DE CASTRO GROUP CODE

Working at DE CASTRO GROUP 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.

DE CASTRO GROUP has developed the DE CASTRO GROUP 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 DE CASTRO GROUP Code too.

The DE CASTRO GROUP 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
• Commitment to environmental responsibility
• Exercise common sense

The DE CASTRO GROUP Code is an integral part of DE CASTRO GROUP’s Compliance Program, which has been adopted to assist employees in better understanding DE CASTRO GROUP’s business behavior and complying with the legal, regulatory and ethical obligations of the company and its personnel. The program conveys DE CASTRO GROUP’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 a compliance or legal concern
• monitoring and auditing employee practices, and
• maintaining an organizational structure that supports the furtherance of the program.

DE CASTRO GROUP 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 DE CASTRO GROUP Code include:

• Seeking assistance or clarification of the DE CASTRO GROUP Code before taking any questionable action to avoid unethical or illegal business conduct
• Reporting any potentially improper, unethical or illegal behavior

Language proficiency shall not be a barrier for employees or Partners. As such, DE CASTRO GROUP will translate the DE CASTRO GROUP Code into the languages its employees speak and understand. DE CASTRO GROUP will provide employees and Partners with additional translations as it expands into new areas.

DE CASTRO GROUP/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 DE CASTRO GROUP Code and its requirements put themselves, their colleagues and DE CASTRO GROUP at risk, and may face (i) disciplinary action up to and including termination, and (ii) potential government prosecution. Violations of the DE CASTRO GROUP Code by third parties will be considered grounds for termination of the relationship and may result in referral for prosecution.

Enforcing the DE CASTRO GROUP Code is impossible without the participation and support of employees and Partners at all levels. DE CASTRO GROUP may be unaware of a serious breach of the DE CASTRO GROUP Code until an employee or Partner brings that matter to the attention of DE CASTRO GROUP leadership. DE CASTRO GROUP 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

DE CASTRO GROUP is committed to investigating potential violations of law and company policy and to implementing timely and appropriate remediation and process improvements as warranted.

DE CASTRO GROUP 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 DE CASTRO GROUP’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).

DE CASTRO GROUP is further committed to honoring contractual obligations. All business shall be conducted in a manner consistent with DE CASTRO GROUP’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, DE CASTRO GROUP offers training (both company-wide and role specific) to increase employee understanding of the DE CASTRO GROUP Code. Furthermore, DE CASTRO GROUP expects that services and products supplied by consultants, subcontractors, suppliers and other entities doing business with DE CASTRO GROUP meet our high level of integrity expectations.

Raise Industry Standards

As a member of LUSH, the Luxury Sustainable Hotels International Association, a nonprofit association dedicated to promoting sustainability and ethical conduct in the hospitality industry, DE CASTRO GROUP has joined other leading companies to identify and share best ethical and compliance practices within our industry.

In all our business ventures, DE CASTRO GROUP 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

DE CASTRO GROUP 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 DE CASTRO GROUP 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. DE CASTRO GROUP 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 DE CASTRO GROUP, 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

DE CASTRO GROUP 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, DE CASTRO GROUP 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, DE CASTRO GROUP 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 DE CASTRO GROUP to criminal sanctions and/or civil liability under national, state, local and foreign anti-bribery laws.

Environmental Responsibility

DE CASTRO GROUP 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. DE CASTRO GROUP goes beyond and is committed to sustainability.

Bribery

Bribery is illegal and DE CASTRO GROUP 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 DE CASTRO GROUP 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 DE CASTRO GROUP’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

DE CASTRO GROUP 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. DE CASTRO GROUP 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 DE CASTRO GROUP or its employees have become a party to.

DE CASTRO GROUP’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. DE CASTRO GROUP employees shall remain free of outside influences in the performance of workplace duties and responsibilities.

DE CASTRO GROUP facilities and company-owned equipment, including vehicles, phones, copiers, and computers, should be used for business purposes. The unauthorized removal of DE CASTRO GROUP property may be considered theft.

Employees may not use DE CASTRO GROUP 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:

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

If you’re unsure, contact your local Communications+Brand team member for advice

Third Parties

Under relevant Anti-Corruption Laws, DE CASTRO GROUP 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. DE CASTRO GROUP 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 DE CASTRO GROUP Code.

Selective with Consultants and Subcontractors

DE CASTRO GROUP 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 DE CASTRO GROUP.

As part of prequalification, our subcontractors confirm they understand the DE CASTRO GROUP Code, will comply with its requirements, and that they have no open, pending or closed litigation on any matters covered by the DE CASTRO GROUP Code. Our subcontractors reaffirm their compliance with the DE CASTRO GROUP Code each time they prequalify.

Our standard contract terms also require joint venture partners, third parties, subcontractors, consultants, and suppliers to comply with the DE CASTRO GROUP Code and all applicable laws and regulations, and we have the right to terminate those agreements upon breach of those terms. DE CASTRO GROUP’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 DE CASTRO GROUP a competitive advantage is considered intellectual property and is an asset as valuable as money, property, time or skill. As such, DE CASTRO GROUP’s intellectual property can only be used for authorized business purposes. All DE CASTRO GROUP employees are required to sign an intellectual property agreement and disclose any applicable personal intellectual property.

Employees must protect DE CASTRO GROUP’s proprietary and confidential information, which may include technical designs, strategy, software, employee records or information learned in a partnership or teaming arrangement.

DE CASTRO GROUP’s intellectual property, including data and information systems, customer lists, and other trade secrets, will remain with DE CASTRO GROUP when an employee leaves the company. 

Confidentiality Agreements

Many customers require DE CASTRO GROUP to sign confidentiality or nondisclosure agreements, either within our contracts or separately. DE CASTRO GROUP employees must comply with these agreements by not revealing protected information. And it’s important to communicate these requirements to the entire project team.