Conduct Code

This Code is intended to establish the rules governing the activity of Chance and Choices, SL (hereinafter CHao or the Company), in order to prevent the loss of its independence, avoid conflict of interests and establish the professional competence policies, thus guaranteeing the objectivity and best professional practices of the work carried out.

The Code has been approved by the Sole Administrator of CHao on 01/01/2020 and any modification thereof must be approved by the same corporate body.

Article 1.- Objective scope

The Code provisions will be directly applicable to the Company’s activity, with the applicable particularities in each specific case.

Article 2.- Fundamental principles of conduct – Subjective scope

This Code is applicable to all individuals who work or collaborate with the Company, including each Administrator, Director, Employee or Consultant, who must adjust their activity to the principles of Independence, Integrity, Objectivity, Professional Competence and Confidentiality, which are presented in this Code as follows:


CHao does not accept that its Shareholders, Administrators, Employees or Consultants or the Shareholders, Administrators, Employees or Consultants of its clients or the recipients of their work, influence their professional activity in detriment of good practices.


CHao, its Administrators, Directors, Employees and Consultants who carry out activities for the Company are subject to strict compliance to the duties of professional secrecy in accordance with the law, specifically:

(a) They cannot disclose to third parties, other than their authorized clients, the information entrusted to them.

(b) They must ensure the security and confidentiality of the information entrusted to them. Confidentiality is applicable to both third parties and the client’s own staff. In this sense and where appropriate, the confidentiality policies established with the information’s broadcaster will be strictly adhered to.

(c) The information acquired as a result of their activity at the Company cannot be used for their own benefit. The Company does not tolerate any transgression of said obligations whose potential breach would give rise to civil, criminal and labour responsibilities established by law.

Additionally, the Company does not accept that any new Employee or Consultant provide confidential information from its previous employer or contractual relationship.

The Law and contractual loyalty require confidentiality of Company Employees or Consultants with respect to any internal, non-public Company information. The strictest confidentiality should be maintained in all aspects that are strategic and vital to obtain and / or maintain competitive advantages over same sector companies.


CHao is committed to proper statutory accounting, issuing transparent financial reports and auditing such.


CHao does not accept corruption and therefore, in any of its dealings it is totally forbidden to promise, offer, grant, receive, request or accept a benefit or advantage of any unjustified nature, to directly or indirectly favour the Company or a third party. The company will comply with the anti-corruption laws of the countries in which it carries out its activities.

It is forbidden to accept anything of personal benefit, with the exception of reasonable expenses directly related to achieving the company’s objectives. In general, if they are invitations to meals or similar, they can be accepted provided they represent a reasonable cost, are infrequent and, if possible, reciprocal.

All members of the Company and its independent collaborators, as well as their family members, live ins or associates of any kind, must prevent any activity or personal interest from creating a conflict between their interests and Company interests.

The Company believes in free competition. Therefore, any kind of illegal agreement between competitors or anti-competitive arrangements with suppliers and customers are prohibited.

Article 3.- Compliance with the fundamental principles of conduct

The Partners, Administrators, Directors, Employees and Consultants have the obligation to identify, evaluate and reject actions that affect compliance with the Fundamental Principles mentioned above. And in particular they should:

1. Act with honesty and transparency, in accordance with the highest ethical standards, so as to preserve and increase the trust of customers, the Administration and the general public, in the Company´s integrity, objectivity and independence. Therefore, all members of the Company and its Consultants must prevent any activity or personal interest, real or perceived, creating a conflict between self-interest and Company interest. All your activity must be driven by technical criteria, based on best professional practices and applicable law.

2. Have no relations with any individual whom is responsible for contracting work with or for the Company.

3. Refrain from intervening or influencing the decision-making process by third parties, especially in case the decision affects entities or individuals with a real or perceived conflict of interest.

4. Not request or accept, for himself or family members, from any person whom contracts the work with or for the Company, remuneration of any kind other than the fees previously agreed upon for the work performed. Without prejudice to commercial courtesy gifts and other tokens accepted by custom, provided they are given and accepted with the express or implied understanding that the person receiving them does not incur any obligation.

5. Do not accept indications, guidelines, instructions, recommendations, pressures or relevant information of any kind, especially from any individuals, customers, shareholders, influence groups or their managers or employees, in relation to Company activity in detriment of good professional practices. All the Company’s professional dealings are exclusively governed by technical criteria.

6. Maintain strict confidentiality and professional secrecy about all the information (self-developed or third-party) related to the commissioned work and share the information only with those Company personnel who need to know. Do not use the information received or developed for personal gain.

7. Do not perform work for which the Company or its employees lack adequate professional competence. At all times the Company’s work will be executed with the highest quality standards and subject to the most appropriate techniques and methodologies for each case.

8. Establish as a priority customer loyalty in all activities developed for them, with the objective of offering and providing efficient, effective, reliable, competitive and adequate solutions based on the client’s needs.

9. Maintain a commitment to equality and loyalty in the negotiation of Company business and mutual respect in relations with all of the Company’s suppliers.

10. Respect the dignity of the people who make up your organization, respecting the rights to equal opportunities and to be treated with dignity and respect. Additionally, Chao maintains labour policy compliance with occupational safety and health measures as essential element.
All individuals affected by this Code have the obligation to inform Chao’s corresponding corporate bodies with the conflicts of interest that may be created with any person, client or not, or other individuals whom are entrusted with Company responsibilities.

For this purpose, the following email address is available for individuals to voice their issues: info@

Article 4.- Code breach Consequences

Failure to comply with the provisions of this Code may result in the imposition of the following sanctions:

(a) In the case of an Employee, pursuant to Article 54 of the Workers’ Statute (Disciplinary Dismissal), it will be considered a violation of good contractual faith, as well as abuse of confidence in work performance.

(b) If the relationship with the non-compliant individual or entity is commercial, it will be considered cause for contract termination.

(c) If it is an Administrator, it will be considered cause for his removal.

Article 5.- Client relations

Client relations will be based on professionality and predicated on integrity, fairness and mutual respect, taking special care that the information provided to the client is clear, concrete, pertinent and sincere.

We do not tolerate unrealistic promises to clients regarding the quality and characteristics of the services provided, delivery times and prices.

Article 6.- Supplier relations

Supplier and consultant selection is based on objective criteria and will receive equitable treatment.

Consultants will receive fees and commissions for their consulting services in the ordinary course of business activities. Any fee paid will be accompanied by the corresponding documentation showing that the invoiced amount corresponds to the value of the services provided.

Code Dissemination.

This Code will be published on the Company’s website and personally communicated to all interested parties.


Antonio Perez Collar
Sole Administrator