CODE OF CONDUCT

Grupo Bodegas Olarra places central importance on adherence to labour standards and is committed to the values and behaviours outlined in the Ethical Trading Initiative (ETI) Base Code, the principles established in the BSCI Code of Conduct, as well as compliance with current policies and regulations.
This Code of Conduct shall apply to all suppliers contracted by the companies that make up Grupo Bodegas Olarra and highlights the elements we consider most relevant in our suppliers.
We expect our suppliers to actively support this commitment by respecting our values and principles in their operations.
The undersigned company agrees to comply with the following labour practices, which Grupo Bodegas Olarra adopts as its own:

1. FREEDOM OF EMPLOYMENT

1.1 Forced, bonded, or involuntary labour shall not be used.
1.2 Workers shall not be required to lodge “deposits” or hand over identity documents to their employer and shall be free to leave their employment with reasonable notice.

2. RESPECT FOR THE RIGHT TO FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING

2.1 Workers, without distinction, shall have the right to join or form trade unions of their own choosing and to bargain collectively.
2.2 The employer shall adopt an open attitude towards the activities of trade unions and their organisational activities.
2.3 Workers’ representatives shall not be discriminated against and shall be allowed to carry out their representative functions in the workplace. These functions may include the formation of a workers’ committee with elected members where employees can confidentially raise concerns relating to these guidelines.
2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer shall facilitate, and not hinder, alternative means of independent and free association and bargaining.

3. WORKING CONDITIONS THAT RESPECT HEALTH AND SAFETY STANDARDS

3.1 A safe and hygienic working environment shall be provided, considering industry knowledge and specific hazards. Adequate steps shall be taken to prevent accidents and injury arising out of, associated with, or occurring during work, by minimising hazards as far as reasonably practicable.
3.2 Workers shall receive regular, documented health and safety training. This shall be provided to new and reassigned workers.
3.3 Clean toilet facilities, potable water, and, where appropriate, sanitary facilities for food storage shall be provided.
3.4 If accommodation is provided, it shall be clean, safe, and meet the basic needs of the workers.
3.5 A senior management representative shall be appointed to oversee health and safety.

4. CHILD LABOUR SHALL NOT BE USED

4.1 Children shall not be employed.
4.2 Children or persons under 18 shall not be employed at night or in hazardous conditions.
4.3 Policies and procedures shall conform to the relevant ILO standards.

5. LIVING WAGES SHALL BE PAID

5.1 Wages and benefits for a standard working month shall meet at least national legal standards or industry benchmarks, whichever is higher. In all cases, wages should be enough to meet basic needs and provide some discretionary income.
5.2 All workers shall be provided with written and understandable information about their employment conditions in respect to wages before starting, and about their pay for each pay period.
5.3 Deductions from wages as a disciplinary measure or for reasons not permitted by national law shall not be allowed without the express permission of the worker. All disciplinary measures must be recorded.

6. WORKING HOURS SHALL NOT BE EXCESSIVE

6.1 Working hours must comply with national laws or industry standards, whichever affords greater protection.
6.2 Workers shall not work more than 48 hours per week on a regular basis and shall have at least one day off in every seven-day period on average.
6.3 Overtime shall be voluntary, shall not exceed 12 hours per week, shall not be demanded regularly, and shall always be compensated at a premium rate.

7. NO DISCRIMINATION SHALL BE PRACTISED

7.1 There shall be no discrimination in hiring, compensation, access to training, promotion, termination, or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, pregnancy, disease, trade union membership, political affiliation, or any other condition that could give rise to discrimination. Workers shall not be harassed or disciplined on any of these grounds. All forms of discrimination shall be actively prevented and addressed.

8. REGULAR EMPLOYMENT SHALL BE PROVIDED

8.1 Wherever possible, work should be based on recognised employment relationships established in accordance with national law and practice.
8.2 Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour-only contracting, subcontracting, or home-working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment. Nor shall such obligations be avoided through excessive use of fixed-term contracts.

9. NO HARSH OR INHUMANE TREATMENT SHALL BE ALLOWED

9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse, and other forms of intimidation are prohibited.
9.2 Modern slavery practices, including servitude and other exploitative or oppressive practices such as extreme economic or sexual exploitation or degradation, are strictly prohibited.

10. ENVIRONMENTAL COMMITMENT

10.1 The supplier shall evaluate any significant environmental impact of its operations and adopt effective policies and procedures that reflect its responsibility to the environment. Adequate steps shall be taken to avoid or minimise adverse effects on natural resources and the broader environment.

11. SUSTAINABILITY COMMITMENT

11.1 Grupo Bodegas Olarra aims to establish a sustainable production system based on reducing vineyard treatments, preserving soil, rational use of water resources, and appropriate waste management — all linked to the promotion of a sustainable tourism model integrated into its surroundings, while ensuring product quality through environmental respect and conservation of natural resources.
11.2 With regard to waste, efforts are made to achieve significant progress in eco-design for packaging to improve recyclability, explore complementary systems such as reuse, and valorise agricultural and winery by-products, accelerating the transition towards a circular economy.

12. ETHICAL BUSINESS BEHAVIOUR

12.1 There shall be no engagement in any form of corruption, extortion, or embezzlement, nor acceptance or offering of bribes, promises, or improper incentives.
12.2 Personal data shall be collected, used, and processed appropriately in accordance with privacy and information security laws.

13. LEGAL COMPLIANCE

13.1 Grupo Bodegas Olarra is fully committed to complying with all applicable laws and regulations governing its operations and shall not knowingly violate them.
13.2 Grupo Bodegas Olarra will not knowingly do business with suppliers who violate such laws and regulations.
Grupo Bodegas Olarra expects its suppliers to support and uphold the above principles by incorporating them into their own business practices and taking appropriate steps to ensure that this Code of Conduct is communicated to their employees. Likewise, they shall ensure that their own suppliers also comply with the principles set out in this Code of Conduct.
Grupo Bodegas Olarra expects adherence to and compliance with this Code of Conduct. It wishes to work with suppliers to achieve the principles laid out herein.
Failure by a supplier to commit to or implement corrective actions will result in termination of the business relationship and cancellation of existing contracts.