Code of Conduct
1. PURPOSE AND STRUCTURE
This Code of Conduct (the "Code") sets out the core ethical principles and standards that guide the business activities of RETAIL FOR TOMORROW, S.L. (“Kombo”) in its relationships with its clients, partners and other stakeholders. It applies primarily to Kombo’s directors, employees and contractors when interacting with clients and performing services under client agreements. Kombo expects all persons subject to this Code to conduct themselves with integrity, professionalism and respect for applicable laws and regulations.
2. COMPLIANCE WITH LAWS AND REGULATIONS
Kombo is committed to complying with all applicable laws and regulations in the jurisdictions in which it operates, including laws relating to food safety, employment, data protection, competition, taxation and corporate governance.
3. ANTI-BRIBERY AND ANTI-CORRUPTION
Kombo maintains a zero-tolerance approach to bribery and corruption in its dealings with clients and business partners. No director, employee or contractor of Kombo may offer, give, solicit or accept any bribe, kickback or improper advantage, whether directly or indirectly, in connection with Kombo’s business or client relationships.
4. HUMAN RIGHTS AND MODERN SLAVERY
Kombo is committed to respecting human rights and does not tolerate any form of modern slavery, forced labor, child labor or human trafficking in connection with its business activities. Kombo expects its own operations to comply with applicable labor and employment laws and to uphold fair and lawful working conditions.
5. CONFLICTS OF INTEREST
Individuals subject to this Code must avoid situations in which personal interests conflict, or appear to conflict, with the interests of Kombo or its clients. Any actual or potential conflict of interest must be disclosed promptly to Kombo so that it can be appropriately managed.
6. ETHICAL BUSINESS PRACTICES AND CLIENT RELATIONSHIPS
Kombo is committed to conducting business with honesty, transparency and professionalism. In particular, Kombo seeks to:
deal fairly and in good faith with clients;
provide clear, accurate and non-misleading information regarding its services;
respect client confidentiality and commercial sensitivities; and
comply with applicable competition and fair-trading laws.
7. CONFIDENTIALITY AND DATA PROTECTION
Kombo is committed to protecting confidential information and personal data of its clients in accordance with applicable data protection laws, including the GDPR. Confidential and personal information must be handled responsibly and used solely for legitimate business purposes.
8. REPORTING CONCERNS
Kombo encourages the reporting of any suspected misconduct, unethical behavior or violations of this Code. Reports may be made through appropriate internal channels and will be handled in good faith and without retaliation.
9. ENFORCEMENT
Breaches of this Code may result in appropriate corrective action in accordance with applicable law and internal policies. This Code is intended to set ethical standards and does not create additional contractual rights or obligations beyond those expressly agreed with clients.
10. UPDATES
Kombo may update this Code from time to time to reflect changes in law or business practices. The most recent version will be made available through Kombo’s official channels.