Sensitive Information
Recipients are prohibited from disclosing confidential or sensitive information they may access.
Proper Use of Company Assets
Recipients are responsible for safeguarding company assets, avoiding misuse or harmful practices.
Behavioral Standards
Relationships with clients must be based on fairness, transparency, courtesy, honesty, loyalty, and professionalism, in line with the Code of Ethics. Offering or accepting non-negligible gifts or benefits of significant value is strictly prohibited.
The company promotes transparency in commercial transactions and is committed to preventing money laundering, handling of stolen goods, terrorism, and organized crime, avoiding dealings with entities engaged in such activities.
TITLE I – PRELIMINARY PROVISIONS AND GENERAL PRINCIPLES
Art. 1 – Purpose of the Code
LuxurEat and CaviarEat, specialized in the trade of luxury products, particularly caviar, adopt this Code of Ethics with the aim of:
- Promoting commitment to excellence, quality, and sustainability in the luxury food sector.
- Ensuring that all business operations are carried out with integrity, transparency, and compliance with the law.
Art. 2 – Compliance with Principles
LuxurEat and CaviarEat commit to strict compliance with national and international laws, both in the agri-fishery sector and in the luxury goods sector, ensuring that employees and collaborators uphold these standards.
Art. 3 – General Rules of Conduct
LuxurEat and CaviarEat operate with loyalty, honesty, and fairness toward all stakeholders, including clients, suppliers, partners, and competitors, fostering a work environment based on these values.
Art. 4 – Updating and Dissemination
The Board of Directors is responsible for updating this Code of Ethics and ensuring its dissemination among collaborators and stakeholders, guaranteeing accessibility and clarity.
Art. 5 – Adhesion Clause
Joining LuxurEat and CaviarEat implies full acceptance and compliance with this Code of Ethics. Violations may result in sanctions as provided in the company’s bylaws. The company also ensures proper training on the Code for all new employees upon onboarding.
TITLE II – GENERAL RULES OF CONDUCT
Art. 6 – Fairness, Impartiality, and Transparency
All contractual relationships must be carried out with maximum clarity, truthfulness, and transparency, clearly specifying:
a) The type of product/service provided;
b) Terms and delivery methods;
c) Price, technical specifications, and payment terms.
Art. 7 – Professionalism and Diligence
The company undertakes to:
- Identify customer needs and tailor services accordingly.
- Ensure conformity and customer satisfaction.
- Maintain accuracy and safety in data management.
- Continuously improve internal processes and staff training.
- Select suppliers and external partners who share the same ethical standards.
Art. 8 – Privacy and Data Protection
LuxurEat and CaviarEat operate in full compliance with data protection laws, ensuring lawful, fair, and secure data collection and storage, avoiding discriminatory databases, and adopting appropriate security measures.
Art. 9 – Environmental Protection
The company actively reduces its environmental impact, promotes sustainability across its supply chain, and invests in technologies that minimize ecological effects.
TITLE III – RELATIONS WITH KEY STAKEHOLDERS
Art. 10 – Fair Contract Terms
Contracts must be fair, clear, and balanced, avoiding abuse of economic dependency.
Art. 11 – Good Faith in Contracts
The company ensures fairness and transparency in fulfilling contractual obligations with both suppliers and clients.
Art. 12 – Dispute Resolution
LuxurEat and CaviarEat prefer non-judicial methods such as mediation or arbitration through chambers of commerce or similar institutions.
Section I – Clients
Art. 13 – Duty of Loyalty
The company strives to understand and exceed client expectations, using systems to monitor and improve customer satisfaction.
Art. 14 – Conflict of Interest
Agents must avoid assignments that may cause conflicts of interest between clients or with the company.
Section II – Suppliers
Art. 15 – Supplier Relations
Supplier relationships are based not only on price, quality, and quantity, but also on reliability, ability to collaborate, and commitment to ethical practices.
Art. 16 – Transparency in Communication
Clients are informed about the Code of Ethics and its implications, ensuring awareness and accountability.
Section III – Employees/Agents/Collaborators
Art. 17 – Workplace Safety
The company complies with all health and safety regulations, ensuring ongoing training and preventive measures.
Art. 18 – Employee Engagement
LuxurEat and CaviarEat actively involve employees in achieving corporate goals, fostering respect, ethics, and professional growth.
Art. 19 – Compliance with the Code
Employees must align their actions with the Code of Ethics, understanding that personal conduct directly affects company reputation.
Section IV – Competitors
Art. 20 – Fair Competition
The company refrains from unfair competition practices and ensures fair collaboration where applicable.
Art. 21 – Advertising
All communications must be truthful, accurate, and non-misleading, reflecting the company’s responsibility toward clients.
TITLE IV – FINAL PROVISIONS
Art. 22 – Disciplinary Relevance of Violations
Violations of this Code of Ethics by employees, agents, or collaborators may result in disciplinary actions, ranging from written warnings to suspension or termination.
Art. 23 – Reporting Violations
Clients or stakeholders who believe a violation has occurred may report it through clear and accessible channels provided by the company. Reports will be properly assessed, ensuring accountability and ongoing improvement.