Version 1.0 | Effective Date: January 1, 2026

Code of Business Conduct

A Message from the Compliance & Audit Committee

To the Saporina Family and Network,

At Saporina, our name is our promise. While our reach is global, our commitment to quality is personal. This Code of Business Conduct is the foundation of our reputation. It outlines not just what we do, but how we ensure our products are made—with integrity, safety, and excellence—across our entire strategic manufacturing network.

This Code applies to every Saporina employee, officer, and extends to every facility authorized to manufacture our products.

1. Our People: The Heart of Saporina

1.1 Diversity, Equity, and Inclusion

Saporina thrives on unique perspectives.

Our Commitment

We foster a culture of respect. We strictly prohibit discrimination or harassment based on race, gender, religion, age, disability, sexual orientation, or any other protected characteristic. See our Commitment Against Harassment for full details.

Your Duty

Whether in our corporate offices or present at a manufacturing site, treat everyone with dignity.

1.2 Health, Safety, and Wellbeing

Safety is non-negotiable, both within our corporate environments and in the operational facilities where our products are created.

Our Commitment

We maintain strict safety protocols in our corporate operations. Furthermore, we only operate within a manufacturing network that adheres to international health and safety standards.

Your Duty

If you are managing production on-site and see a safety risk, you have the authority and duty to pause operations and report it immediately.

1.3 Human Rights

Our Commitment

Saporina has zero tolerance for forced labor, child labor, or human trafficking. This applies to our team and is a mandatory requirement for any facility integrated into the Saporina supply chain, as codified in the ETI Base Code.

2. Our Products: Uncompromising Standards

2.1 Quality and Process Control

We own the standard, the recipe, and the result.

Our Commitment

Saporina products must meet our rigorous specifications. We enforce strict adherence to food safety regulations (HACCP, IFS, BRC) through continuous quality assurance and process management.

Your Duty

  • For Supply Chain Teams: Ensure all raw materials and ingredients allocated for production meet Saporina's exact quality criteria.
  • For Operations Teams: Monitor strict adherence to our manufacturing protocols. If a batch does not meet Saporina standards, it does not leave the facility.

2.2 Product Integrity

Our Commitment

We ensure that what is on the label matches exactly what is in the package. We strictly control the Bill of Materials (BOM) and the processing methods used to create our final goods.

Your Duty

Rigorously verify that production utilizes only the specific raw materials and processes authorized by Saporina. Any unauthorized substitution in the manufacturing process must be reported as a serious compliance breach.

3. Our Business: Integrity in Action

3.1 Anti-Corruption and Ethical Operations

The Rule

We do not buy business, and we do not sell our integrity. Bribery, kickbacks, or "facilitation payments" are strictly prohibited in all dealings, including those with government officials, suppliers, and manufacturing entities. For detailed guidance, refer to our Anti-Bribery & Anti-Corruption Policy.

3.2 Conflicts of Interest

The Rule

Business decisions must be based on merit and Saporina's best interest.

Action

If you have a personal relationship with a supplier, a contracted manufacturer, or a logistics provider, you must disclose it to the Global Compliance Committee immediately.

3.3 Fair Competition

The Rule

We compete on the strength of our brand and the quality of our products. We do not collude with competitors to fix prices or divide markets.

4. Our Supply Chain: Responsible Operations

4.1 Manufacturing Excellence

Our product is only as good as the standards we enforce.

Our Commitment

We select manufacturing sites based on their technical capability, ethical standing, and ability to execute Saporina's strict production requirements.

Your Duty

Maintain rigorous process control. We do not "hand off" responsibility; we manage the manufacturing lifecycle from raw material to final product.

4.2 Environmental Responsibility

Our Commitment

We actively work to minimize the environmental footprint of our products. This includes optimizing the materials we utilize for production and selecting facilities that demonstrate a commitment to energy efficiency and waste reduction.

Your Duty

Champion sustainable practices in our supply chain. Encourage and monitor environmental performance across our manufacturing network.

5. Our Assets: Intellectual Property & Data

5.1 Protecting Saporina's Know-How

The Rule

Our recipes, material specifications, and processing techniques are Saporina's proprietary assets.

Your Duty

When sharing technical specifications for manufacturing, share only what is necessary for execution. Ensure Non-Disclosure Agreements (NDAs) are in place and respected.

5.2 Confidentiality

The Rule

Protect the privacy of our employees, consumers, and business strategies. See our Privacy Policy for data-specific obligations.

6. Compliance & Speaking Up

6.1 The Duty to Report

If you see something that compromises Saporina's quality, safety, or integrity—whether in our office or on the production floor—you must speak up.

Reporting Channels

Your Direct Manager

Start here for day-to-day quality or safety concerns.

Legal Department

For matters involving contracts, IP, regulatory, or legal risk.

Saporina Ethics & Compliance Channel

Anonymous and confidential. Available 24/7.
ethics@saporina.com | +1 (000) 000-0000

For full details on the reporting procedure, anonymity guarantees, and protections, see the Whistleblowing Policy.

6.2 Zero Retaliation

We support those who protect our reputation. Retaliation against anyone reporting a concern in good faith is grounds for immediate dismissal.

7. Contact

For questions about this Code, or to raise any concern related to ethics, compliance, or product integrity:

Global Compliance Committee

For policy interpretation, conflict-of-interest disclosures, and compliance guidance.
compliance@saporina.com

Ethics & Compliance Channel

Anonymous and confidential. Available 24/7.
ethics@saporina.com | +1 (000) 000-0000