Code of Conduct
About this Code
This Code of Conduct sets out how Whan Amador Prestige Group S.L. and everyone who works for it or on its behalf are expected to behave. It covers our property management and concierge service, property rentals and sales, Whan Amador Vineyards & Wines, Whan Amador Yacht Chartering, The Collection of Fine Art and The Eye experience audits, in Spain and in France.
Version 1.0. Approved by the Administrator. In force from 21 October 2026.
1. Our commitment
Our clients trust us with their homes, their keys, their cars, their privacy and, often, their money. That trust is the business. We keep it by acting lawfully, honestly and discreetly, by doing what we said we would do, and by telling clients plainly when something is wrong.
Where this Code sets a higher standard than the law, we follow this Code. Where the law sets a higher standard than this Code, we follow the law. Where Spanish and French law differ, we follow the stricter rule for the work in question.
2. Who this Code applies to
This Code applies to the company's administrators and founders, to employees, including seasonal and temporary staff, and to anyone who acts in our name: independent professionals, agents, introducers, drivers, housekeepers, crew we arrange and contractors working in clients' homes. Partners who act for us are told about this Code and are expected to work to it in anything they do on our behalf. Our separate Team & Partners statement explains how we engage them.
Prestige Group is founder-led: the founders handle every client relationship personally, and specialist work is done by registered subcontractors and independent partners on written terms. Every part of this Code that concerns employees applies in full to anyone the company employs.
3. How to use this Code
No code can list every situation. When you are unsure, ask yourself four questions. Is it legal? Is it what the client agreed to? Would I be comfortable if the client, or a newspaper, saw exactly what I did? Would I accept it if it were my own home, car or money?
If any answer is no, or you are not sure, stop and ask the Administrator before you act. Asking is never a mistake. Acting first and asking later sometimes is.
4. Who is responsible
The Administrator is responsible for this Code: for making sure people know it, for answering questions about it, for receiving concerns and for acting on breaches. Anyone who manages other people is expected to set the example, to make it easy to raise problems, and never to ask anyone to do something this Code forbids.
5. Confidentiality and discretion
Discretion is part of the service. We do not discuss clients, their homes, their guests, their movements, their purchases or their families with anyone who does not need to know, including friends, family, other clients and the press. We do not confirm or deny that a person is a client.
We never name a client, show a client's home, or share a photograph taken in a client's home or on a client's yacht, in marketing or on social media, without that client's written permission. This duty continues after a person stops working with us and after a client relationship ends.
Information about a property for sale, a work of art or a business we audit is shared only with people who need it for the job, and under a confidentiality agreement where the matter calls for one.
6. Keys, codes and clients' homes
Keys, alarm codes, gate codes, Wi-Fi details and access arrangements are held securely, labelled so that a lost key cannot be linked to an address, and released only to people the client has authorised for a specific job. Every handover of keys or codes is recorded. Codes are not written on keys, sent in group messages or kept in personal notes.
A client's home is entered only for the agreed service, at the agreed times, by the agreed people. We do not use a client's home, pool, garden, wine, food or belongings for ourselves, do not bring guests, and do not stay overnight unless the client has asked us to in writing. If we find a problem, such as a leak, a break-in or an open door, we make the home safe, record what we found with dated photographs, and tell the client the same day.
7. Clients' cars, boats and possessions
When we take a client's car to the ITV inspection station, to a garage or to the airport, we drive it only for that purpose and by the most direct sensible route, with the client's authorisation and valid insurance in place. We never use a client's car for personal errands. We note the mileage and condition at collection and return, and keep fuel, toll and parking receipts.
Quotes from garages and other suppliers are passed to the client unchanged. Work is approved by the client before it starts, except where it is needed urgently to prevent damage and the client cannot be reached, in which case we do only what is necessary and explain it promptly.
8. Personal data and information security
We handle personal data under the GDPR and Spanish and French data protection law, as set out in our Privacy Policy and Security Statement. We collect only what we need, use it only for the purpose we collected it for, keep it only as long as we need it, and never sell it.
Client files are kept on company systems, not on personal phones, personal email accounts or messaging groups. Identity documents, bank details and passwords are never requested or sent by WhatsApp or ordinary email; we arrange a secure route. Lost devices, misdirected messages and any suspected breach are reported to the Administrator at once, so that the company can meet its legal duty to notify the Spanish Data Protection Agency within 72 hours where that applies.
9. Honest dealing and honest marketing
Everything we say about a property, a wine, a yacht, a work of art or a service must be true and fair, and must not mislead by what it leaves out. Prices are given clearly, with taxes and fees explained. Illustrations, sample listings and example content are labelled as such.
We describe a grower or winery as a partner or producer only where that relationship really exists, and we describe wine we buy from other producers accurately. We never write, buy or arrange fake reviews or testimonials, never review our own services under another name, and never post invented endorsements. Photographs of homes and works of art may be professionally edited for light and colour but must not hide defects or change what the buyer or tenant will actually receive.
10. Conflicts of interest
A conflict of interest arises when a personal or family interest could influence, or could look as if it influences, the advice or service we give a client. Prestige Group is a family business, so we are open about family interests. For example, if we ever present a property in which the family has an interest, we say so.
Anyone working for us declares to the Administrator any interest in a property, business, supplier, artwork or deal we are involved in, and any family or close personal relationship with a client, buyer, seller or supplier. The client is told about any conflict that could matter to them before they commit. Where a conflict cannot be managed fairly, we step aside.
11. Referral fees and commissions
When we introduce a client to a lawyer, agent, notary, broker, producer, yacht owner or other supplier, and we receive a fee, commission or other benefit for that introduction, we tell the client before they commit. Our recommendations are based on the quality of the supplier for that client, never on the size of the fee. We do not accept undisclosed payments from suppliers on work we manage for a client, and we do not inflate supplier invoices.
12. Gifts, hospitality and bribery
We do not offer, promise, give, ask for or accept a bribe or any other improper advantage, directly or through anyone else, in any form: money, gifts, hospitality, favours, jobs for relatives, discounts or donations. This applies to public officials, such as town hall, registry, port, customs or tax staff, and equally to private individuals, such as a buyer's agent, a yacht captain or a restaurant manager. Bribery and private corruption are crimes in Spain and in France, and companies can be criminally liable for them.
Modest gifts and hospitality given or received as a normal courtesy, such as a bottle of wine at Christmas or a business lunch, are acceptable if they are occasional, proportionate and could not be seen as buying a decision. Cash and cash equivalents are never acceptable. Anything above a modest value, as a guide €150, or anything offered while a decision is pending, is declared to the Administrator, who decides whether it can be kept, returned or shared. We never make facilitation payments to speed up a licence, inspection, registration or customs clearance.
13. Anti-money laundering and client verification
We will not let our business be used to hide the proceeds of crime or to finance terrorism. Several of our activities are ones the law treats as high risk, which makes us an obliged entity under anti-money-laundering law when we carry them out.
In Spain, under Law 10/2010, this covers acting as agent or intermediary in the sale of property, at any price; acting as intermediary in a lease where the rent is €10,000 a month or more, or €120,000 a year or more; and trading professionally in works of art. In France, under the Monetary and Financial Code, it covers acting as agent in property sales, and in lettings where the monthly rent is €10,000 or more, and trading in works of art in transactions of €10,000 or more.
For this work we identify and verify our clients, and the people who ultimately own or control them, before the transaction goes ahead. We understand the purpose of the business and the source of the funds, apply enhanced checks where the risk is higher, such as for politically exposed persons or clients connected to high-risk countries, and keep the records for at least ten years, the Spanish period, which is longer than the French minimum of five.
Suspicions are reported, whatever the amount, to the national financial intelligence unit: SEPBLAC in Spain or TRACFIN in France. It is an offence to tell a client, or anyone else, that a report has been made or is being considered, so anyone with a concern tells only the Administrator.
We apply these checks whenever our work reaches these levels, including lettings of €10,000 a month or more if we take them on, from the first enquiry. We also apply them where the law may not strictly require it. Original works by Whan Amador sold through this website are treated as art sales under this section, so every buyer is verified before sale. If we ever advertise land or property owned by the Amador family, we say so openly, act as the owner's representative, and verify buyers in the same way. The notary who completes any property sale also carries out the checks the law gives notaries.
Signs that make us stop and ask questions include a buyer who will not say who they are acting for, unexplained urgency, payments from third parties or from countries unconnected to the client, requests to pay in cash, and requests to record a price different from the real one.
From 10 July 2027, the EU Anti-Money Laundering Regulation, (EU) 2024/1624, applies across the EU with common rules for property, art and other high-value goods. We will review this section before that date.
14. Cash and payments
The law limits cash payments to businesses. In Spain the limit is €1,000 when either party is acting as a business or professional, or €10,000 for a private individual whose tax residence is outside Spain (Law 7/2012, article 7), and breaking it can lead to a fine of 25% of the amount paid, for which payer and payee are both liable. In France the limit is €1,000 for residents. A private individual whose tax residence is abroad, paying a personal expense, may pay up to €15,000 to a business subject to anti-money-laundering rules, or €10,000 otherwise (Monetary and Financial Code, articles L112-6 and D112-3). From July 2027 an EU-wide ceiling of €10,000 will also apply, and the lower national limits stay in force.
Our own rule depends on the kind of transaction. For property sales and lettings, yacht charters and works of art, we accept no cash at all: payment is by bank transfer from an account in the name of the client, or of the verified company or trust acting for them. For our other services, such as property care, concierge and wine, we accept cash only up to the legal limit that applies to the client: €1,000, or for a private client whose tax residence is outside Spain or France and who is paying a personal expense, up to €10,000. For any cash payment above €1,000 we check and copy the client's identity document and issue a receipt.
We do not split a payment, or accept several linked payments, to stay under a limit. Payments are made to company bank accounts only, never to personal accounts, and we never change bank details on the strength of an email or message alone. Any request to change payment details is confirmed by telephone on a number we already hold, because invoice fraud often starts with a convincing email.
15. Sanctions
We do not deal with people, companies or vessels subject to European Union sanctions, and we do not help others to avoid sanctions. Before a property sale, a yacht charter, a significant wine export or the sale of a work of art, we check the parties against the EU sanctions lists, and we stop if there is a match until the position is clear.
16. Tax
We pay the taxes we owe in Spain and in France, including IVA, the special taxes on wine and corporate tax, and we keep accurate records to support them. We do not help clients or anyone else to evade tax. In particular, we never take part in recording a property price lower than the price actually paid, in taking part of a price or rent in undeclared cash, or in hiding rental income from a holiday let.
17. Property sales and rentals
Every home listed is visited by us, or by a vetted specialist acting for us, before it is advertised. Listings show the energy rating required by law and, for holiday lets in Andalusia, the tourist registration number. We do not advertise a holiday let that lacks the registration it needs. Known defects, legal issues and charges that a reasonable buyer or tenant would want to know about are disclosed.
Deposits and advance payments are held and returned as the contract says. Prospective tenants and buyers are treated equally whatever their origin, nationality, religion, sex, sexual orientation, disability or family situation; we refuse instructions from owners to discriminate. A seller's lowest acceptable price and a buyer's maximum budget are confidential and are never passed to the other side.
In France we follow the rules for estate agents set by the Loi Hoguet. If we present land or property owned by the Amador family, we act as the owner's representative. For any French property belonging to someone else, we work through a French agent who holds the required professional licence, or obtain the authorisation ourselves, before we act.
18. Wine
Our wines are made, labelled and described in line with the rules of their appellation and with European, French and Spanish labelling law. We never misstate a grape, vintage, origin, appellation or alcohol content. Wine is moved from France to Spain with the excise and transport documents the law requires, and duties are paid.
We do not sell or supply alcohol to anyone under 18 and do not aim our marketing at young people. Our wine pages are behind a legal-age check. We do not suggest that drinking improves health, performance, social or sexual success, and we follow France's strict rules on alcohol advertising, the Loi Évin, when promoting wine in France. Private-label and Grape to Table partnerships are described accurately and agreed in writing.
19. Yacht charter
We arrange charters only on yachts that hold the registration, commercial charter permissions, safety certification and insurance required for the waters concerned, with qualified crew. We never arrange unlicensed charters. The yacht owner's identity and terms are made clear to the client before booking. Guest safety comes before the itinerary: we follow the captain's decisions on weather and safety, and never ask a crew to take risks to satisfy a schedule. Guests and their activities on board are confidential.
20. Fine Art
Every work we offer is described accurately: artist, medium, size, date, edition, condition and provenance. Works are sold with a certificate of authenticity signed by the artist. Where the artist is connected to the company, as with works by Whan Amador, we say so. We do not inflate prices with invented sales or valuations, and the price paid is recorded truthfully. Sales are subject to the client verification described in section 13.
21. The Eye experience audits
Our auditors visit as ordinary guests, but they behave lawfully and fairly. They book, order and pay as any guest would. They never try to trick staff into breaking the law or their employer's rules, never make false complaints to provoke a reaction, never record people in a way the law does not allow, and never take or share images of other guests.
Reports describe roles and moments, not individual employees by name, wherever possible, and are written to help a business improve, not to embarrass people. Every engagement is covered by a written confidentiality agreement, and we never name an audited business or a client without permission. We do not audit a business where we have a conflict of interest, such as a competitor of a client we are already auditing, without telling both.
22. Fair competition
We compete on service, not on agreements with competitors. We do not agree prices, commissions, rental rates or territories with other agencies, concierge firms, charter brokers or wine distributors, and we do not exchange confidential pricing information with them. We do not make false statements about competitors.
23. Respect, equality and safety at work
Everyone who works with us is treated with dignity. We do not tolerate harassment, bullying, sexual harassment or discrimination, by or towards anyone, including clients and suppliers. Our commitments and the way complaints are handled are set out in Respect & Equality. Clients are told politely but clearly that our team is to be treated with the same respect we show them.
24. Vineyard work, subcontractors and staff
Vineyard and harvest work at our vineyard in France is carried out by specialist subcontractors. Under French law the business that hires a subcontractor has duties of its own, and can be held jointly liable for the subcontractor's unpaid wages, taxes and social charges if it fails them. So, for every subcontractor, agency or foreign service provider:
Before the contract is signed, and every six months while it runs, for any contract worth €5,000 or more, we obtain the subcontractor's URSSAF or MSA vigilance certificate, dated within the last six months, and check it online. Where the law requires, we also obtain the list of the subcontractor's foreign workers who need a work permit. For workers posted from another country, such as harvest teams from a Spanish agency, we check before each posting starts that the provider has filed the SIPSI posting declaration and named a representative in France, and we keep the acknowledgement on file. If the provider has not filed, we file the declaration ourselves within 48 hours, as the law requires.
Our contracts require subcontractors to declare and pay their workers lawfully, at no less than the French minimum wage and the applicable collective agreement, to respect working-time limits, to provide safety training and equipment, and to house workers lawfully. If we learn that a subcontractor is not paying its workers properly, we require it in writing to put it right and stop using it if it does not.
For anyone we employ directly, in France or in Spain: every hire is declared before work starts: in France through the DPAE or the TESA farm employment form with the MSA, and in Spain through registration with social security. Everyone has written terms and is paid the same as permanent staff doing equivalent work, never below the legal minimum or the collectively agreed rate, with overtime premiums paid in full. Before employing a non-EU national in France, we check their work authorisation with the préfecture at least two working days before they start, and keep proof of the check. Hours are recorded and kept within the legal limits, which in French agriculture are normally 10 hours a day and 48 hours in any week, with at least 11 hours' rest between working days and 35 hours' weekly rest. Practical safety training and protective equipment are provided from the first day.
Any collective accommodation we provide meets the standards of the French Rural Code and is declared to the authorities before it is used. We never keep workers' passports or identity documents, never charge workers any fee for finding them work, and do not use forced, bonded or child labour. We expect the same of every supplier.
25. Suppliers and partners
We choose suppliers for quality, reliability and price, and we pay them on time and as agreed. Suppliers who work in clients' homes, on clients' cars or on board yachts are briefed on confidentiality and on this Code. We do not accept personal benefits in return for choosing a supplier, as section 12 explains. If we learn that a supplier is acting unlawfully or unsafely, we stop using them. The full requirements are set out in our Supplier & Subcontractor Standards.
26. Health and safety
We assess the risks in our work, including driving, lifting, working alone in empty houses, working near pools and on boats, and vineyard work with machinery and treatments, and we provide the training and equipment needed. Nobody drives for work after drinking alcohol, including after a tasting, or while tired. Anyone who feels unsafe stops work and tells the Administrator, without any penalty.
27. Environment and the land
We look after our vineyard and the homes we manage. We follow the rules on the use and storage of vineyard treatments, avoid waste, report leaks and faults that waste water or energy, and dispose of waste lawfully. We do not make environmental claims about our wine or services that we cannot support.
28. Company assets, records and accounts
Company money, vehicles, equipment, information and time are used for company business. Expenses are claimed honestly, with receipts. Every record we keep, from a key log to an invoice or a property report, is accurate and complete, and is never altered after the event to hide a mistake. Records are kept for the periods required by law, and nothing relevant to a dispute, audit or investigation is destroyed.
29. Social media and public statements
Only the founders, or people they authorise, speak for the company to the press or post on its accounts. In personal posts, nobody reveals client information, shows a client's home or yacht, or suggests that they speak for the company. Mistakes made in public are corrected promptly.
30. Political activity
The company does not make political donations. People who work for us are free to take part in politics in their own name and time, but not in the company's name or using company resources.
31. Speaking up
If you see or suspect a breach of the law or of this Code, tell us. You can speak to the Administrator or use our confidential Report a Concern channel, which accepts anonymous reports and follows Spanish whistleblowing law. Reports are acknowledged within seven days and handled impartially. Nobody will suffer any retaliation for raising a concern in good faith, even if it turns out to be mistaken; retaliation itself is a serious breach of this Code.
32. Breaches
Breaches of this Code are taken seriously and investigated fairly, with the person concerned given the chance to respond. Depending on what happened, the outcome can include further training, disciplinary action in line with employment law and any applicable collective agreement, ending a contract with a partner or supplier, and reporting the matter to the authorities. Some breaches are also crimes for which individuals can be personally liable.
33. Review
The Administrator reviews this Code at least once a year, and whenever the law, our services or the size of the company change. Questions about this Code can be sent to info@prestigegroup.es or raised by telephone on +34 672 93 99 23.