Compliance
CRIMINAL COMPLIANCE SYSTEM
In order to have an adequate regulatory compliance program, a series of policies and procedures have been developed for the Spanish companies of the Emperador Group, which expressly regulate the possibility of avoiding criminal liability for crimes committed by their representatives, executives, and employees. Among these policies and procedures, the following documents stand out:
- Compliance Policy: it is the reference framework for the implementation of a crime prevention system, where the commitments, principles, and purposes of the system that have been implemented with respect to the companies of the Emperador Group are defined. The objective of this policy is to provide an overview of the crime prevention model, training and raising awareness among all professionals, executives, and advisors about the criminal risks to which their actions are exposed.
- Ethical Code: the objective of this code is to define the general principles and basic rules of corporate governance and conduct that govern the activities of the companies of the Emperador Group, applicable both to the relationship with their employees and to the relationship between employees in the development of their professional activities. This code especially takes into account the obligations and ethical and conduct principles that frame the actions of all employees of the companies of the Emperador Group. The Ethical Code is contained in the document found below.
ETHICAL CODE
I. INTRODUCTION
The present Code of Ethics (hereinafter, the “Code”), as a full expression of the culture of the Spanish Companies belonging to Grupo Emperador (hereinafter, “Grupo Emperador” or the “Group”, or the “Companies”, interchangeably), defines the general principles and basic rules of corporate governance and conduct that govern the development of the Group’s commercial activities, applicable both to the relationship with its employees and to the relationship between employees in the development of their professional activities and, to the extent of its compatibility, it is also applicable to the relationship with suppliers and customers. The purpose of this Code is to establish the guidelines, limitations, and incompatibilities that determine the actions of the Group’s professionals, who must know, apply, internalize, and disseminate them. The ideal that drives the creation of this Code of Ethics is the internal implementation and dissemination of a true Culture of Compliance, for the benefit of the Group, its owners, employees, and other interested third parties and, ultimately, the environment in which Grupo Emperador operates. It is about reinforcing a Culture that also promotes Good Corporate Governance and Corporate Social Responsibility. Therefore, it is not intended to cover all possible situations that may arise but, in any case, to provide a reference framework on which to base the daily activity of all those who make up Grupo Emperador. The fundamental philosophy of this Code lies in the fact that there should be no differences between our principles and our actions.
II. SCOPE OF APPLICATION
The Code encompasses the two lines of business of the Spanish Companies belonging to Grupo Emperador:
- Spirits (through the registered corporate brand Emperador Distillers and all other brands with which the products of this line of activity are identified); and
- Real Estate (through the registered corporate brand Emperador Properties and all other brands with which the assets of this line of activity are identified).
The Code applies to all personnel of the Spanish Companies belonging to Grupo Emperador, within the perimeter of influence of their activity, whether internally (employees, executives, shareholders) or externally, to those natural or legal persons who contract or provide their services for the Group (consultants, suppliers, agents, etc.), in a direct or indirect manner.
III. GENERAL PRINCIPLES
3.1 Compliance with the Law
Grupo Emperador is committed to strictly complying with the current legislation in all places where it conducts its activities, present and future, to fully respect the obligations and commitments assumed in its contractual relationships with third parties, and to know and comply with the laws and regulations affecting its respective areas of activity at all times. No employee will consciously or voluntarily collaborate, alone or with third parties, in the violation of any law, nor will they participate in actions that compromise respect for the principle of legality. It is the responsibility of each employee, regardless of their role and hierarchy, to respect the content of both this Code and the general legal framework. The content of this Code respects constitutional and specifically labor rights. Notwithstanding this, and in the event of an irresolvable conflict regarding a specific fact, the prevailing legal regulations should take precedence, as they are of higher rank.
3.2 Ethical Behavior
The values and principles incorporated in this Code form the minimum necessary basis for responsible organic growth, and for the constant maintenance and improvement of a corporate image and a good reputation, which continue to make Grupo Emperador a leading company in its sector at both national and international levels. Each employee must carry out their work within the company in accordance with these values and principles, avoiding situations that compromise the image and reputation of Grupo Emperador.
3.3 Confidentiality. Transparency. Traceability
Confidentiality. All employees must protect the information of our clients, intermediaries, suppliers, collaborators, and third parties related to the activities of the Companies with the utmost diligence, preventing it at all times and under all circumstances from going beyond the limits of the professional scope. This implies the strictly confidential use of internal information that the Companies make available to each employee, any type of documentation created, developed, and used by their staff during the performance of work activities or with resources provided by the company. Therefore, the use of such information is restricted to the internal scope of Grupo Emperador.
Information Transparency. All products and services of Grupo Emperador, as well as any documentation, must be offered in a sufficient, transparent, and precise manner, thus ensuring adequate knowledge by the recipient.
Traceability. In the development of the commercial activities of the Spanish companies belonging to Grupo Emperador, each employee must respect the set of pre-established and self-sufficient procedures, thus generating a transparent, complete, and permanent record of each operation.
The confidentiality duties extend beyond working hours and will persist indefinitely, even when the employment relationship between the employee and Grupo Emperador has ended.
3.4 Human and Labor Rights
Importance of the Human Team. The human team of Grupo Emperador is the most important asset. Therefore, the Companies are committed to providing all their employees with a safe working environment, where no one is exposed to unnecessary risks:
- Teamwork. Teamwork and mutual respect are the main pillars of the relationships that Grupo Emperador establishes. It means, therefore, achieving a sense of integration, a permanent spirit of collaboration, acceptance, and exchange of ideas and suggestions between the parties.
- Respect and work environment. Grupo Emperador respects the personal dignity, privacy, and personal rights of each employee, client, and collaborator. Therefore, we do not tolerate any form of abuse or harassment against our employees, collaborators, or clients. Our success and reputation depend not only on the quality of our products but also on the way we conduct our profession.
3.5 Environmental Protection
Grupo Emperador maintains a strong commitment to the care and respect of the environment in the daily exercise of its activities, minimizing negative environmental impacts to try to achieve a high level of safety in our processes, facilities, and services, paying special attention to the protection of our employees, mediators, suppliers, clients, third parties related to the activity of the Group’s Companies and the environment in general, in strict compliance with the environmental legislation applicable to us. Therefore, we must apply environmental criteria in all planning and decision-making processes on issues that could affect the environment and implement the necessary measures to prevent environmental pollution or the waste of natural resources, using them rationally (for example and without limitation, regarding the consumption of water, paper, and energy); reducing the generation of waste and emissions, promoting recycling, and seeking eco-efficient solutions. This environmental policy extends to the promotion of good environmental practices among our mediators, suppliers, client partners, and collaborators in general.
IV. PRINCIPLES RELATED TO ETHICS AND GOOD GOVERNANCE
4.1 Leadership and Responsibility
The management of the Spanish Companies belonging to Grupo Emperador is the responsibility of each of their Administrative Bodies, who will have the responsibility of establishing the operational guidelines and the long-term responsibility for the company’s success. It is the responsibility of the Companies’ managers and all those who, within its hierarchical structure, have management and control powers (understood both in a general sense and in relation to specific roles), to lead by examples of compliance. Establishing the company’s objectives, and implementing and controlling the way in which the objectives are achieved.
4.2 Anti-Bribery and Anti-Corruption
Employees of the Spanish Companies belonging to Grupo Emperador must adapt their behavior to the highest standards of integrity, ethics, and honesty. Direct or indirect participation in the development of bribery, corruption, improper commission payments, and abuse of position, office, or role (public or private) is strictly prohibited. If an employee is involuntarily involved in any such activity, or becomes aware of a situation involving a member of the Companies (regardless of whether the latter is aware of it or not), the situation must be reported through the Compliance Mailbox, regarding any offer, promise, or request for bribery, at the moment it becomes known.
4.3 Gifts and Invitations
The exchange of gifts and invitations between employees, suppliers, intermediaries, clients, or third parties related to the activities of the Group’s Companies can be a legitimate way to build the necessary trust in the regular development of the company’s commercial activity. However, such exchange is strictly prohibited when, due to its amount or nature, it involves excessive, disproportionate, or inappropriate gifts or invitations, creating the impression of being intended to exert undue influence and, consequently, constituting bribery. For practical purposes, a maximum limit of 150 Euros is established as an acceptable value for gifts and invitations made to or offered by employees of the Companies. In the case of a gift or invitation whose value exceeds this threshold, the employee wishing to make the delivery or is potentially the beneficiary of it must request prior authorization from their area manager, who must inform the Crime Prevention and Control Body (hereinafter, the “OPCD”).
4.4 Prevention of Conflicts of Interest
It is strictly prohibited for a Grupo Emperador employee to act in circumstances where there is a current or potential risk of conflict of interest, whether it involves the employee’s personal interests and those of the Group, or the people with whom both are related. In such a situation, the employee must declare the real or potential existence of such a conflict of interest to their supervisor, who must inform the OPCD, so that appropriate measures can be taken. Each employee of the Spanish companies belonging to Grupo Emperador must always act with loyalty in fulfilling their responsibilities and promote the defense of the interests of the companies and the people with whom they interact.
4.5 Fraud Prevention
It is strictly prohibited to engage in fraudulent and/or deceptive activities, understood as those carried out by evading legal obligations or usurping rights in order to obtain a benefit, regardless of the hierarchy of the employee involved and whether they act individually or in collusion with other people, internal or external to the organization.
4.6 Financial Records
It is about applying the principle of informational transparency to all types of information, and in particular, to financial information. The economic-financial information of Grupo Emperador must faithfully reflect its economic, financial, and asset position, in accordance with the accounting principles adopted by Grupo Emperador. It is strictly prohibited to knowingly provide incorrect, unreal, inaccurate, or imprecise information, or that could mislead its recipient, and to record financial, asset, and accounting information evading the rules and standards adopted by Grupo Emperador for this purpose. Similarly, anyone who conceals, distorts, or destroys information from the records and accounting reports of the companies will be penalized.
4.7 Intellectual and Industrial Property
Grupo Emperador is committed to respecting the intellectual and/or industrial property of third parties and protecting the Group’s own intellectual and industrial property. Therefore, all employees of Grupo Emperador must respect the intellectual and industrial property rights of the Group and third parties, assuming that the materials handled in the development of the tasks that concern each one have copyright, unless explicitly stated otherwise. These materials must be used in accordance with the terms of the corresponding license and for the purpose for which they were conceived or licensed.
4.8 Data Protection
All employees of the Companies must ensure the protection of the personal data of our customers, intermediaries, business partners, employees, suppliers, and other third parties linked to the company, stored and exchanged during the daily activity of each employee, respecting their legitimate rights to privacy and complying with the current legislation on the matter and any others that may be established in the future. In this way, we can ensure the privacy and trust placed in Grupo Emperador by our customers, intermediaries, suppliers, employees, business partners, public administrations, and society in general.
4.9 Prevention of Insider Information Use
Grupo Emperador is committed to safeguarding the use of insider information, communicating it exclusively to those strictly necessary to carry out their functions. Therefore, it is the responsibility of each of our employees to control the traceability, access, and delivery of documents containing insider information and to protect its disclosure, in whole or in part, by physical or digital means, to unauthorized persons, taking measures such as, among others and without limitation, including the legend “CONFIDENTIAL” in emails, envelopes, and faxes through which such information is sent to authorized personnel only.
4.10 Prevention of Money Laundering and Terrorism Financing
Grupo Emperador declares its firm commitment in the fight against money laundering and terrorism financing and, in particular, its willingness not to be subject to illicit use for any type of illegal activities through customers, suppliers, intermediaries, business partners, third parties linked to the Spanish Companies belonging to Grupo Emperador or through its own employees. Therefore, each employee must pay special attention to those cases where there are indications of lack of integrity of the people or entities with whom business is conducted, in addition to the general duty to comply with the applicable legal provisions on the matter.
V. PRINCIPLES RELATED TO THE WORK ENVIRONMENT
5.1 STAFF SELECTION AND EVALUATION
The success of Grupo Emperador and the reputation we have built are measured by the people who make it up and the internal talent selection processes. Therefore, we are committed to always using objective criteria in the selection of personnel to be hired, conducting the selection process transparently and considering exclusively the academic, personal, and professional merits required for the position in question, respecting the principle of equal treatment for all candidates. Grupo Emperador will conduct the necessary investigations and inquiries about candidates deemed necessary in each case to gain confidence in their integrity and honesty, asking them to provide the appropriate documentation according to the position in question, which includes, without limitation, proof of the licenses and permits necessary to work in the country. No form of child labor or forced labor will be tolerated under any circumstances, and special attention will be paid to ensuring that suppliers or third parties providing services to the organization do not engage in such practices.
5.2 EQUALITY AND DIVERSITY
Grupo Emperador is committed to applying the principle of non-discrimination in employee hiring, training, professional development opportunities, salary levels, and other aspects related to the employment relationship. Regarding the promotion of our employees, equal treatment between men and women will be promoted concerning, without limitation, access to employment, training, professional progression, and working conditions. Similarly, we are committed to respecting the right to privacy of employees, especially concerning their personal data and personal communications via the internet and other communication means. Employees who must access such data concerning other employees in the exercise of their professional activity are committed to maintaining the confidentiality of such information. Consequently, Grupo Emperador will not tolerate any form of discriminatory conduct based on race, color, nationality, religious, political, or union ideas, sex, marital status, age, disability, or family responsibilities, or any other reason. Any manifestation of violence, physical, sexual, psychological, moral, or other harassment will be inadmissible and penalized, with the relevant authorities being involved to take appropriate measures. Abuse of authority at work and any other conduct that creates an intimidating, hostile, or offensive environment for the personal rights of employees, regardless of their hierarchy, are contrary to the spirit of collaboration and the culture of Grupo Emperador and are therefore prohibited. The disclosure of personal data of the organization’s employees is strictly prohibited, except with the consent of the interested parties and in cases of legal obligation or compliance with judicial or administrative resolutions. The use of personal data of employees of the Companies for purposes other than those legally or contractually provided is also strictly prohibited.
5.3 PROFESSIONAL DEVELOPMENT, REMUNERATION, AND COMPENSATION
Grupo Emperador will offer its employees fair and adequate compensation, avoiding conflicts of interest among employees, customers, and other stakeholders. Likewise, Grupo Emperador is committed to promoting the personal and professional development of its employees, encouraging their involvement in improving their own skills and competencies. The Companies will duly inform their employees about the policies for evaluating their performance, inviting them to actively participate in the established processes to improve their work, initiative, and dedication. The Companies will promote the continuous training of their employees, fostering equal opportunities and the development of each of their professional careers in accessing the training programs adopted by the company.
5.4 TRAINING
With a view to adequately complying with the standards contained in this Code and other internal and external regulations, the Companies commit to developing initial training and periodic updating activities for staff, appropriate to the type of tasks of each employee and their level of complexity and responsibility, with the aim that all interested parties know and understand not only the rules of the Code but also the principles, values, and spirit of compliance behind them. Likewise, and beyond the actions that the Companies adopt in each case, it will be the responsibility of each employee to maintain updated knowledge about the changes, modifications, and updates made to this Code, and to report to their immediate superior and the OPCD the compliance function, as the case may be, situations of ignorance and/or conflict that may pose a risk to the employee and/or the Group. In accordance with the previous sections, Grupo Emperador makes this Code available to employees, customers, mediators, suppliers, and interested third parties through its website https://www.grupoemperadorspain.com/. Additionally, it will be available to employees on the corporate Intranet of each of the Spanish Companies belonging to Grupo Emperador.
5.5 RECONCILIATION OF FAMILY LIFE WITH WORK ACTIVITY
Grupo Emperador is aware that each of us, beyond being part of the Group, maintains outside of our work, family ties and personal relationships that generate emotional commitments and personal needs. Therefore, it is firmly committed to respecting the space and time necessary for the development of a full family and personal life, balancing work commitments with the family needs of each of our professionals, particularly concerning working hours, national, regional, and local holidays, and vacation days.
5.6 RIGHT TO PRIVACY
It is also a commitment of Grupo Emperador to respect and ensure respect for the right to privacy of each of our professionals, particularly regarding the management of information and data stored about each of them as a result of the work relationship, which also extends to all information (written or verbal, obtained formally or informally) acquired regarding each employee during the development of the work relationship. This commitment extends even after the end of the professional relationship.
5.7 HEALTH, HYGIENE, AND SAFETY AT WORK
Grupo Emperador will continue to implement its occupational health and safety programs, strictly complying with health, safety, and occupational risk prevention regulations and adopting all necessary preventive measures to safeguard the integrity of its employees. All employees must responsibly use the equipment assigned to them when carrying out activities that may pose a risk. Therefore, it is prohibited to engage in behaviors or actions that individually or collectively may endanger one’s own integrity and/or that of their coworkers, or to provoke or collaborate in behaviors or actions that individually or collectively may lead to such a result. The facilities of the Companies are smoke-free environments, where smoking is consequently not allowed. The consumption of alcoholic beverages during working hours is not permitted, except for strictly work-related reasons as a result of the work activity, to the extent that its intake may compromise safety and productivity in the work environment and the maintenance of professionalism and responsibility of the employees. Likewise, the consumption of drugs is strictly prohibited in the facilities or premises of the Companies. All these health, hygiene, and safety at work regulations will apply to all third parties with whom the organization operates, who must adequately comply with occupational health and safety legislation.
VI. MARKET-RELATED RULES
6.1 RELATIONS WITH CUSTOMERS
In its relationships with customers, Grupo Emperador is committed to establishing appropriate measures to ensure that all employees and third parties providing services to the Companies apply the same standard of quality and respect, acting with integrity towards our customers, with the objectives of achieving the highest levels of quality, efficiency, transparency, and excellence in the provision of our services and the development of long-term relationships based on trust and mutual respect. This implies not only guaranteeing the confidentiality of our customers’ data (as established in this Code regarding confidential information and privileged information held by Grupo Emperador) but also, and mainly, explaining to customers, clearly and transparently, the characteristics and risks of our products and services. The necessary channels must be made available to our customers so they can present their complaints in case of disagreement with the services and/or products obtained, which must be addressed promptly, analyzing the causes that motivated them and making a fair decision on their resolution. It is prohibited to offer information or perform actions that may induce or be interpreted as possible deception to our customers to get them to contract a product or service of the Organization that, had they known its real characteristics, they would not have contracted, as well as improperly modifying the commercial and contractual information and documentation that governs the provision of our services and the offer of our products.
6.2 MARKETING AND ADVERTISING
The commitment of Grupo Emperador, regarding the contents of marketing and advertising campaigns developed and to be developed in the future, extends both to respecting current legislation and to ensuring that they will always be ethical, respectful of society, truthful, and honest, respecting the rights of consumers and competitors of the Companies. It is the responsibility of each of us to fulfill our commitment to honesty with our customers, always providing them with complete, truthful, clear, useful, and accurate information about our products and services, and to verify that they meet all the required and advertised specifications. Therefore, employees of Grupo Emperador must not, under any circumstances, abuse the good faith of our customers or offer arguments that take advantage of their fear, apprehension, or superstitions, incite violence or illegal behavior, encourage dangerous practices, suggest circumstances of discrimination, violate the dignity of the person, or, in general, include content that goes against prevailing criteria of good taste and social decorum, as well as against good customs.
6.3 MEDIA AND SOCIAL NETWORKS
Employees, mediators, suppliers, and third parties linked to Grupo Emperador will exercise prudence and good judgment in any communication made through media and social networks, always respecting what is indicated in this Code of Ethics. Therefore, it is convenient for the reputation and corporate image of the Group to establish a social media use policy, as its digital presence will imply public exposure, making it vital to supervise the information, data, and images transmitted through this channel. They should not, in any case, be aspects left to chance, but it is essential that all departments of the Group, in direct connection with the OPCD, intervene and get involved in their management. In this way, legal and technical guarantees will be established in their use, and the legal risks derived will be defined, in order to foresee actions aimed at their elimination or containment.
6.4 RELATIONS WITH SUPPLIERS
Grupo Emperador’s commitment to respecting human rights and ethical behavior also involves promoting and ensuring that our collaborators share our principles. In relationships with our collaborators, we must urge them to operate in strict compliance with current regulations, respecting the fulfillment of internationally recognized human rights and complying with the ethical standards with which our Companies operate, to whom we must always provide truthful and complete information.
6.5 RELATIONS WITH PARTNERS/COMMERCIAL COLLABORATORS
The relationship that Grupo Emperador maintains with its partners and commercial collaborators is always collaborative, based on trust, transparency in information, and the sharing of knowledge, experiences, and capabilities to achieve common goals and mutual benefit. Additionally, we seek for our partners and commercial collaborators to commit to respecting legality in general, human rights, and ethical behavior in the development of their businesses. This implies the need to verify that the companies our partners/collaborators subcontract work under the standards promoted by this Code and with current regulations.
6.6 RELATIONS WITH AUTHORITIES AND PUBLIC ADMINISTRATIONS
Grupo Emperador, in its relations with authorities and public administrations, always applies, in the most rigorous manner, the principles of maximum transparency and cooperation. We must always act with honesty and integrity in all contacts and relations with authorities and public administration employees of any rank and hierarchy, ensuring that all information and documents provided and statements made are complete, truthful, and clear.
6.7 FAIR COMPETITION AND COMPETITION DEFENSE
Grupo Emperador has a strong commitment to fair competition in the market, promoting free competition for the benefit of our customers and consumers in general, in compliance with current legislation.
VII. PRINCIPLES RELATED TO SOCIETY
7.1 Respect and Commitment of Grupo Emperador with the Community and the Environment
Grupo Emperador includes within its corporate values, respect for cultural diversity and local customs, enhancing the economic and social development of the different communities in which we operate. We promote the defense of historical heritage as one of our most significant principles, understanding that this policy directly impacts the communities where the Group produces its products or provides its services. Therefore, we expect our employees and professionals to act proactively and participatively, in line with this commitment to the community and the environment, especially in social action and respect for the social, economic, and cultural environments surrounding them in all the regions where they operate.
7.2 Corporate Social Responsibility
Grupo Emperador expresses its commitment to the progress and well-being of the communities it interacts with, which includes our employees, mediators, customers, suppliers, vendors, business partners, and other stakeholders. All decisions involving making any donation to any organization or individual, whether physical or legal, of recognized prestige and moral solvency and that have the appropriate organizational structure to ensure the proper management of resources, must always be made by the specially authorized governing body, under the supervision of the OPCD. Once approved, they must be faithfully recorded in their records and accounting books.
VIII. COMPLIANCE MAILBOX
The Group has a Compliance Mailbox with the aim of promoting compliance with the law and the Ethical Code established by the Spanish companies belonging to Grupo Emperador. The Compliance Mailbox is an instrument made available to employees, suppliers, mediators, customers, and third parties linked to the Companies, to report behaviors that may involve the commission of any irregularity or act contrary to the law or the rules of conduct of the Ethical Code or to consult doubts that may arise about its interpretation. Communications addressed to the Compliance Mailbox can be sent by completing an electronic form that will be available in the section called “Ethical Channel” enabled within the company’s Intranet and on the website https://www.grupoemperadorspain.com/.
IX. PERIODIC VERIFICATION
The Ethical Code is subject to a permanent periodic verification process, in light of possible legislative changes that may occur; the introduction of new products and/or services offered by the Spanish companies belonging to Grupo Emperador, their modification, alteration, or elimination; changes in the structure and management of the company, and in the geographical areas in which the Group operates; as well as any other factual or legal circumstance that makes its update necessary or convenient.
X. ACCEPTANCE AND COMMITMENT
This Code of Ethics is intended for ALL EMPLOYEES of the Spanish companies belonging to Grupo Emperador, from their bodies with management, control, and supervision powers, to employees who lack such attributions, including in this section suppliers, intermediaries, and linked third parties. It is the RESPONSIBILITY of all the aforementioned subjects to KNOW, RESPECT, and COMPLY with the provisions of this Code, applying it to the development of their tasks, in accordance with the work plan, objectives, and goals established by the Group’s commercial policy, which, in turn, will always be aligned with the provisions of this Code. Similarly, IT IS THE RESPONSIBILITY OF ALL EMPLOYEES TO KNOW, RESPECT, and COMPLY with the internal procedural rules regarding the development of the function that pertains to each one, within the structure and hierarchy of the Spanish companies belonging to Grupo Emperador, and in case the employee finds themselves in a conflict situation arising from the need to comply with the rules of this Code and the current legal framework, it will be the responsibility of said employee to report the situation to their supervisor, who will inform the OPCD immediately, so that they can evaluate the situation and initiate, if applicable, an internal adaptation process and/or update of this Code of Ethics and/or internal rules, contributing to the articulation of a satisfactory and respectful solution with the current legality.
XI. APPROVAL. COMMITMENT OF THE ADMINISTRATORS TO THE REGULATORY COMPLIANCE POLICY
The Administrative Bodies of the Spanish Companies belonging to Grupo Emperador, based on their commitment to their ethical policy, accept and approve this Code of Ethics, assuming the responsibility to respect, apply, and update it, as appropriate at any given time. Grupo Emperador is committed to maintaining honest and integral behavior in all its actions, avoiding any form of corruption or breach of legality, and respecting at all times the particular circumstances and needs of all parties involved in all business and professional activities. The members of the Administrative Bodies will maintain ZERO TOLERANCE towards the commission of any type of illicit act, reaffirming their firm opposition to the commission of any type of illicit act and their total commitment to putting all means at their disposal for the detection, prevention, and sanction of fraudulent acts and behaviors that may be committed by their legal representatives, those authorized to make decisions on behalf of Grupo Emperador or who hold organizational and control powers, their employees, executives, or any person subject to their authority, as well as to maintain at all times a business culture of honesty and ethics.
XII. ADVERTISING AND DISSEMINATION
The Administrative Bodies of the Companies and the Crime Prevention and Control Body will retain the original version of the Code of Ethics and its successive updates. They will be responsible for ordering the publication of the electronic version, when possible, and its dissemination among executives, employees, and third-party collaborators. The dissemination will be carried out by email with acknowledgment of receipt to all members of the company and third parties with whom they collaborate. The accreditation of the notification made will be kept along with the original version of the disseminated document. The Spanish Companies belonging to Grupo Emperador will forward it whenever there is any significant modification in the Code and in any case when a new collaborator is incorporated. Otherwise, they will use any method that is operationally efficient and allows obtaining the desired results. The Administrative Bodies of the Companies and the Crime Prevention and Control Body will ensure that all executives, employees, and third-party collaborators can access the updated electronic version of the Code of Ethics through the office systems made available for the dissemination of internal control procedures.