Code of ethics & conduct apply

To whom does this Code of Ethics and Conduct apply?

This Code of Ethics and Conduct applies to all:
-    employees, sales agents and trade representatives,
-    company officers and members of the executive and management committees,
-    suppliers and commercial partners,
(hereinafter referred to as “Colleagues”) of companies within the BOISSET Group (hereinafter referred to as the “BOISSET Group” or the “Group”) in all the countries in which we operate.

A shared commitment to compliance with our values and ethical principles will allow the Group to maintain its image and reputation and pursue its development safely and securely.

BOISSET Group means the business entity formed by the company GRANDS VINS JEAN CLAUDE BOISSET, a French joint stock company with capital of €7,693,864, whose registered office is at Rue des frères Montgolfier – 21700 NUITS-SAINT-GEORGES, registered with the Dijon Trade and Companies Register under number 300 221 017 (as the controlling company) and all the companies it controls.

 How should this Code be used?

This Code of Ethics and Conduct has been designed to underpin the values and policies implemented and pursued by the Group, and aims to provide a better understanding of their logic and purpose.

The BOISSET Group recognises that this Code of Ethics and Conduct is not exhaustive, that its content may change over time and that it may refer to other procedures (including but not limited to the Procedure on Compiling and Processing Whistleblowing Reports) or internal documents.

Finally, it should be noted that any more stringent local laws and regulations prevail over the provisions of this Code of Ethics and Conduct.

PRODUCT SECURITY, SAFETY, INTEGRITY, QUALITY AND LEGALITY

These principles are the proof of our commitment to our clients and consumers and our respect for them. All Group Colleagues involved in manufacturing, marketing and commercial activities must seek to achieve a level of quality characterised by total product compliance, from development to distribution.

Accordingly, we undertake to:
-    Comply with all applicable national and international laws and regulations to ensure the compliance of our products;
-    Ensure that hygiene and quality control standards are implemented at every stage;
-    Ensure compliance with the applicable hygiene and safety standards by each of our employees;
-    If we become aware of a customer complaint, ensure the compliance of the product development process and, if the complaint shows a potential health or safety problem, ensure that the crisis unit is informed immediately and without delay.

Our production sites have been awarded a number of quality certificates, as a mark of our commitment to quality:
-    IFS
-    BRC

All our production processes are standardised and formalised and are available to our production teams at all times. Compliance with procedures must be maintained throughout the logistics and supply chain.

COMBATING FRAUD AND COUNTERFEITING

We are committed to active fraud prevention, both internally and externally. This commitment is demonstrated, in particular, by raising our Colleagues’ awareness of the issue of fraud and the implementation of disincentive control mechanisms.

We encourage all our staff to be vigilant and to respond appropriately if they suspect or detect a fraudulent activity, counterfeiting or any other evidence of unlawful practices.

HEALTH, HYGIENE AND SAFETY AT WORK

We guarantee a safe and healthy working environment, based on a risk assessment and taking all the necessary measures to eliminate or reduce the risks identified.
Strict safety instructions are regularly updated, disseminated and brought to the attention of our staff, particularly those who work on the Group’s production sites.
Every Colleague must take all reasonable precautions to maintain a safe and healthy working environment and must ensure that their actions do not create any risk either for themselves or other people.

Every Colleague shall ensure that they know what to do in an emergency, and report any accident or incident, even minor, and any behaviour, installation or situation that may compromise the security, safety, integrity, quality of our working environment to their line manager immediately.

Any employee who breaches safety instructions will be reminded of the rules and may be given a warning. Moreover, the employee concerned may be held liable in the event of an accident caused by their negligence.

Furthermore, given the nature of our products, we support harm-prevention procedures related to the irresponsible consumption of alcohol. Any employee who is inebriated while carrying out their duties will have committed professional misconduct and may be subject to disciplinary proceedings.

Compliance with these rules is essential to ensure everyone’s physical safety and welfare.

HUMAN RESOURCES MANAGEMENT

FREEDOM OF ASSOCIATION AND RIGHT TO COLLECTIVE BARGAINING

We respect the right of workers to form trade unions or other forms of worker representation association and to engage in collective bargaining. Accordingly, we encourage consultation and social dialogue.

FAIR PAY

We respect the right of workers to receive fair pay that reflects the work they do and the associated responsibilities.

All decisions relating to setting pay, awarding bonuses and appraising employees’ performance shall be made in accordance with the procedures in effect in the Group and the applicable legislation in force.

SPECIAL PROTECTION FOR YOUNG WORKERS

We only hire workers who have reached the statutory minimum age.

Where we recruit minors who have legal capacity to work, we offer them special protection in accordance with the statutory and regulatory provisions in force.

WORKING HOURS

We comply with the legislation on working hours and leave, except where an agreed exemption applies in accordance with statutory and regulatory procedures.

NO FORCED LABOUR

Our business does not practise any form of involuntary servitude and does not use labour derived from human trafficking or working against one’s will.

NON-DISCRIMINATION

We guarantee equality of treatment for all our Colleagues and do not practise any form of discrimination in respect of any of them.
We are strictly opposed to any form of discrimination, notably as a result of:
-    ethnic origin;
-    sex;
-    lifestyle;
-    sexual orientation;
-    gender identity;
-    age;
-    family situation or pregnancy;
-    political opinions;
-    trade union and mutual society activities;
-    religious convictions;
-    physical appearance;
-    state of health;
-    loss of autonomy or disability;
-    or any other situation that could create discrimination.

This applies not only when employees are hired but also to decisions concerning training, promotion, continued employment and working conditions in general, as well as in our relationships with our suppliers, clients, commercial partners and others.

BULLYING AND SEXUAL HARASSMENT

We are committed to ensuring the right to respect and human dignity of every individual.

Every Colleague undertakes to support and promote the Group’s commitment to a working environment that is free from any form of bullying, sexual harassment or sexist behaviour.

This applies to relationships between colleagues, as well as between employees and their line managers.

Any action that constitutes a form of bullying, sexual harassment or sexist behaviour may result in disciplinary proceedings.

ENVIRONMENTAL PROTECTION

We take the necessary steps to protect the environment and strive to minimise our ecological impact.

Accordingly, we undertake to implement any measure aimed at conserving natural and energy resources, reducing waste production and harmful emissions or discharges into air or water, and combating climate change.

This necessarily implies compliance with the statutory provisions in force in relation to environmental protection.

Accordingly, every Colleague shall contribute to the Group’s environmental initiatives by prioritising the use of recyclable materials and the development of biodegradable packaging, and ensuring they make reasonable use of resources and energy.

USE OF COMPANY ASSETS

The purpose of the company’s assets is to enable Colleagues to achieve the Group’s economic objectives.

Assets include, among other things, patents, know-how, lists of clients, subcontractors or suppliers, market information, technical or commercial practices, sales proposals and technical studies, all data or information and more generally, any physical or computerised tool to which employees have access in carrying out their duties.

Every Colleague undertakes not to waste or make inappropriate use of these resources in a way that would harm the Group’s operational and financial performance.

Accordingly, every Colleague undertakes to:
-    protect and preserve the company’s assets, along with all documents belonging to the Group;
-    use them for strictly business purposes;
-    make appropriate use of information systems, email and the internet, and any digital media;
-    comply and ensure others comply with the internal procedures applicable to them.

CONFLICT OF INTERESTS

A situation of conflict of interests arises when the personal interests of a Colleague or those of a close contact of the latter interfere with the Colleague’s ability to carry out their duties in the interests of the Group.

A conflict of interests leading to a biased decision may constitute an act of corruption.

In the case of a conflict of interests that could influence or give the impression of influencing their judgement and actions, every Colleague must inform their line manager of the actual or potential risk as soon as they become aware of it.

Cases that could constitute a conflict of interests include the following:
-    An employee’s family member who works for a supplier;
-    An employee who occupies a position, has a role or holds a financial interest in an organisation that is a competitor, client, supplier or partner;
-    Any action that would prioritise a Colleague’s personal interest to the detriment of the Group’s interest.

GIFTS AND INVITATIONS

Receiving or offering a gift or invitation can be a simple sign of courtesy and contribute to a positive relationship with a partner.

Accordingly, we ensure that any gifts or invitations offered are appropriate and transparent, fall within reasonable limits without seeking anything in return, and comply with the Group’s ethical principles.

Every Colleague must inform their line manager of any gift or invitation received and gifts or invitations must be given in the name of the company.

Gifts or invitations offered or received by an employee must be of a reasonable and proportionate amount.

These practices are prohibited, regardless of their amount or nature, when they seek to obtain an unfair commercial advantage or influence an action or an official decision, when they do not comply with the rules established in the Group, or more broadly, when they are contrary to statutory or contractual provisions.

Accordingly, every Colleague undertakes to refuse gifts and invitations that are not solely and clearly of symbolic value only, or which are offered for the purpose of receiving something in return.

Giving or receiving gifts in cash is also prohibited.

CHOICE AND FAIR TREATMENT OF COMMERCIAL PARTNERS

We promote ethical business practices and condemn any form of unlawful or anti-competitive practices and corruption.

Actions such as the following are deemed anti-competitive practices: abuse of dominant position, price-fixing or conditions of sale agreements with the competition, denigration of a competitor, etc.

We offer fair opportunities to all candidates, regardless of the origin or scale of the transaction, in our relationships with our suppliers and commercial partners.

Suppliers are selected in the sole interests of the Group, on the basis of objective criteria, such as quality, price, reliability of deliveries or services, or the stability of their business.

We are committed to ensuring that our cooperation with suppliers and commercial partners complies with the applicable regulations, particularly in respect of forced, compulsory or child labour.

CORRUPTION, BRIBERY AND “FACILITATION” PAYMENTS

We take a zero-tolerance approach to corruption.

Corruption can be defined as the fact of seeking or accepting, directly or indirectly, offers, promises, donations, gifts or benefits of any kind whatsoever, for oneself or others, for taking or having taken an action during the course of one’s duties, mission or mandate, or having facilitated it through one’s duties, mission or mandate, either actively or passively.

This includes a ban on “facilitation payments”, i.e. payments made to public officials to complete or accelerate certain administrative formalities, such as applications for permits or customs clearance.

We undertake to ensure that our commercial partners are aware of our standards and commit to compliance with them, particularly if they operate in countries where the risk of corruption is high.

Colleagues must therefore inform their line managers immediately first, if they are aware of actions likely to breach our commitments in terms of combating corruption and secondly, in the case of extortion or attempted extortion, which is the act of obtaining through violence, the threat of violence or constraint, either a signature, commitment or waiver, either by revealing a secret or a piece of sensitive or confidential information, or the handover of funds, securities or any kind of property whatsoever.

It is therefore forbidden to offer, promise or give money or any other item of value in any form whatsoever to either:
-    a representative of the public authorities, a political party or a person who is active in public life, a trade union or a person who is active in a trade union;
-    an employee or representative of another business that could result in them breaching their obligation to act fairly towards that business.

Accepting or seeking money or any other item of value in any form whatsoever or any other form of facility that could result in an employee breaching their obligation to act fairly towards the Group or be perceived as influencing a commercial relationship is also prohibited.

BUSINESS AND FINANCIAL DOCUMENTS, AND COMBATING MONEY LAUNDERING

Every Colleague must ensure that all information appearing in business and financial documents, including financial reports, reflects the economic reality and is backed by internal and external audits. This is an essential element of honest, efficient and lawful business dealings. The information provided to our shareholders, among others, must be transparent, accurate and reliable.

Every Colleague must ensure that the business’s activities are not used to “launder” funds derived from criminal activities or which contravene the applicable regulations.

This means:
-    keeping business and financial documents secure and complying with archiving instructions;
-    following internal verification procedures that allow the business to ensure that our clients and suppliers are involved in legitimate activities and that their money does not come from unlawful activities;
-    cooperating with internal and external auditors.

Our staff, particularly within the Administration and Finance Department, are trained and made aware that such practices are prohibited, and that a series of checks are carried out by several employees in line with our internal control practices.

INSIDER DEALING

The fact that a Colleague uses privileged information (i.e. information that has not been made public and that a reasonable investor could use as one of the justifications for their investments) in the context of private investments could be classified as insider dealing.

Every Colleague must keep all privileged information confidential to avoid disclosure and unforeseen use.

The fact of using privileged information to make a direct or indirect personal profit is not only contrary to the Group’s rules on conduct but also the law, including AMF (French Financial Markets Authority) regulations.

TAX

We wish to act as a good corporate citizen in relation to tax.

We are therefore committed to scrupulous compliance with the legislation in force and to paying all local and national taxes required.

To this end, all Group subsidiaries maintain accurate and compliant accounting records and documents, and complete all their tax declarations.
Group Colleagues are obliged to produce regular and accurate financial statements that give a true picture of the Group’s financial situation, operating profit or loss, transactions, assets and liabilities. These documents must be produced in accordance with accounting principles and entries backed by appropriate documentation, issued by the parties in good faith.

All documents must be retained in accordance with the applicable legislation and Group policies.

CONFIDENTIALITY – RESPECT FOR PRIVACY AND PERSONAL DATA

We undertake to respect the privacy of all our stakeholders, including our Colleagues and consumers, and to protect the use of their personal data.

Accordingly, we ensure that only necessary personal data are collected and that people are informed of their right of access, rectification and objection in line with the provisions of Regulation (EU) 2016/679 – GDPR (General Data Protection Regulation).

Moreover, Group Colleagues undertake to:
-    protect the use of all internal information, as well as confidential and sensitive data;
-    not disclose it to people outside the Group;
-    limit its disclosure solely to those internal people who have a legitimate interest to know it in the interests of the Group;
-    not to divert the use of personal data from its primary purposes.