ENTREMONTES
An express statement of the values, principles, and conduct guidelines for the development of professional activities.
January 2026.
This document constitutes the Code of Ethics (hereinafter, the “Code“) of the company “Cooperativa Ntra. Sra. de la Piedad,” commercially known as “Bodegas Entremontes” (hereinafter, the “Company“). It aims to establish an express statement of the values, principles, and conduct guidelines that form part of its corporate culture.
In this regard, within the scope of the Company’s operations, all its members assume a firm commitment to comply with current legislation, while also respecting good practices and customs.
Thus, this Code seeks to become the channel for the development of the Company’s corporate values and to guide the behavior of all individuals within the organization in the execution of their professional activities, regardless of their position or function, preventing criminal behavior by them.
The scope of this Code applies to both the Company and the individuals who make it up, meaning the members of the governing body, the executive staff, and, in general, all employees, regardless of their position or function.
Similarly, when establishing business relationships with other companies or professionals, one of the selection criteria will be whether they have adopted behavior and management principles similar to those outlined in this Code.
Furthermore, in entities that the Company may be involved in or where it has appointed a member to the governing body, such members will propose the adoption of values similar to those expressed in this Code.
Integrity and ethics, both in the personal and professional realms, are fundamental and essential principles for the Company. Therefore, all individuals within the Company must carry out their activities with objectivity, professionalism, and honesty, committing to perform their work under optimal conditions.
All actions of the Company and its members will uphold a strict respect for Human Rights and Public Freedoms as outlined in the Universal Declaration of Human Rights by the United Nations.
All individuals working for the Company will maintain strict adherence to the current legal regulations in the territory applicable to their professional activities.
The actions of an executive that are contrary to the law or any instructions or orders they may give in this regard do not exempt employees from responsibility if they follow such instructions or orders.
No order that contravenes a legal provision should be obeyed. Employees must confidentially report the existence of such orders to the “Compliance Committee” immediately through the established channels.
The Company has a solid reputation thanks to its extensive experience and a competent, loyal management team committed to the values that form the corporate culture of the Company.
Consequently, each and every member of the Company will safeguard its good reputation. Specifically, the employees of the Company commit to using social media and other communication channels appropriately, refraining from disseminating any information, statements, or images that could harm the prestige and reputation of the Company, undermine or attack the honor of its professionals, stakeholders, or third parties in general.
The Company will always seek to safeguard the interests of all parties involved in the development of its activities, implementing the appropriate procedures and measures for identifying and resolving potential conflicts of interest.
For its part, the Company’s personnel will perform their duties solely considering the interests of the company and, as a result, will refrain from engaging in any private or personal activities that could result in a conflict of interest. However, should such a situation arise, it must be immediately reported to the “Compliance Committee,” which will be responsible for resolving it.
One of the Company’s core values is treating subordinate personnel as a fundamental source of quality and increased productivity. In this regard, all managers agree that the personnel are the most important asset of the Company. Consequently, the managers and middle management of the Company will not foster “us-versus-them” attitudes among staff and will consider each employee as a fundamental source of ideas for increasing productivity and improving quality.
In line with this, the Company will continue to uphold its commitment to providing job security to all its employees and will ensure the compatibility of their family and work life.
The Company strives to create work environments where trust, respect, and teamwork are promoted. Therefore, any abuse of authority is strictly prohibited, as is any behavior that could create an intimidating or hostile work environment.
Specifically, each member of the Company will contribute to maintaining a pleasant, rewarding, and safe work environment that encourages individuals to give their best in performing their duties. In this sense, the managers and middle management of the Company will promote face-to-face communication among all staff to stimulate enthusiasm and interest in the work of their subordinates and will also keep the staff informed about the Company’s performance and business progress, encouraging the exchange of opinions.
In general, relationships between employees of the Company should follow these basic guidelines:
Relationships Between Superior and Subordinate:
Relationships Between Subordinate and Superior:
The Company guarantees equal opportunities for all its employees and is committed to employing the necessary resources to support their professional and personal development. Therefore, no form of discrimination will be allowed based on gender, race, sexual orientation, religious beliefs, political opinions, nationality, social origin, disability, or any other discriminatory circumstance.
The Company is committed to providing the necessary means and financial resources to contribute to the learning, training, and updating of the knowledge and skills of all employees, aiming to broaden their professional horizons or simply enrich their general culture.
For their part, the Company’s personnel will participate in training programs as required and will strive to make the most of them, applying the knowledge acquired in the performance of their professional tasks.
These programs will aim at acquiring knowledge that allows for professional development as well as training in occupational risk prevention.
Safety and health in the workplace are fundamental aspects for the Company, which is committed to providing the necessary means to minimize risks, both for the Company’s own personnel and for its clients or subcontracted individuals.
All Company personnel will actively work to create and maintain a safe work environment by anticipating the necessary preventive measures to ensure the best possible conditions for safety and occupational health, while strictly adhering to current legislation and internal procedures for risk prevention in the performance of their activities.
The Company is committed to promoting and respecting the right to association and collective bargaining in the workplace.
Any non-public information about the Company or its members, including information related to employees or third parties with whom the Company collaborates in its activities, is considered strictly confidential. The necessary mechanisms will be applied for its proper handling, ensuring its integrity, availability, and confidentiality. All members of the Company will use this information, when necessary, with the utmost caution, preserving its integrity, safeguarding its confidentiality and availability, and minimizing the risks associated with its disclosure and misuse, both internally and externally.
Furthermore, only authorized employees will have access to such confidential information to the extent necessary for the performance of their duties, and they will refrain from disclosing or misusing it in any way that could harm the Company’s image.
The confidentiality obligation will remain after an employee’s activity with the Company has concluded and will include the obligation to return any documentation related to the Company that the employee possessed at the time of termination of their employment relationship.
The Company provides employees with all the necessary material resources for the performance of their professional activities and ensures the means for their proper protection and safeguarding. Each member of the Company is responsible for the correct use and protection of the assets and resources provided, specifically complying with any regulations that may apply regarding their use.
The Company works every day to achieve the highest levels of quality in its products and services. To this end, the Company provides its employees with the best and most advanced technical knowledge and resources and encourages employee involvement in the Company’s core value of striving for excellence.
The Company is committed to transmitting information related to the company in a complete and truthful manner, allowing minority shareholders, analysts, and other stakeholders to form an objective judgment about the Company.
Similarly, the Company commits to cooperating with the supervisory or inspection bodies of the State Administration, in any of its territorial or hierarchical areas, and with anything that may be required in order to facilitate administrative oversight.
Members of the Company must ensure that all economically significant transactions carried out in the name of the Company are clearly and accurately recorded in the appropriate accounting records, reflecting a true image of the transactions and being available to both internal and external auditors.
Consequently, accounting standards and principles must be strictly followed, complete and accurate financial reports must be made, and adequate internal controls and procedures must be in place to ensure that the preparation of financial and accounting reports complies with the applicable legislation at all times.
All Company personnel are obligated to ensure the security of payment methods used in transactions in order to guarantee the proper functioning and traceability of billing and collection procedures, protect customer data, prevent fraud, and comply with regulations related to cash payments.
Employees of the Company will avoid any practices that involve the illegal evasion of tax payments to the detriment of the Public Treasury, Social Security, and equivalent organizations, as well as the use of opaque structures for tax purposes. These structures include those in which, through the interposition of shell companies in tax havens or non-cooperative jurisdictions, are designed to prevent tax authorities from knowing the activities or the ultimate owner of the assets or rights involved.
Furthermore, the Company will ensure that any public assistance requested or received is used appropriately and that its application and use are transparent, avoiding falsification of conditions for obtaining it or using it for purposes other than those for which it was granted.
To prevent any illicit payments, every operation conducted with the Company’s funds must be carried out with due diligence, fulfilling the required duties of care and, in all cases:
The Company is committed to competing in the markets by promoting free competition for the benefit of communities and users, and to complying with the laws established in the different markets where it may operate, avoiding any actions that constitute an abuse or violation of free competition.
The employees of the Company will avoid any conduct that may constitute an abuse or unlawful restriction of competition and should consult legal advisors regarding any doubts that may arise in this area before taking any action.
In relation to the Company’s participation in tenders, competitions, and public auctions, the necessary principles of conduct will be observed to ensure compliance with the applicable administrative legality.
The Company is committed to the protection of its own and third-party intellectual and industrial property. In this regard, employees will respect the reputation of the Company’s distinctive signs (patents, trademarks, trade names, and utility models) and will use them only in the proper development of their professional activities.
The creation, ownership, participation, or collaboration by employees of the Company in social networks, forums, or blogs on the internet, as well as the opinions or statements made on them, will always be done in a manner that clearly indicates they are personal in nature. In any case, employees of the Company must refrain from using the corporate image, trade names, or trademarks of the Company to open accounts or register on these forums and social networks.
Furthermore, the Company’s personnel undertake to respect the intellectual and industrial property rights held by third parties outside the Company, and in all cases, they must obtain the corresponding licenses or authorizations from the legitimate owners when applicable to the performance of their duties, consulting legal advisors regarding any use or situation that may raise doubts about its legality.
Intellectual and industrial property resulting from the work of the Company’s employees during the performance of their duties that relates to the activities carried out by the Company will be the property of the Company.
The processes for selecting the Company’s suppliers are carried out in terms of impartiality and objectivity. Special attention, diligence, and care will be taken to avoid any relationship with individuals or entities that may be involved in unethical or dishonest behavior.
In the selection processes, the employees of the Company responsible for carrying out these tasks must apply criteria of quality and timeliness, always acting in defense of the Company’s interests. Additionally, the “Compliance Committee” must promote the awareness of this Code among the Company’s suppliers for the better implementation of the principles contained in it.
The Company is firmly committed to the protection, conservation, and improvement of the environment, as well as to compliance with urban legality. Therefore, it will establish the relevant mechanisms and management systems to ensure, to the extent applicable to its activities, the appropriate training of its employees and collaborators and compliance with the applicable regulations for this purpose.
The members of the Company will comply with the legal and professional obligations that may apply to the professional actions they carry out. Furthermore, the Company expresses its firm commitment to the values and principles stated in this Code of Ethics and does not tolerate practices that may be considered irregular in its relationships with clients, suppliers, partners, competitors, and other third parties or stakeholders.
In particular, the members of the Company will pay special attention to preventing behaviors related to money laundering and terrorist financing. To this end, due diligence, information, and internal control measures will be applied, and full cooperation will be provided to the competent authorities.
Managers, employees, and any external persons providing services to the Company, in their relationships with national public administrations, third-country governments, international organizations, and other individuals, must act in a manner that does not induce any public official, authority, or individual to violate their duties of impartiality or any legal provision. That is, even in private business relationships, offering any type of gift or illicit advantage to employees of other companies responsible for the acquisition or contracting of goods or services is prohibited, with the aim of causing them to favor the acquisition of our products through the breach of their duties.
In general, offering any type of gift, attention, invitation, gratuity, compensation, or undue advantage to authorities, public officials, or individuals that exceeds the criteria established in the Company’s internal policies is prohibited.
This prohibition extends to individuals closely related by family or friendship ties to the public official, authority, or individual and includes:
Ultimately, it is each employee’s responsibility to adequately know and assess local practices, considering the interests and good reputation of the Company. The limits established in the internal policies should always be applied, and in case of doubt, the “Compliance Committee” should be consulted before taking any action.
BODEGAS ENTREMONTES’ commitment to the community is reflected in the development and promotion of initiatives aimed at improving the quality of life of the people in the societies where it operates, provided that such contributions are related to the different areas of activity carried out by the Company.
This commitment is primarily carried out through social action, sponsorship, and patronage activities managed by “BODEGAS ENTREMONTES,” a non-profit organization with a nationwide scope whose primary purpose is to promote popular culture and gastronomic traditions, primarily through the offering of training courses in this field.
The Company has established as its primary objective the satisfaction of its clients, with excellence in the services and products it offers being its utmost priority. Therefore, all employees will guarantee quality customer service by providing efficiency and professionalism in their interactions and dealings with clients. Specifically, the employees of the Company commit to providing clients with respectful and non-discriminatory service.
In the same vein, and in accordance with the next section, the Company commits to ensuring that the services and products offered to clients do not pose any health risks, providing necessary means to mitigate or eliminate them, and always acting in accordance with the applicable regulations.
Specifically, regarding the hospitality activities carried out by the Company, it commits to implementing the necessary guidelines and policies to offer clients fresh and high-quality products, marketing only those that meet the guarantees and requirements set by current legislation, including quality, composition, and expiration standards. The Company also ensures that suppliers have the necessary quality and food safety certifications required for this purpose.
The Company reserves the right of admission to its facilities, and may therefore deny access to certain clients only in cases where it is properly justified based on a reasonable expectation of violation or breach of socially recognized ethical values and human rights.
In accordance with current regulations, the Company has a “complaints and suggestions book” available to clients, committing to resolve any incidents efficiently and quickly, aiming to satisfy the interests of all parties involved as much as possible.
All employees of the Company are obligated to understand the content of this Code and the values on which it is based, and to respect it and ensure its effective implementation.
This Code is dynamic and open to participation from everyone. Therefore, any suggestions, doubts, or criticisms should be communicated to the “Compliance Committee,” which is the competent body responsible for ensuring compliance with the Code and for promoting its dissemination and the necessary specific training for its proper application.
The “Compliance Committee” will have the necessary resources to ensure the application of this Code and may act on its own initiative or at the request of any employee or third party with sufficient interest through a report made in good faith. Its decisions will be binding for the Company and for all employees.
Additionally, the “Compliance Committee” will prepare and maintain an updated criminal risk map for the Company and propose to the governing body the measures and controls it considers necessary for the continuous improvement of the criminal risk prevention program developed within the Company, which is based on this Code.
Managers and employees of the Company have the duty to immediately report to the “Compliance Committee” any illegal behaviors, irregularities, or violations they become aware of through the designated email address for whistleblowing.
The reports, in addition to helping uncover possible irregularities, are an essential tool for ensuring that this Code is fully enforced and for continuously improving our criminal risk prevention system.
The Company’s activities may reveal new conflicts and ethical dilemmas where applying the provisions of this Code may not always be straightforward. Consequently, all employees and stakeholders are encouraged to use the previously provided email address to make inquiries regarding professional practice or to report possible violations or non-compliance, with the assurance that strict confidentiality will be maintained at all times.
The reports made will be handled through the internal channels established, and in any case, the “Compliance Committee” will ensure that no reprisals of any kind occur against the whistleblowers.
The Company will apply the legal or disciplinary measures it deems appropriate, in accordance with current legislation, to prevent non-compliance with this Code. Inappropriate behavior, and therefore subject to legal or disciplinary sanctions, will apply not only to those who violate the Code but also to those who, by action or omission, approve such behaviors or are aware of these violations and do not attempt to correct them immediately.
In this regard, specific or supplementary regulations may be established to develop this Code, incorporating certain corrective measures for cases of non-compliance.
This Code will be distributed to all employees of the Company and will also be published on the corporate website.
Furthermore, the Company is committed to carrying out the appropriate communication, training, and awareness actions to promote a culture of compliance and disseminate the content of the Code to all its employees. For this purpose, training sessions and support will be organized, in which the protocols and specific policies that make up the criminal risk prevention program developed within the Company will be explained, and that affect, directly or indirectly, each of the identified risk areas.
The obligation to comply with the Code will be explicitly included in the employees’ employment contracts, and the “Compliance Committee” will ensure the proper communication of the adherence to this Code to third parties who, for any reason, must adhere to the rules contained therein.
This Code will come into effect on the fifth business day following the date of approval by the Company’s governing body and will remain in force until the governing body approves its update, revision, or repeal.
The Code will be reviewed and updated at the frequency specified by the governing body. In any case, any revisions and updates made will take into account changes in the activities carried out by the Company and in the applicable legislation at any given time.
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