Ethics Matters
At REGENERA LUXURY, we uphold the highest standards of integrity and professionalism in everything we do. We are committed to creating a workplace rooted in honesty, respect, and accountability. Every decision reflects our core values. Ethical conduct is essential for building trust with employees, clients, and partners. It forms the foundation of our reputation and success. A robust Code of Ethics empowers team members to make principle-aligned decisions. This fosters a workplace of fairness, transparency, and mutual respect.
Working at REGENERA LUXURY is about being part of something bigger than us. It’s about contributing to the growth and success of an international organization deeply committed to create wealth for our stakeholders, nature and social communities.
REGENERA Luxury has developed the REGENERA Luxury Code to help guide employees through the many rules and regulations of today’s complex business environment. We expect our business partners, subcontractors and suppliers (collectively, our “Partners”) to be guided by the REGENERA Luxury Code too.
The REGENERA Luxury Code:
The REGENERA LUXURY Code is an integral part of REGENERA Luxury’s Compliance Program, which has been adopted to assist employees in better understanding REGENERA Luxury’s business behavior and complying with the legal, regulatory and ethical obligations of the company and its personnel. The program conveys REGENERA Luxury’s commitment to the highest standards of integrity.
The program involves:
REGENERA Luxury will make periodic changes to the Code as laws change and issues evolve as our business grows and expands.
Individual Responsibility
Employee and Partner responsibilities under the REGENERA Luxury Code include:
Language proficiency shall not be a barrier for employees or Partners. As such, REGENERA Luxury will translate the REGENERA Luxury Code into the languages its employees speak and understand. REGENERA Luxury will provide employees and Partners with additional translations as it expands into new areas.
REGENERA Luxury/Partner managers and leaders must:
Those who fail to follow the REGENERA Luxury Code and its requirements put themselves, their colleagues and REGENERA Luxury at risk, and may face (i) disciplinary action up to and including termination, and (ii) potential government prosecution. Violations of the REGENERA Luxury Code by third parties will be considered grounds for termination of the relationship and may result in referral for prosecution.
Enforcing the REGENERA Luxury Code is impossible without the participation and support of employees and Partners at all levels. REGENERA Luxury may be unaware of a serious breach of the REGENERA Luxury Code until an employee or Partner brings that matter to the attention of REGENERA Luxury leadership. REGENERA Luxury has a strict non-retaliation policy and any retaliation for a raised concern is grounds for disciplinary action, up to and including termination of employment.
Investigations and Reviews
REGENERA Luxury is committed to investigating potential violations of law and company policy and to implementing timely and appropriate remediation and process improvements as warranted.
REGENERA LUXURY takes very seriously our responsibility to follow both the local and international laws and regulations, and we expect our employees and Partners to do the same. Although we realize it’s impossible for every employee to know every detail of every law and regulation that applies to REGENERA Luxury’s business, we ask that employees and Partners understand the laws and regulations that apply specifically to their work, job duties and location (i.e. different countries may have different laws and regulations).
REGENERA Luxury is further committed to honoring contractual obligations. All business shall be conducted in a manner consistent with REGENERA Luxury’s strong commitment to the highest standards of integrity.
We trust that every employee is dedicated to performing their job with integrity. To support this, REGENERA LUXURY offers training (both company-wide and role specific) to increase employee understanding of the REGENERA Luxury Code. Furthermore, REGENERA Luxury expects that services and products supplied by consultants, subcontractors, suppliers and other entities doing business with REGENERA Luxury meet our high level of integrity expectations.
Raise Industry Standards
As a member of REGENERA, the Luxury Sustainable Hotels International Association, a nonprofit association dedicated to promoting sustainability and ethical conduct in the hospitality industry, REGENERA Luxury has joined other leading companies to identify and share best ethical and compliance practices within our industry.
In all our business ventures, REGENERA Luxury shall always act in good faith and deal fairly. That means staying true to our word and honoring contractual obligations. All employees and partners must be faithful to contract requirements and the interests of the project as well.
Equal Opportunity Employer
REGENERA Luxury is committed to the principle of equal employment opportunity for all employees and to providing employees with a work environment free of discrimination and harassment. All employment decisions at REGENERA Luxury are based on business needs, job requirements and individual qualifications, without regard to race, color, religion or belief, national or ethnic origin, sex (including pregnancy), age, physical or mental disability, sexual orientation, gender identity and/or expression, marital, civil union or domestic partnership status, past or present military service, medical history, or any other status protected by the laws or regulations in the locations where we operate. REGENERA Luxury will not tolerate discrimination or harassment based on any of these characteristics. We expect the same of our employees and Partners.
Respect the Individual to create good
As a company group founded on two central beliefs, integrity and sustainability, DE CASTRO GROUP does not tolerate any behavior or symbols that threaten the physical and mental wellbeing of anyone who works for REGENERA Luxury, including behavior or symbols that are biased and racially motivated, harassment, sexual harassment, bullying or hazing for any reason including one based on an individual’s race, color, sex, age, gender, sexual orientation, gender identity and/or expression, religion or belief, national or ethnic origin, disability, or any other protected characteristic. We expect our employees and Partners to respect all individuals in the same way.
Treat Subcontractors and Suppliers Fairly
REGENERA Luxury employees must treat all subcontractors, vendors and suppliers fairly. Employees should not discriminate against any subcontractor, vendor or supplier because of race, sex, age, national origin, citizenship, ancestry, religion, disability, veteran status or any other status protected by anti-discrimination laws in our geographies.
Also, antitrust laws exist to preserve competition that is essential to fair trade practices and the global economy.
Socially Responsible
As a company group working with world-class customers in the global economy, REGENERA Luxury has a duty to help solve—rather than contributing to or turning our back on—the problems and challenges in our industry and the world. For example, REGENERA Luxury is committed to minimizing our impact on the environment and waste, conserving natural resources, supporting the use of more sustainable practices and products, respecting rights of individuals, improving workplace conditions, complying with local labor laws, and eliminating corruption.
Stand Up to Corruption
An improper payment to gain advantage in any situation is never acceptable and exposes you and REGENERA Luxury to criminal sanctions and/or civil liability under national, state, local and foreign anti-bribery laws.
Environmental Responsibility
REGENERA Luxury complies with the applicable environmental laws and regulations, including cooperating with law enforcement and regulatory agencies that conduct inspections or investigations into possible violations of such laws and regulations. REGENERA Luxury goes beyond and is committed to sustainability.
Bribery
Bribery is illegal and REGENERA Luxury prohibits bribery of any kind. Bribery means promising, offering, or giving “anything of value” with the intent of influencing an act or decision of the recipient or obtaining an improper advantage to gain or retain business. Bribes can take many different forms, and there is no minimum value, regardless of whether it is reimbursed by REGENERA Luxury or comes out of the employee’s own pocket. Examples of “things of value” include cash, gifts to family members, forgiveness of a debt, loans, personal favors, entertainment, travel, political and charitable contributions, business opportunities or employment opportunities.
Facilitation Payments
Employees and third parties acting on REGENERA Luxury’s behalf are also prohibited from making “facilitation” payments, which are payments made to government officials in exchange for expediting or ensuring the performance of a routine governmental action or function (e.g. processing visas, issuing permits).
Protect Human Rights
REGENERA Luxury is committed to supporting and maintaining the highest standards of ethical conduct and respect for human rights, and is opposed to all forms of human trafficking, child exploitation, and slavery. REGENERA Luxury is committed to complying with all applicable labor and employment laws, rules, and regulations, and will cooperate with authorities to address any instances of exploitation which REGENERA Luxury or its employees have become a party to.
REGENERA LUXURY’s reputation relies on the integrity and action of our employees, who should always act in the best interests of our customers and companies. Avoid any activities or relationships that might compromise or even appear to compromise your ability to make fair and impartial decisions.
Disclose Personal Activities and Interests
A conflict of interest may occur if an employee’s outside activities, personal financial interests, or other personal interests influence or appear to influence their ability to make objective decisions while doing their job. REGENERA Luxury employees shall remain free of outside influences in the performance of workplace duties and responsibilities.
REGENERA LUXURY facilities and company-owned equipment, including vehicles, phones, copiers, and computers, should be used for business purposes. The unauthorized removal of REGENERA Luxury property may be considered theft.
Employees may not use REGENERA Luxury communication channels or access the Internet at work to post, store, transmit, download or distribute any threatening materials, knowingly, recklessly, or maliciously transmit false materials, obscene materials, or anything constituting or encouraging the violation of any laws.
Be Truthful in Marketing and Advertising
In preparing, using or discussing DPR marketing and advertising materials, we must ensure that:
If you’re unsure, contact your local Communications+Brand team member for advice
Third Parties
Under relevant Anti-Corruption Laws, REGENERA Luxury may face liability if a third party acting on the company’s behalf engages in improper business practices, or if the company’s business dealings with the third party itself are found to be improper. REGENERA Luxury will not engage or do business with a third party if the company believes there is a material risk that the third party will violate anti-corruption laws or the prohibitions of the REGENERA Luxury Code.
Selective with Consultants and Subcontractors
REGENERA Luxury can be held accountable for the acts of its agents and could be exposed to penalties and sanctions for any illegal acts committed by joint venture partners, third parties, consultants, subcontractors, suppliers and other entities doing business with or for REGENERA Luxury.
As part of prequalification, our subcontractors confirm they understand the REGENERA Luxury Code, will comply with its requirements, and that they have no open, pending or closed litigation on any matters covered by the REGENERA Luxury Code. Our subcontractors reaffirm their compliance with the REGENERA Luxury Code each time they prequalify.
Our standard contract terms also require joint venture partners, third parties, subcontractors, consultants, and suppliers to comply with the REGENERA Luxury Code and all applicable laws and regulations, and we have the right to terminate those agreements upon breach of those terms. REGENERA Luxury’s reputation also depends on doing business only with subcontractors and suppliers that deal with their workers and treat the environment responsibly.
The information, knowledge and know-how that gives REGENERA LUXURY a competitive advantage is considered intellectual property and is an asset as valuable as money, property, time or skill. As such, REGENERA Luxury’s intellectual property can only be used for authorized business purposes. All REGENERA Luxury employees are required to sign an intellectual property agreement and disclose any applicable personal intellectual property.
Employees must protect REGENERA Luxury’s proprietary and confidential information, which may include technical designs, strategy, software, employee records or information learned in a partnership or teaming arrangement.
REGENERA Luxury’s intellectual property, including data and information systems, customer lists, and other trade secrets, will remain with REGENERA Luxury when an employee leaves the company.
Confidentiality Agreements
Many customers require REGENERA Luxury to sign confidentiality or nondisclosure agreements, either within our contracts or separately. REGENERA Luxury employees must comply with these agreements by not revealing protected information. And it’s important to communicate these requirements to the entire project team.
