This code of ethics and professional conduct sets out the values, legal obligations and standards of behaviour that govern every aspect of Unique Villas Collection Ltd’s operations.

UNIQUE VILLAS COLLECTION LTD

Registered in England and Wales  ·  Company No. 15759075  ·  ICO Registration No. ZB823986

CODE OF ETHICS AND PROFESSIONAL CONDUCT

Effective date1 January 2026
Next review date1 January 2027
CompanyUnique Villas Collection Ltd
Company number15759075 (England and Wales)
ICO registrationZB823986
Governing lawLaws of England and Wales
Ethical frameworkUN Tourism Global Code of Ethics for Tourism (2001, as revised); UK Modern Slavery Act 2015; Equality Act 2010; UK Corporate Governance principles
Contactlegal@uniquevillascollection.com
NOTE ON LEGAL STATUS OF THIS DOCUMENT This Code of Ethics and Professional Conduct (‘the Code’) sets out the ethical framework and professional standards by which Unique Villas Collection Ltd conducts its business. It is a public statement of voluntary commitment and professional values. It does not, of itself, create legally enforceable obligations as between the Company and third parties beyond those already arising under applicable law and the Company’s contractual documents. Where the Code refers to specific legal obligations, those obligations derive from the relevant statute or regulation identified. The Code is reviewed annually and is published as part of the Company’s transparency and due diligence framework.

Part 1 — Founding Statement

1. Executive statement on ethics

Unique Villas Collection Ltd is a founder-led private office operating at the intersection of private estate management, bespoke travel, real estate advisory and luxury concierge services for ultra-high-net-worth individuals and family offices across the Mediterranean, Ibiza, St. Tropez, Monaco and the Caribbean.

The Company conducts its business on the basis that commercial success and ethical conduct are not competing objectives — they are inseparable. A private office trusted by principals at the highest level of wealth management cannot operate without the absolute confidence of those principals in its integrity, its discretion and the standards it applies to every party it engages.

This Code of Ethics and Professional Conduct sets out the framework of values, legal obligations and professional standards that govern every aspect of the Company’s operations — from the selection of properties and vessels to the conduct of staff, partners and sub-contractors; from the protection of principal data to the contribution the Company makes to the communities and natural environments of the destinations it serves.

The Company aligns its ethical framework with the principles of the UN Tourism Global Code of Ethics for Tourism (adopted by the UN General Assembly in 2001 and incorporated into the Framework Convention on Tourism Ethics in 2019) as a statement of professional values. This alignment is a voluntary commitment and does not constitute formal registration as a signatory to that instrument.

2. Scope and application

2.1  This Code applies to:

  • Unique Villas Collection Ltd and its founder in their conduct of all business activities;
  • all employees, consultants, agents and contractors engaged by the Company;
  • all Partners engaged to deliver services as part of a Principal’s programme, to the extent set out in their engagement terms;
  • all Owners who list Properties or Vessels with the Company, to the extent set out in their management or representation agreements.

2.2  Compliance with this Code is a condition of engagement for all Partners and a material term of all services agreements. Breach of any provision of this Code by a party engaged by the Company may result in immediate termination of that engagement.

2.3  This Code is reviewed annually by the founder and updated to reflect changes in applicable law, regulatory guidance and the Company’s business activities. The current version is always published at uniquevillascollection.com/ethics. The effective date appears at the top of this document.

Part 2 — The Nine Principles of Professional Conduct

The following principles constitute the Company’s ethical framework. Each principle is stated as a commitment and accompanied by its legal basis and the standard of enforceability the Company applies to it internally.

Principle 1  —  Mutual respect, cultural integrity and non-discrimination
Our Commitment The Company conducts all business relationships — with Principals, Owners, Partners, staff and the communities in which it operates — on the basis of mutual respect and equal dignity. The Company does not discriminate on the grounds of nationality, religion, culture, gender, age, disability or any other protected characteristic in the selection of properties, the delivery of services or the engagement of staff and partners.
The Company expects all Principals and members of their party to respect the social, cultural and legal norms of the destinations they visit, including the traditions of local and indigenous communities.		Legal basis & enforceability Legal basis: Equality Act 2010 (UK). The Company’s non-discrimination commitment is not merely a voluntary principle — it reflects statutory obligations under the Equality Act 2010 in respect of the Company’s employment practices and, where applicable, the provision of services. Breach of the Equality Act 2010 may give rise to claims before the Employment Tribunal or civil courts. The Company’s commitment to cultural respect in destinations abroad reflects the principles of Article 1 of the UN Tourism Global Code of Ethics for Tourism.
Principle 2  —  Human rights, dignity and zero tolerance of exploitation
Our Commitment The Company maintains an absolute and unconditional zero-tolerance policy regarding the exploitation of human beings in any form. This includes, without limitation, forced labour, child labour, trafficking in persons, sexual exploitation and any form of modern slavery.
The Company requires all Partners — including estate staff, yacht crew, aviation operators, private chefs, security personnel and ground transportation providers — to operate in accordance with applicable local and international human rights standards as a condition of engagement.		Legal basis & enforceability Legal basis: Modern Slavery Act 2015 (UK); Human Rights Act 1998 (UK); ILO Core Labour Standards. The Company is subject to the Modern Slavery Act 2015. Where the Company meets the annual turnover threshold requiring a transparency statement, it will publish a Modern Slavery and Human Trafficking Statement annually. Irrespective of turnover threshold, the Company voluntarily applies the Act’s due diligence standards to its supply chain. Any Partner found to be in breach of these standards will have their engagement terminated immediately and, where there is evidence of criminal conduct, the matter will be reported to the relevant authorities.
Principle 3  —  Environmental responsibility and sustainable operations
Our Commitment The Company is committed to minimising the environmental footprint of its operations and those of the Properties and Vessels it manages. This commitment includes: encouraging Owners to adopt energy-efficient and water-conservation measures in their estates; recommending carbon offset options to Principals planning aviation or superyacht programmes; refusing to represent Properties that operate in flagrant breach of local environmental regulations; and sourcing provisions and services locally where quality and safety permit.
The Company does not make representations as to the environmental credentials of any Property or Vessel unless those credentials have been verified by a recognised certification body.		Legal basis & enforceability Legal basis: UK Environment Act 2021; applicable EU and local environmental regulations in destination jurisdictions (including Greek Law 4685/2020 on environmental licensing); MARPOL Convention (for vessel operations). The Company’s environmental commitments are enforceable internally as conditions of the Asset Integrity Protocol and in the engagement terms of all Partners. Representations as to environmental certification are subject to the Misrepresentation Act 1967 — the Company will not make unverified environmental claims.
Principle 4  —  Preservation of cultural and archaeological heritage
Our Commitment The Company promotes responsible engagement with the cultural, archaeological and natural heritage of the destinations it serves. The Company will not facilitate, recommend or assist in activities that damage, disturb or unlawfully commercialise cultural monuments, protected sites, archaeological assets or areas of natural conservation significance.
Where experiential activities are offered in or near heritage sites, the Company ensures that all relevant permissions have been obtained and that the activity is conducted in compliance with applicable laws and in a manner respectful of the site’s significance.		Legal basis & enforceability Legal basis: UNESCO Convention on the Means of Prohibiting and Preventing the Illicit Import, Export and Transfer of Ownership of Cultural Property (1970); Greek Law 3028/2002 on the Protection of Antiquities and Cultural Heritage; French Monuments Historiques legislation; applicable heritage protection law in all operating jurisdictions. Facilitation of damage to or unlawful trade in cultural property may constitute a criminal offence in multiple jurisdictions.
Principle 5  —  Local community benefit and responsible economic contribution
Our Commitment The Company is committed to ensuring that the communities of its operating destinations derive fair and equitable benefit from the economic activity it generates. Where skills, quality and operational requirements are equal, the Company gives preference to local and regional suppliers, craftspeople, food producers and service professionals.
The Company does not engage in or facilitate pricing or commercial arrangements that are designed to extract economic value from local communities without commensurate contribution. The Company supports local charitable and community initiatives in its operating destinations where this is operationally appropriate.		Legal basis & enforceability Legal basis: This principle reflects the spirit of Article 5 of the UN Tourism Global Code of Ethics for Tourism and the principles of the UN Sustainable Development Goals (SDG 8 — Decent Work and Economic Growth; SDG 10 — Reduced Inequalities). It is not currently the subject of mandatory UK legislation but is increasingly reflected in ESG reporting frameworks. The Company applies it as a binding internal standard.
Principle 6  —  Transparency, honest dealing and professional integrity
Our Commitment The Company provides all Principals, Owners and Partners with accurate, complete and honest information regarding the properties and services it represents. The Company does not make exaggerated, false or misleading claims in respect of any Property, Vessel or service.
All commercial terms — including fees, commissions, payment schedules and cancellation provisions — are disclosed clearly and in writing before any commitment is made. The Company does not engage in hidden fees, undisclosed commissions or any commercial practice designed to obscure the true cost or nature of its services.		Legal basis & enforceability Legal basis: Consumer Rights Act 2015; Misrepresentation Act 1967; Consumer Protection from Unfair Trading Regulations 2008; Financial Services and Markets Act 2000 (where applicable). The Company’s disclosure obligations are not merely ethical — many are statutory. False or misleading representations as to the nature, quality or price of services may give rise to civil liability under the Misrepresentation Act 1967 and criminal liability under the Consumer Protection from Unfair Trading Regulations 2008. The Company’s commitment to fee transparency is reflected in its Terms and Conditions of Business Version 2.0.
Principle 7  —  Principal privacy, data protection and confidential conduct
Our Commitment The Company treats the privacy and confidentiality of all Principals as a foundational obligation. Principal identities, movements, family composition, financial arrangements and programme details are held in the strictest confidence and are never disclosed to any third party without the Principal’s prior written consent, except where required by law.
All personal data is processed in compliance with the UK General Data Protection Regulation (UK GDPR) and the Data Protection Act 2018. The Company’s ICO registration number is ZB823986. Full details of the Company’s data processing activities are set out in its Privacy Policy and Data Protection Policy.		Legal basis & enforceability Legal basis: UK General Data Protection Regulation (UK GDPR); Data Protection Act 2018; Human Rights Act 1998 (Article 8 — Right to Respect for Private Life). Data protection compliance is a statutory obligation. Breach of UK GDPR may result in enforcement action by the Information Commissioner’s Office (ICO), including fines of up to the higher of £17.5 million or 4% of global annual turnover under Article 83(5) UK GDPR. The Company’s privacy obligations are reflected in its Privacy Policy and Data Protection Policy, published at uniquevillascollection.com.
Principle 8  —  Anti-bribery, anti-corruption and financial integrity
Our Commitment The Company maintains an absolute prohibition on bribery, corruption and improper financial inducements in all its business dealings. No payment — whether in cash, in kind or by any other means — will be made to any person for the purpose of improperly influencing a business decision, securing preferential treatment or obtaining any commercial advantage.
The Company applies this standard to all Partners and requires compliance with applicable anti-bribery legislation as a condition of engagement. The Company reports any suspected bribery or corruption to the appropriate authorities without delay.		Legal basis & enforceability Legal basis: Bribery Act 2010 (UK). The Bribery Act 2010 creates criminal offences of bribing another person (section 1), being bribed (section 2), bribing a foreign public official (section 6), and — critically — the corporate offence of failing to prevent bribery (section 7). The section 7 offence applies to commercial organisations and carries an unlimited fine. The only defence is having adequate procedures in place to prevent bribery. This Code, together with the Company’s contractual requirements, forms part of those adequate procedures.
Principle 9  —  Anti-money laundering, financial crime prevention and compliance
Our Commitment The Company operates in full compliance with the United Kingdom’s anti-money laundering and counter-terrorist financing legislative framework. All Principals, Owners and parties to significant transactions are subject to Customer Due Diligence (CDD) and, where applicable, Enhanced Due Diligence (EDD) prior to the commencement of any business relationship.
The Company is registered with HMRC for AML supervision under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. The Company does not knowingly facilitate or participate in any transaction suspected of involving the proceeds of crime or the financing of terrorism.		Legal basis & enforceability Legal basis: Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017); Proceeds of Crime Act 2002 (POCA 2002); Terrorism Act 2000; Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018). Full details of the Company’s AML obligations, procedures and reporting framework are set out in the Company’s Anti-Money Laundering Policy, published at uniquevillascollection.com. Breach of AML legislation may constitute a serious criminal offence carrying substantial custodial sentences and unlimited fines.

Part 3 — Implementation, Governance and Enforcement

Clause 10 — Responsibility and accountability

10.1  The founder of Unique Villas Collection Ltd bears personal responsibility for the implementation of this Code and for ensuring that all persons acting on behalf of the Company are aware of its provisions and conduct themselves accordingly.

10.2  Any person engaged by the Company who becomes aware of conduct that may be in breach of this Code — whether by a member of staff, a Partner, an Owner or any other party — is expected to raise the matter promptly with the founder at legal@uniquevillascollection.com. Reports may be made in confidence. The Company will not retaliate against any person who raises a concern in good faith.

10.3  The Company will investigate all concerns raised under this Code promptly and impartially. Where a concern is substantiated, the Company will take appropriate action, which may include: termination of the relevant engagement; referral to the appropriate regulatory or law enforcement authority; and, where applicable, notification to affected Principals or Owners.

Clause 11 — Partner and supply chain standards

11.1  The Company requires all Partners engaged in the delivery of services to Principals to comply with the standards set out in this Code as a condition of engagement. Partner engagement terms incorporate by reference the obligations in Principles 1 through 9, adapted as appropriate to the Partner’s role.

11.2  The Company conducts due diligence on all Partners prior to engagement under its Asset Integrity Protocol. This due diligence includes: identity and business verification; AML screening; review of relevant licences and accreditations; and assessment of the Partner’s own ethical and environmental standards.

11.3  The Company reserves the right to terminate a Partner engagement immediately and without compensation where the Partner is found to be in breach of any provision of this Code, irrespective of whether the breach occurred in the context of the Company’s operations.

Clause 12 — Modern Slavery and Human Trafficking statement

12.1  Unique Villas Collection Ltd is committed to operating a business and supply chain free from modern slavery and human trafficking in all its forms. The Company recognises that the high-value hospitality and travel sector presents specific risks in this regard, particularly in relation to domestic and hospitality staff, maritime crew, and seasonal labour in destination countries.

12.2  The Company’s approach to mitigating these risks includes:

  • requiring all Partners who supply staff or crew to confirm compliance with applicable employment law and the ILO Core Labour Standards;
  • refusing to engage with any supplier where there are reasonable grounds to suspect the involvement of forced, trafficked or child labour;
  • training all persons acting on behalf of the Company to recognise indicators of modern slavery and to report concerns immediately;
  • cooperating fully with any investigation by law enforcement or regulatory authorities into suspected modern slavery in the Company’s supply chain.

12.3  Where the Company’s annual turnover meets or exceeds the threshold under section 54 of the Modern Slavery Act 2015 (currently £36 million), the Company will publish a Modern Slavery and Human Trafficking Transparency Statement annually on its website. Irrespective of turnover, the Company voluntarily applies the standards of section 54 to its operations.

Clause 13 — Bribery Act adequate procedures

13.1  In accordance with its obligations and the guidance of the Ministry of Justice under the Bribery Act 2010, the Company maintains the following procedures designed to prevent bribery:

  • a written prohibition on bribery and improper inducements applicable to all persons acting on behalf of the Company (set out in Principle 8 above);
  • proportionate due diligence on all Partners and associated persons prior to engagement;
  • clear reporting procedures for suspected bribery (Clause 10.2 above);
  • annual review of anti-bribery procedures as part of this Code’s review cycle;
  • a commitment by the founder to communicate these procedures clearly and to lead by example in their application.

13.2  The Company does not make facilitation payments of any kind. A facilitation payment — defined as a small, unofficial payment made to a public official to secure or expedite a routine government service — is a criminal offence under the Bribery Act 2010 and is prohibited absolutely by this Code.

Clause 14 — Dispute resolution and external oversight

14.1  The Company acknowledges the role of the World Committee on Tourism Ethics (WCTE) — the oversight body established under the UN Tourism Framework Convention on Tourism Ethics — as an international reference body for the interpretation of tourism ethics principles. The Company aligns its voluntary ethical commitments with the WCTE’s published guidance and will have regard to that guidance in the event of any ethics-related dispute concerning the Company’s conduct in connection with tourism services.

14.2  This acknowledgement does not constitute submission to the jurisdiction of the WCTE or any other international body for the purpose of binding dispute resolution. All binding dispute resolution is governed by English law and the exclusive jurisdiction of the courts of England and Wales, as set out in the Company’s Terms and Conditions of Business.

14.3  Principals, Owners or Partners who have a concern regarding the Company’s compliance with this Code are invited to raise that concern directly with the founder at legal@uniquevillascollection.com in the first instance. The Company commits to responding substantively within 14 working days.

Clause 15 — Annual review and publication

15.1  This Code is reviewed annually by the founder, with reference to:

  • any changes in applicable UK or international law relevant to the Company’s operations;
  • any material changes to the Company’s business activities or geographic footprint;
  • published guidance from the ICO, HMRC, the FCA (where applicable), UN Tourism, and relevant industry bodies;
  • any concerns or incidents arising during the preceding year that indicate a need to strengthen any provision of the Code.

15.2  The current version of this Code is published at uniquevillascollection.com/ethics. Previous versions are retained in the Company’s records. The Company will notify Principals, Owners and Partners of any material amendment to the Code within 30 days of publication.

CompanyUnique Villas Collection Ltd
Company number15759075 (England and Wales)
ICO registrationZB823986
Effective1 January 2025
Next review1 January 2026
Contactlegal@uniquevillascollection.com
Published atuniquevillascollection.com/ethics
A NOTE ON WHY THIS DOCUMENT EXISTS A Code of Ethics is not legally mandatory for a UK private company of this size. The Company publishes it for three reasons. First, it is the standard expected by family offices and institutional advisors who conduct due diligence on service providers before introducing their principals. Second, it gives the Company’s commercial commitments — on transparency, privacy, anti-bribery and AML — a coherent public articulation that supports legal enforceability. Third, it is the right way to operate a business that has privileged access to private estates, personal data, and the trust of some of the world’s most private families. The Company means every word of it.

UNIQUE VILLAS COLLECTION LTD  ·  CODE OF ETHICS AND PROFESSIONAL CONDUCT

Company No. 15759075  ·  ICO Reg. ZB823986  ·  Governed by English Law  ·  legal@uniquevillascollection.com