Since Staria’s founding, we have sought to ensure that all of us who are part of the company act with integrity and honesty, building fair business relationships in full compliance with both the policies of the brands we distribute and applicable laws.
This organizational culture has served as the benchmark and guiding principle for our employees’ conduct in their daily responsibilities, enabling us to earn the commitment and loyalty of our customers and suppliers, and thereby maintain the prestige of the brand we represent and the quality of the service we provide.
This Code of Conduct reflects Staria’s corporate principles. Through it, we seek to continuously strengthen the values and principles that guide us as an organization by establishing certain standards of conduct applicable to all employees.
The Code of Conduct does not aim to cover every possible situation that may arise; rather, its purpose is to serve as a framework for the conduct of all members of the organization and to ensure that such conduct is aligned with the company’s culture and values.
It is everyone’s responsibility to ensure compliance with the code. To achieve this, we must follow these guidelines:
1. COMPLIANCE WITH LAWS, RULES, AND REGULATIONS
At Staria, employees shall enjoy all human and civil rights and shall have all other obligations of the same nature as established by the laws governing the national territory. In addition, employees must adhere to internal policies and regulations as they apply to a given situation. These policies are specific to the company and may go beyond legal requirements without contravening them.
2. SOCIAL RESPONSIBILITY
We are committed to our employees, society, and the environment. We take responsibility for implementing actions and best practices that positively impact the lives of everyone who works at Staria, as well as for reaffirming our commitment to our stakeholders to implement and improve our performance in the core areas of corporate social responsibility (CSR).
3. DISCRIMINATION
We respect the dignity, privacy, and personal rights of every employee and are committed to maintaining a workplace free from discrimination or harassment. Therefore, employees must not discriminate on the basis of origin, nationality, religion, race, gender, age, or sexual orientation, nor must they engage in any form of verbal or physical harassment based on the aforementioned factors or any other grounds. Employees who feel that their work environment does not comply with the principles that prevent or address discrimination and harassment may raise their concerns with the head of the Human Resources department.
4. SEXUAL HARASSMENT
Sexual harassment is sexual behavior or advances that are unwanted by the person receiving them and refers to “the exercise of power in a relationship where the victim is in a position of actual subordination to the perpetrator in the workplace and/or school setting. It manifests itself in verbal or physical conduct—or both—related to sexuality and having a lewd connotation.”
Sexual harassment can take many forms and result in a hostile work environment; “it is a form of violence with lewd connotations in which, although there is no subordinate relationship, there is an abusive exercise of power” that jeopardizes and seriously affects the victim’s dignity and can lead to job loss or even the loss of future employment opportunities. (NMX-R-025-2015). At Staria, we take responsibility for ensuring a commitment to preventing harassment and bullying.
5. WORKPLACE INCLUSION AND GENDER EQUITY
At Staria, we are committed to equity, always seeking equal opportunities for professional development and fulfillment, employee participation in the organization, as well as the enjoyment of rights and working conditions (compensation, safety, etc.) for both men and women.
6. CONFLICTS OF INTEREST
A conflict of interest arises when an employee’s personal interests or those of a third party take precedence over those of the company. Whenever possible, employees must avoid potential conflicts of interest. If such a conflict arises, or if an employee finds themselves in a situation that could involve or give rise to a conflict of interest, the employee must report it to their immediate supervisor, the head of the Human Resources department, or the Legal department, in order to resolve the situation fairly and transparently.
7. BUSINESS ACTIVITIES
We are committed to our customers and business operations, and therefore we will always act in full compliance with the laws applicable to our business activities, as well as with loyalty toward our suppliers and customers.
Employees, regardless of the area of the company to which they belong, will respect the territories and markets in which we are authorized to operate, with the aim of showing consideration for other distributors in the country and always seeking fair competition. All employees—but particularly those involved in marketing, sales, and purchasing, or those who are in frequent contact with competitors—must ensure that they are familiar with applicable competition laws. If in doubt, they should contact the head of the legal department to receive guidance and training on these laws.
8. CONFIDENTIAL INFORMATION
*Based on the Federal Law on the Protection of Personal Data Held by Private Parties
Staria recognizes the importance of sensitive information; therefore, employees must handle data—whether from customers, suppliers, or employees—in accordance with the Federal Law on the Protection of Personal Data Held by Private Parties, safeguarding information classified as confidential and preventing its misuse (destruction, concealment, or rendering it unusable).
Sensitive information is defined as confidential information that should not be in the public domain or that should not yet be made public:
Employees are strictly prohibited from disclosing such information to third parties, unless required by law or authorized by the company’s General Management. If an employee fails to safeguard confidential information, whether intentionally or unintentionally, they will be subject to disciplinary action, which will be determined by the CSR Committee based on the severity of the act and its impact on the organization.
The protection of confidential information is not limited to the organization itself but extends to all third parties with a relationship of interest to the company, such as business partners, suppliers, customers, etc.
9. PROTECTION OF COMPANY PROPERTY AND ASSETS
All employees are required to protect company property at all times against loss, damage, misuse, theft, fraud, embezzlement, and destruction. These obligations apply to both tangible and intangible assets, including trademarks, confidential or proprietary information, and computer systems.
Staria reserves the right to manage and audit the use of assets and material and IT resources (data, emails, etc.) within the corporate network.
COMPANY VEHICLES
Any vehicle owned by Staria must be used solely and exclusively for company business and under no circumstances for personal tasks or to transport individuals outside the company; therefore, any excuse for an employee to use Staria vehicles without a justification consistent with the company’s operational logic must be avoided.
10. FRAUD, BRIBERY, AND CORRUPTION
Employees must never engage in fraud or other dishonest conduct involving the property, assets, financial records, or accounting of the company or a third party.
Offering or providing improper benefits to influence the recipient’s decision may not only result in disciplinary action but also lead to criminal charges. Improper benefits may include anything of value to the recipient, including employment or consulting contracts for closely related parties.
FAVORS AND EXCHANGES WITH CUSTOMERS OR SUPPLIERS
Employees, either directly or through intermediaries, must never offer or promise an improper personal or financial favor—or any other type of favor—in order to obtain or secure business or an advantage from a third party, whether public or private. Employees must also not accept such an advantage in exchange for preferential treatment they provide to a third party.
In accordance with the above, employees exposed to a situation involving misconduct are required to consult the policy applicable to their area. In case of doubt, or if such a policy is not documented, employees must adhere to the most restrictive practice in order to avoid compromising or inappropriate situations, or consult their immediate supervisor or the Legal Department for guidance.
11. VALUES
These principles guide our day-to-day actions at Staria and complement this Code of Conduct. It is our responsibility to understand them so that we can live by them and make them a part of who we are.
12. FAIR HIRING
The fair hiring guidelines will apply in all cases and to all aspects of the employment relationship (compensation, professional development and growth, etc.).
TALENT SELECTION
All personnel joining the company are protected by the Federal Labor Law, as well as by internal guidelines. We will conduct recruitment and selection based on a policy of equal rights and opportunities for both women and men seeking employment.
FAMILY MEMBERS AND RELATIVES
The internal policy regarding the hiring of immediate family members and partners allows for their employment as employees, advisors, or consultants, provided that such an opportunity is based on evidence of knowledge and experience that qualifies the individual as competent to perform a specific task. We must ensure that there is no conflict of interest in such an employment relationship, whether direct or indirect; that is, under no circumstances may there be a direct relationship of authority or subordination in their daily work.
13. REPORTING / COMMUNICATING CONDUCT
We are responsible for ensuring that everyone in the organization acts with integrity in all situations. Therefore, employees must report to their immediate supervisors, the area manager, or the head of the Human Resources Department or the Legal Department any practice or action they believe to be inappropriate—or even illegal—under this code.
Due to the sensitive and confidential nature of certain issues (such as fraud, harassment, etc.), employees may file a report anonymously and confidentially through the appropriate hotlines, so that the Management Committee may follow up appropriately. It is Staria’s responsibility to ensure that such reports do not result in retaliation against the employee who made the report, as well as to protect and uphold the rights of the person accused.
14. VIOLATION OF THE CODE OF CONDUCT
The Human Resources Department is responsible for creating, maintaining, modifying, and communicating the code of conduct that all employees must follow.
It is each employee’s responsibility to ensure compliance with this Code of Conduct, the dress code, and the organization’s policies. If an employee is unsure how to proceed in a given situation, they should consult the relevant policies and codes to act in accordance with established guidelines. They may also seek assistance from their immediate supervisor, the head of the Human Resources Department, or the Legal Department.
If it becomes necessary to impose a sanction, “the organization is obligated to treat all staff with dignity and respect; when enforcing sanctions, the organization must not engage in or tolerate corporal punishment, mental or physical coercion, or verbal abuse. Harsh or inhumane treatment is not permitted.” (SA-8000 NORMA).
Employees who fail to comply with policies and the code of conduct will be subject to an administrative report, which—depending on the severity of the violation and in accordance with the CSR Committee’s determination upon review of each case—may result in one or more of the following:
a warning from the immediate supervisor or General Management; the possibility of termination of the employment contract; sanctions or legal action (if warranted by the case). Administrative reports must be signed by the employee as evidence of acknowledgment of the violation committed, as well as by the supervisor and the administrative representative from Human Resources. These must be filed, without exception, in the employees’ personnel files.
REPORTS: