INTRODUCTION

This Code of Ethics defines the ethical commitments and responsibilities that  SANDRONE LUCIANO Società Semplice Agricola upholds, every day, in cultivating its grapevine, producing its wines, entertaining relationships and maintaining, as well as promoting, the values on which Luciano Sandrone had based his life and work, namely love, endeavour, competence, respect for the earth and its fruits, as well as daily and continuous hard work, always with care for the people and their environment.

The principles which have inspired the work of Sandrone Luciano ssa are formally collected in a Behavioural Code of Ethics, with the conviction that reliability is constructed daily by respecting the rules of communal living, valuing people and protecting the environment.

This Code of Ethics represents, therefore, a distinctive and identifying element for the Market and for Third Parties, whose recognition and promotion, requested of all those who work for and/or collaborate with the Company, constitute the foundation of our business and our vision.

The objective of Sandrone Luciano ssa has always been that of pursuing excellence  within the Market in with it operates, through sustainable development, protecting  the Environment and the Safety of the People involved, thanks to the constant display of a behaviour mindful of Social Ethics, in order to obtain satisfaction and to ensure added value for Employees, Customers, and the Community as a whole.

PURPOSE AND ADDRESSEES

This Code of Ethics (hereafter, "Code") illustrates all the moral and ethical principles which form the basis of the activities of SANDRONE LUCIANO Società Semplice  Agricola (hereafter “Sandrone Luciano ssa”) as well as the lines of conduct  adopted by the Company both internally (regarding the relationship with its employed or collaborating Personnel) and externally (regarding the relationship with institutions, suppliers, customers, business partners, political organizations and trade unions, as well as organs of information - hereafter “Stakeholders”).

This Code is binding for the Associates, the Administrators and the Employees of Sandrone Luciano ssa, as well as for all those who, permanently or on a fixed-term basis, work for and collaborate with Sandrone Luciano holding any position and pursuing any purpose (hereafter “Addressees”).

The Code shall be shared by the Company both internally and externally, as well as through its website to ensure its most efficient diffusion and distribution.

1 GENERAL PRINCIPLES

The conduct of the Addressees, on all levels, must be based on the principles of           lawfulness, correctness, non-discrimination, reservedness, diligence, loyalty and sustainability.

1.1 Lawfulness

Sandrone Luciano ssa operates in compliance with the law, the rules and the present Code.

All Addressees, and every individual according to his or her role, competence and responsibility, is required to observe the law, keeping abreast of legislative developments and the applicable rules; to this end, Sandrone Luciano ssa strives to offer training sessions to the Addressees.

Sandrone Luciano ssa deems transparency and the respect of the law the founding principles for the exertion of its activity and for the safeguarding of its reputation.

1.2 Correctness

Correctness and moral integrity constitute a duty for all Addressees. The Addressees are required not to establish any privileged relationships with Third Parties which derive from external solicitations aimed at obtaining inapt advantages. In the exertion of their activity, the Addressees are required to not accept any donations, favours or benefits of any kind (save objects of modest value) and, in general, not to accept any exchange aimed at inappropriately favouring third parties.

Moreover, the Addressees must not make donations in the form of money or goods to third parties or offer illicit favours or benefits of any kind (save objects of modest value or business courtesies authorized by the Company) in connection with the work provided by latter to the benefit of Sandrone Luciano ssa.

1.3 Non-Discrimination

In the relationship with Stakeholders, and in particular in the selection and management of their personnel, in the organization of work, in the selection and management of their suppliers, as well as in the relationship with Authorities and Institutions, Sandrone Luciano ssa condemns any discrimination regarding the age, sex, race, sexual orientation, health status, political opinion and trade union membership, religion, culture and nationality of its interlocutors.

1.4 Reservedness

Sandrone Luciano ssa strives to ensure the protection and the confidentiality of the personal data of the Addressees and the Stakeholders, in compliance with the applicable privacy regulations.

The Addressees strive to never use confidential information, gathered by reason of their working activity and/or collaboration, for purposes which go beyond the exertion of that activity; they furthermore strive to act in accordance with the obligation of reservedness assumed by Sandrone Luciano ssa towards its Stakeholders.

The Addressees must observe the highest level of confidentiality in dealing with documents liable to reveal company know-how regarding the production or other aspects, business information, information regarding the company’s marketing and communication, as well as information on transport and corporate transactions, even after their relationship with Sandrone Luciano ssa has ceased.

1.5 Diligence

The relationship between Sandrone Luciano ssa and its Employees and Collaborators is based on mutual trust: the latter are, therefore, required to operate in favour of the Company’s interests, acting by the values to which this Code refers.

The Addressees must abstain from any activity that might constitute a conflict with the interests of Sandrone Luciano ssa, refraining from pursuing personal interests in conflict with the legitimate interests of the Company and communicating possible conflicts of interest to the latter.

In cases of a violation of the aforementioned rule, Sandrone Luciano ssa can adopt any appropriate measure to end the conflict of interests, reserving itself the right to protect itself.

1.6 Loyalty

Sandrone Luciano ssa and the Addressees strive to act with loyalty, following the principles of fair competition as well as the national and international regulations, with the conviction that fair competition stimulates growth, innovation and development, and protects the interests of the Consumers and the Community.

1.7 Sustainability 

Sandrone Luciano ssa strives to conduct its activity respecting the environment and the principles of environmental sustainability.

Sandrone Luciano ssa and the Addressees strive to observe the national and international regulations, aiming to protect and safeguard their environment, to achieve climate neutrality. 

2 RELATIONSHIP WITH EMPLOYEES AND COLLABORATORS

       Sandrone Luciano ssa values and protects its Human Resources, acknowledging the professionality and personal characteristics of each individual, whilst guaranteeing professional growth through continuing education and other initiatives aimed at reaching this objective.

Sandrone Luciano ssa encourages its resources to take part in the life of the company, mindful of the fact that everyone’s contribution is essential not only to personal growth, but to the development of the company.

Notwithstanding his or her maximum availability granted to the Company, no Resource can be obliged to fulfil tasks or offer services or favours that are not foreseen in his or her respective work contract or appropriate to his or her role within the Company. Sandrone Luciano ssa endeavours to counteract occurrences of bullying, stalking, psychological violence and any behaviour that is discriminatory or harming the personal dignity, inside and outside the company premises.

The relationships between the Employees and the Collaborators must be characterized by loyalty, correctness and mutual respect, in compliance with the rules of civil coexistence and personal freedoms.

The evaluation and selection of the Personnel occur according to the principles of correctness, transparency, and equality of opportunities.

Hired Personnel, inter alia through the transmission of this Code, receive clear and correct information regarding the roles, responsibilities, rights and duties pertaining to their positions.  

3 WORK ENVIRONMENT

Sandrone Luciano ssa strives to provide the Addressees with a work environment which is healthy, safe and mindful of the Resources’ personal dignity, whilst guaranteeing health protection and the compliance with hygiene standards.

Safety in the workplace is ensured through the observance of the relevant legal framework and through the active promotion of a culture of safety during specific training programmes. 

The training of Personnel constitutes a key element in the management system adopted.

4 WORK MANAGEMENT AND HERITAGE PROTECTION       

4.1 Observance of Internal Procedures

The Addressees are required to strictly observe the Procedures and Instructions issued by the Company.

The Addressees must act according to their respective authorization profiles and preserve any adequate documentation in order to keep track of the actions undertaken on behalf of the Company.

4.2 Account Management

In their activities of Account Management, the Addressees are required to act according to the principles of veracity, accuracy and transparency in order to protect the reputation of Sandrone Luciano ssa, both internally and externally. The respect of these principles permits the Company to plan its operative strategies based on its actual financial position, avoiding any form of omission, falsification and/or irregularity.

In dealing with financial elements based on evaluations and estimations, the relative registration must be inspired by the criteria of reason and prudence.  

4.3 Protection of the Viticultural Heritage

The Viticultural Heritage is the Origin and the Aim of Sandrone Luciano ssa. All Addressees are required to act in favour of the preservation of the company’s Viticultural Heritage, respecting the traditions, as well as the rules and techniques guaranteeing the best agronomic management, the rules regarding the protection of the environment and those regarding safety in the agri-food industry, with due attention to the technological and scientific innovations useful to the achievement of environmental sustainability.

4.4 Protection of the Viticultural Heritage

The Viticultural Heritage has been represented by the Winemaking Activity of the Company from its infant days, carrying today the title of Historic Winery.

The Addressees strive to maintain the highest level of reservation regarding the transformation and vinification methods employed by Sandrone Luciano ssa, the fruit of the ingenuity of its founder, Luciano Sandrone, applied in continuous research of technical Innovation respecting Tradition, and developed throughout the course of over 50 years of work, in accordance with the regulations regarding the protection of agri-food products and hygiene.

4.5 Relational Assets

The Relational Assets of the company comprise all relationships, connections and partnerships which it has acquired over the years of its existence worldwide, thanks to the recognition of the quality of the work of Sandrone Luciano ssa, its striving for excellence in production through innovation, its commitment to sustainable development and its work ethic.

The Addressees strive to maintain maximum levels of reservedness and to not share any information regarding the Company’s relationships, be they of commercial or financial nature, or regarding the production, marketing strategies or research and development, acquired by Luciano Sandrone ssa in the course of, and following, the years of its existence on the Italian and Global markets.

4.6 Cybersecurity

The Addressees are required to correctly apply the safety regulations in order to protect the hardware devices from unauthorized access liable to constituting a severe violation of the rights to the Protection of Personal Data of the Personnel and the Customers of Sandrone Luciano ssa, as well as to refrain from illicitly spreading information regarding the Company’s production and commerce essential to Sandrone  Luciano ssa.

4.7 Communication

The information shared with Stakeholders must be complete and accurate, to enable the Addressees to make correct and informed choices. Sandrone Luciano ssa encourages efficient business communication whereby the Company enters into contact with Externals, in order to be informed about the requests, needs and demands of the Community and to share its values.

The advertising promotion of Sandrone Luciano ssa respects ethical values, protecting individuals and condemning discriminatory, offensive or vulgar messages.

5 EXTERNAL RELATIONS

5.1 Relations with Authorities and Public Administrations

All relations with Public Administrations must be characterized by maximum clarity, transparency and collaboration, in compliance with the law, as well as the moral and professional values on which Sandrone Luciano ssa bases its work.

In their relations with Public Officials, Public Service Providers and the Public Administration in general, the authorized Addressees are required to operate with the highest level of correctness and integrity.

5.2 Relations with Political Organizations and Trade Unions

Sandrone Luciano ssa does not favour, or discriminate against, any political organizations or trade unions.

The Company refrains from making any inappropriate contribution of any kind to political parties, trade unions or other social groups, except for specific derogations and in any case, always within the limits set by the applicable law.

The Addressees are required to refrain from exerting any kind of direct or indirect pressure on representatives of political organizations or trade unions.

5.3 Relations with Customers and Suppliers

All Addressees must relate to third parties in a polite, competent and professional manner, aware of the fact that the protection of the company’s image and reputation depends on their conduct, refraining, therefore, from any disloyal or misleading behaviour which may lead the Customers or the Suppliers to rely on false information and inaccurate circumstances.  

The Addressees are required to continuously strive to offer punctual services of high quality to the Customers, avoiding any form of disservice or delay, to ensure maximum customer satisfaction.

Relations with Suppliers must be based on loyalty, correctness and transparency. The selection of suppliers occurs based on objective criteria regarding cost-effectiveness, opportunity and efficiency.

This Code prohibits a choice of Suppliers based merely on subjective or personal criteria, or ones conflicting with the values and interests of the Company.

The Addressees are required to ascertain in every possible way that Suppliers and Customers, too, are able to respect the ethical principles fundamental to the present Code.

 

6 VERIFYING THE RESPECT OF THE CODE 

The respect of the rules contained in the present Code is to be placed under the prudent, reasonable and attentive surveillance of every one of the Addressees, within their respective role and function within the Company.

All Addressees are invited to report any facts or circumstances potentially contrasting with the principles and the rules of the present Code to their direct superiors.

7 SANCTIONS

The violation of the principles defined in this Code and in the Procedures indicated for internal checks compromises the trust relationship between the Company and its Associates, Administrators, Employees, Consultants, Collaborators of any type, Customers, Suppliers, as well as Commercial and Financial Partners.

Such violations shall immediately be persecuted by Sandrone Luciano ssa in a timely and incisive manner, through the adoption of adequate and proportionate disciplinary measures.

Depending on the severity of the conduct displayed by the person involved in one of the illicit activities defined in the Code, Sandrone Luciano ssa shall immediately proceed to take those measures deemed appropriate, independently of the possible application of a criminal action by the judicial authority.

Notwithstanding the above-mentioned, behaviours that constitute a violation of the Code of Ethics entail:

• breach of contract for Employees, with those sanctions, applied according to severity, foreseen by the employment contract of the category of reference; in case of criminal prosecution or in case of the adoption of freedom-restricting measures against the employee, the latter may be suspended from his or her service and from his or her salary for a duration corresponding to the outcome of the criminal prosecution or till the end of the freedom-limiting measure;
• just cause for the termination of the mandate of Administrators;
• just cause for the immediate termination of the contractual relationship, in the most severe cases, for external Collaborators and contract workers;
• just cause for the immediate termination of the work relationship, in the most severe cases, for Suppliers, Contractors and Subcontractors.

The definition and application of the sanctions shall always consider the general principles of proportionality and adequacy in regard to the disputed violation. In any case, Sandrone Luciano ssa reserves itself the right to exert all actions which it deems appropriate to the compensation for the damage suffered as the immediate result of the behaviour constituting a violating of the Code of Ethics.

Penned in Barolo, 15 December 2024