Code of Ethics

Part of something bigger than us

Working at Regenera Luxury is about contributing to the growth and success of an international organisation deeply committed to creating wealth for our stakeholders, for nature and for 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

• Conduct all business with the highest standards of integrity and sustainability values.
• Follow the law and uphold all contractual agreements.
• Maintain a culture where making a positive impact is practiced by all employees.
• Avoid conflicts of interest and circumstances that may lead to a conflict.
• Commit to environmental responsibility.
• Exercise common sense.

A program built on the highest standards of integrity

The Regenera Luxury Code is an integral part of Regenera Luxury’s Compliance Program, adopted to help employees understand the company’s business behaviour and comply 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

• Setting ethics and integrity compliance standards.
• Communicating those standards through written policies.
• Providing a mechanism for employees to report issues of compliance or legal concern.
• Monitoring and auditing employee practices.
• Maintaining an organisational structure that supports the furtherance of the program.

Regenera Luxury will make periodic changes to the Code as laws change and issues evolve, and as our business grows and expands.

Individual Responsibility

Employee and Partner responsibilities under the Regenera Luxury Code include:

• Seeking assistance or clarification of the Regenera Luxury Code before taking any questionable action, to avoid unethical or illegal business conduct.
• Reporting any potentially improper, unethical or illegal behaviour.

Language proficiency shall not be a barrier for employees or Partners. Regenera Luxury will translate the Code into the languages its employees speak and understand, and will provide additional translations as it expands into new areas.

Regenera Luxury and Partner managers and leaders must create an environment where employees feel comfortable asking questions and raising concerns, and establish procedures and provide opportunities for employees to attend training.

Those who fail to follow the Regenera Luxury Code put themselves, their colleagues and Regenera Luxury at risk, and may face disciplinary action up to and including termination, as well as potential government prosecution. Violations by third parties will be considered grounds for termination of the relationship and may result in referral for prosecution.

Enforcing the Code is impossible without the participation and support of employees and Partners at all levels. Regenera Luxury maintains a strict non-retaliation policy: any retaliation for a raised concern is itself 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.

Local and international law, honoured

Regenera Luxury takes very seriously its responsibility to follow both local and international laws and regulations, and we expect our employees and Partners to do the same. While it is impossible for every employee to know every detail of every applicable law, we ask that employees and Partners understand the laws and regulations that apply specifically to their work, job duties and location.

Regenera Luxury is further committed to honouring contractual obligations. All business shall be conducted in a manner consistent with the company’s strong commitment to the highest standards of integrity.

Performing every role with integrity

We trust that every employee is dedicated to performing their job with integrity. To support this, Regenera Luxury offers company-wide and role-specific training to increase understanding of the Code. We further expect 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 dedicated to promoting sustainability and ethical conduct in hospitality — Regenera Luxury has joined other leading companies to identify and share best ethical and compliance practices. In all our ventures we act in good faith and deal fairly, staying true to our word and honouring contractual obligations.

Equal Opportunity Employer

Regenera Luxury is committed to equal employment opportunity and to a work environment free of discrimination and harassment. All employment decisions are based on business needs, job requirements and individual qualifications — without regard to race, colour, religion or belief, national or ethnic origin, sex (including pregnancy), age, physical or mental disability, sexual orientation, gender identity and/or expression, marital status, military service, medical history, or any other status protected by law. We will not tolerate discrimination or harassment based on any of these characteristics, and we expect the same of our employees and Partners.

Respect the Individual

Founded on two central beliefs — integrity and sustainability — De Castro Group does not tolerate any behaviour or symbols that threaten the physical and mental wellbeing of anyone who works for Regenera Luxury, including biased or racially motivated behaviour, harassment, sexual harassment, bullying or hazing for any reason. 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, and must not discriminate against any of them on the basis of any status protected by anti-discrimination laws in our geographies. Antitrust laws exist to preserve the competition essential to fair trade practices and the global economy.

Socially Responsible

Working with world-class customers in the global economy, Regenera Luxury has a duty to help solve — rather than contribute to or ignore — the problems and challenges of our industry and the world. We are committed to minimising our impact on the environment and waste, conserving natural resources, supporting more sustainable practices and products, respecting the rights of individuals, improving workplace conditions, complying with local labour laws, and eliminating corruption.

Stand Up to Corruption

An improper payment to gain advantage in any situation is never acceptable, and exposes both 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 applicable environmental laws and regulations, including cooperating with law-enforcement and regulatory agencies that conduct inspections or investigations into possible violations. Regenera Luxury goes beyond compliance and is committed to sustainability.

Bribery

Bribery is illegal and Regenera Luxury prohibits it in any form. Bribery means promising, offering or giving “anything of value” with the intent of influencing an act or decision, or obtaining an improper advantage to gain or retain business. Bribes take many forms and there is no minimum value. Examples of “things of value” include cash, gifts to family members, forgiveness of a debt, loans, personal favours, entertainment, travel, political and charitable contributions, and business or employment opportunities.

Facilitation Payments

Employees and third parties acting on Regenera Luxury’s behalf are prohibited from making “facilitation” payments — payments made to government officials to expedite or ensure the performance of a routine governmental action (for example, processing visas or issuing permits).

Protect Human Rights

Regenera Luxury is committed to the highest standards of ethical conduct and respect for human rights, and is opposed to all forms of human trafficking, child exploitation and slavery. We comply with all applicable labour and employment laws and will cooperate with authorities to address any instances of exploitation.

Fair and impartial decisions

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 activity or relationship 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 when an employee’s outside activities, personal financial interests or other personal interests influence, or appear to influence, their ability to make objective decisions at work. Regenera Luxury employees shall remain free of outside influences in the performance of workplace duties and responsibilities.

Stewards of the company’s name and resources

Regenera Luxury facilities and company-owned equipment — including vehicles, phones, copiers and computers — should be used for business purposes. The unauthorised 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 threatening materials, or to knowingly, recklessly or maliciously transmit false or obscene materials, or anything that constitutes or encourages a violation of the law.

Be Truthful in Marketing and Advertising

In preparing, using or discussing Regenera Luxury marketing and advertising materials, we must ensure that:

• No false, misleading or unsubstantiated statements are used.
• All Regenera Luxury proprietary data is properly marked.
• When trademarks of another company are used, they are used correctly and their owners are given proper attribution.

If you are 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 its behalf engages in improper business practices, or if the company’s dealings with that third party are themselves found to be improper. Regenera Luxury will not engage or do business with a third party where it believes there is a material risk that the party will violate anti-corruption laws or the prohibitions of the Code.

Selective with Consultants and Subcontractors

Regenera Luxury can be held accountable for the acts of its agents and could face penalties and sanctions for illegal acts committed by joint-venture partners, third parties, consultants, subcontractors, suppliers and other entities doing business with or for it. As part of prequalification, our subcontractors confirm that they understand the Code, will comply with its requirements, and have no open, pending or closed litigation on matters it covers — reaffirming compliance each time they prequalify. Our standard contract terms require joint-venture partners, third parties, subcontractors, consultants and suppliers to comply with the Code and all applicable laws, and we have the right to terminate those agreements upon breach.

Protecting what gives us our edge

The information, knowledge and know-how that gives Regenera Luxury a competitive advantage is intellectual property — an asset as valuable as money, property, time or skill. It can only be used for authorised business purposes. All employees are required to sign an intellectual-property agreement and to 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. This intellectual property — including data and information systems, customer lists and other trade secrets — remains with Regenera Luxury when an employee leaves the company.

Confidentiality Agreements

Many customers require Regenera Luxury to sign confidentiality or non-disclosure agreements, within our contracts or separately. Employees must comply with these agreements by not revealing protected information, and must communicate these requirements to the entire project team.