Company ethical code




3.1 Respect for legality

3.2 Ethical integrity

3.3 Respect for Human Rights


4.1 Respectful treatment and prohibition of discrimination

4.2 Abolition of child labor

4.3 Equal opportunities

4.4 Occupational safety and health

4.5 Respect for the privacy and confidentiality of employee information

4.6 Promotion of personal and professional balance


5.1 Fair competition

5.2 Probity in management

5.3 Quality

5.4 Confidentiality in third party information

5.5 Transparency, Value Creation and Corporate Governance

5.6 Protection of corporate assets

5.7 Conflicts of Interest

5.8 Use of information on LUQUE ECOLÓGICO S.L.


6.1 Environment

6.2 Social Commitment




The goal of this Code of Business Ethics (the “Code”) is to establish the basic principles that behaviour of LUQUE ECOLÓGICO, S.L. company and all its employees and managers must follow.

The Code builds on our core values by providing greater detail about expected behaviours and drives our culture of compliance, ethical conduct and accountability


The Code links the following persons and entities:

• Members of Board of Directors of LUQUE ECOLOGICO, S.L.

• Members of Management Committee and rest of components of Management of LUQUE ECOLOGICO, S.L.

• All employees who carry out their work at LUQUE ECOLOGICO, S.L.

• All other entities and organizations linked to LUQUE ECOLOGICO, S.L. or any of the companies in its group due to a domain relationship or whose management, by any other title, is responsibility of LUQUE ECOLOGICO, S. L..


The business and professional behaviour of the entities and people referred to in the previous section must follow these basic principles:

3.1. Respect for legality

Business and professional activities will be developed with strict compliance with current legislation in each place they are developed.

3.2. Ethical integrity

Business and professional activities will be based on the value of integrity and will develop in accordance with the principles of honesty, avoiding all forms of corruption and respecting the circumstances and particular needs of all subjects involved in these activities.

LUQUE ECOLOGICO, S.L. will promote among its employees recognition and assessment of behaviours that are in accordance with the principles established in this Code.

3.3. Respect for human rights

All actions of LUQUE ECOLOGICO, S.L. and its employees will keep a strict respect for Human Rights and Public Freedoms included in the Universal Declaration of Human Rights.

These basic principles will translate into compliance with commitments set out below.

3.4. Prevention of Money Laundering and Terrorist Financing

The objective is to establish guidelines that govern the management of risk of money laundering and terrorist financing (hereinafter, MLTF; consult document) to which LUQUE ECOLOGICO SL is exposed both internally and externally, with the final purpose of being able to prevent them and, if they occur, have suitable mechanisms to mitigate their impact on the organization.


Relationship of LUQUE ECOLOGICO, S.L. with their employees and between employees will be based on the fulfilment of the following commitments:

4.1. Respectful treatment and prohibition of discrimination

LUQUE ECOLOGICO, S.L. assumes the responsibility of maintaining a work environment free of all discrimination and any conduct that involves harassment in the Workplace.

All workers must be treated fairly and with respect by their superiors, subordinates and colleagues.

Any abusive, hostile, or offensive conduct, whether verbal or physical, will not be tolerated.

4.2. Abolition of child labour

LUQUE ECOLOGICO, S.L. does not admit child labour.

LUQUE ECOLOGICO, S.L. will not hire child labour nor will incorporate any product or service derived from it into its business activity and will ensure compliance with the provisions of the International Labour Organization (ILO) regarding the work of minors.

LUQUE ECOLOGICO, S.L. requires all its employees and suppliers to strictly observe this principle.

4.3. Equal opportunities

All employees will enjoy equal opportunities for development of their professional careers.

LUQUE ECOLOGICO, S.L. undertakes to establish an effective policy of equal opportunities for its employees to carry out their professional activities on the basis of the principle of merit. Promotion decisions will always be based on objective circumstances and evaluations. Likewise, LUQUE ECOLOGICO, S.L. undertakes to maintain an investment policy for the learning and personal and professional training of its employees.

Employees of LUQUE ECOLOGICO, S.L. will respect the policy of equal opportunities in their professional environment and will support the personal and professional learning of their colleagues.

4.4. Occupational safety and health

LUQUE ECOLOGICO, S.L. It will provide its employees with a safe and stable environment and is committed to permanently updating occupational risk prevention measures as well as scrupulously respecting the regulations applicable in this matter in all places where it carries out its business activities.

All employees are responsible for observing rigorous compliance with health and safety regulations. Likewise, they must responsibly use the equipment assigned to them when they carry out risk activities and will share their knowledge and promote compliance with risk protection practices to their colleagues and subordinates.

4.5. Respect for the privacy and confidentiality of employee information

LUQUE ECOLOGICO, S.L. undertakes to request and exclusively use those data from employees that are necessary for the effective management of its businesses or whose possession is required by applicable regulations. Likewise, LUQUE ECOLOGICO, S.L. will take all necessary measures to preserve confidentiality of personal data available and to guarantee that confidentiality in their transmission for business reasons complies with current legislation.

Employees who, due to their professional activity, have access to information of other employees will respect and promote confidentiality of this information and will make a responsible and professional use of it.

4.6. Promotion of work-life balance (WLB)

LUQUE ECOLOGICO, S.L. will promote a balance between work and family life of its employees.

LUQUE ECOLOGICO, S.L. values benefits for the employee and for the company of having a balance between professional and personal responsibilities of its employees. For this reason, it will promote measures aimed at reconciling these two areas.


LUQUE ECOLOGICO, S.L. and its employees will base their relationships with customers, suppliers, competitors and partners as well as with their shareholders, investors and other market agents on the principles of integrity, professionalism and transparency.

5.1. Fair competition

LUQUE ECOLOGICO, S.L. prohibits any action that involves the practice of unfair competition practices and undertakes to ensure compliance with applicable competition laws in the countries where carries out its activities.

5.2. Transparency and honesty in management

LUQUE ECOLOGICO, S.L. prohibits bribes to authorities and public officials and prohibits its employees from giving to third parties or receiving from third parties undue payments of any kind, or gifts or favours that are out of the market's uses or that, due to their value, their characteristics or their circumstances can reasonably alter development of commercial, administrative or professional relationships in which their companies are involved.

5.3. Quality

LUQUE ECOLOGICO, S.L. is committed to the quality of its products and services.

LUQUE ECOLOGICO, S.L. establishes as a guideline for its business performance the search for quality in its products and services and will make available to its employees necessary means to develop the most appropriate quality management systems at all times.

LUQUE ECOLOGICO, S.L. will seek the best satisfaction of its clients expectations and will develop an effort of knowing their needs in advance.

5.4. Confidentiality regarding third party information

LUQUE ECOLOGICO, S.L. guarantees the respect of the confidentiality and privacy of third parties data that manages.

LUQUE ECOLOGICO, S.L. undertakes to preserve the confidentiality of data it has related to third parties except always legal, administrative or court obligations that order to deliver them to entities or people or to make them public. Likewise, LUQUE ECOLOGICO, S.L. guarantees the right of affected third parties to consult and promote modification or rectification of data when necessary.

Employees of LUQUE ECOLOGICO, S.L., in development of their professional activity, will keep confidential data in the terms set above and will refrain from any inappropriate use of this information.

5.5. Transparency, Value Creation and Corporate Governance

LUQUE ECOLOGICO, S.L. assumes as a guiding principle of its business behaviour towards its shareholders, investors, analysts and the market in general, to transmit truthful, complete information that expresses the true image of the company, its business activities and its business strategies.

The communication will always be carried out in accordance with the rules and within deadlines established by the legislation in each current case.

The business action and strategic decisions of LUQUE ECOLOGICO, S.L. will be focused on creating value for their shareholders, transparency in their management, adoption of the best Corporate Governance practices in the company and strict observance of the regulations that are currently in force on this matter.

5.6. Protection of business heritage

LUQUE ECOLOGICO, S.L. and its employees will always seek the best protection of all assets and rights that constitute the assets of the company, preserving the confidentiality of related information that can only be used in relation to the activities of the company.

Employees are responsible for protecting the assets of LUQUE ECOLOGICO, S.L. that have been entrusted to them and preserve them from any loss, damage, theft or illegal or dishonest use.

5.7. Conflicts of Interest

All employees of LUQUE ECOLOGICO, S.L. should avoid situations that may pose a conflict between your personal interests and those of LUQUE ECOLOGICO, S.L. and refrain from representing society or intervening or influencing decision-making in which, directly or indirectly, he himself or a third party linked to him by any significant economic, family or professional relationship had a personal interest.

Employees who are in a conflict situation will have the obligation to communicate it to their hierarchical superior. Conflicts between personal interests and business interests will always be resolved for the benefit of the company LUQUE ECOLOGICO, S.L ..

5.8. Use of information on LUQUE ECOLOGICO, S.L.

LUQUE ECOLOGICO, S.L. requires its employees to make discreet and professional use of the information of the company to which they have access in the course of their activity, as well as to limit their use to the company's own activities and undertakes to establish management systems focused in respecting this principle.


6.1. Environment

LUQUE ECOLOGICO, S.L. assumes the commitment to ensure the greatest respect for the environment in the development of its activities as well as to minimize the negative effects that these may eventually cause. It will make available to its employees the most appropriate means for this.

Also, LUQUE ECOLOGICO, S.L. will contribute to the conservation of natural resources and those spaces that have ecological, landscape, scientific or cultural interest. For achieving this, it will establish best practices and promote knowledge and use of them among its employees.

LUQUE ECOLOGICO, S.L. undertakes to strictly comply with the applicable environmental legislation.

6.2. Social commitment

LUQUE ECOLOGICO, S.L. undertakes to act in a responsible way in society, in compliance with laws of the countries in which it operates and, in particular, assumes the responsibility to respect cultural diversity and customs and principles in force among the people and communities affected by its activities.

See "Corporate Social Responsibility Policy"


7.1. This Code establishes the principles and commitments of business ethics that LUQUE ECOLOGICO, S.L. and its employees must respect and comply in the exercise of their activities.

7.2. Any employee who has knowledge or well-founded suspicion of a breach of this Code may inform his superior or report it through the mechanisms established by the company to formulate suggestions and complaints. LUQUE ECOLOGICO, S.L. will take the necessary measures to avoid adverse consequences due to the communications that employees make in good faith as provided herein.

7.3. Violation or non-compliance with this Code that constitutes a lack of employment, will be sanctioned in accordance with current regulations, without prejudice to other responsibilities in which the person involved could have concurred.