Code of Conduct
Last update: May 2025
The Code of Conduct establishes a set of ethical principles, practices and rules that everyone at Endiprev should follow when performing their duties. All employees and service providers must respect them, and any violation will be met with appropriate disciplinary measures.
The Code of Conduct aims to ensure the best practices for professional and relational conduct, and proposes to:
- Specify the rules of conduct that all employees must abide by their relationships with co-workers and their dealings with all stakeholders.
- Ensure we have a good corporate image.
- Bolster our stakeholders’ trust in our principles and actions.
Violations of these principles, rules and conduct set forth in this Code of Conduct, Employee Manual or related policies and procedures, as well as other points that may not be addressed here and that have legal, moral or ethical character in the work context of Endiprev, should trigger the steps defined in the procedure of management of damages and divergent behaviors (END-PCD-0023). Endiprev encourages everyone to speak up, in good faith, whenever they observe such divergent behavior.
ETHICAL PRINCIPLES
The following ethical principles are especially important to us:
| Principle | Definition |
|---|---|
| Professionalism | Apply know-how and the most suitable techniques and make every effort to ensure you complete the tasks you are assigned. Strive to renew and build knowledge and competencies, to improve your professional skills. |
| Integrity | Act honestly, refraining from seeking out or accepting compensation, favors or benefits of any kind from third parties, for work performed while in the employ of the company, and refusing to intervene in situations in which there is, or could be, a conflict of interest. |
| Autonomy | Defend Endiprev’s interests impartially as regards third parties. |
| Good faith | Act confidently, appropriately, fairly and cooperatively with internal or external counterparts. |
| Non-discrimination | Don’t make distinctions based on race, gender, sexual orientation, belief, marital status, disability, political affiliation or opinion, ethnic or social background or nationality. |
| Responsibility | Act in accordance with the responsibility and autonomy you have been given. Protect and preserve Endiprev assets by using resources carefully and wisely. |
| Confidentiality | Keep information you are privy to during the performance of your duties confidential, which you are forbidden to use for personal or third-party gain. |
| Non-competition | Do not directly or indirectly take part in activities that compete with our business. |
| Loyalty | Uphold Endiprev’s reputation, credibility and prestige, as well as that of our brands in any given situation. |
| Legality | Always act in accordance with the law and applicable regulations, it is forbidden forced labor, slavery, child labor or harassment. All complaints should be addressed to the People Department of your Endiprev society, not leading to retaliation. |
APPLYING ETHICAL PRINCIPLES IN DEALINGS WITH STAKEHOLDERS
Below are some of the ethical principles to follow in dealings with stakeholders:
| Principle | Definition |
|---|---|
| Shareholders | Always act in such a way as to safeguard the interests of all shareholders, through equal treatment and without any discrimination of any kind. Ensure the accuracy and veracity of the information provided to share-holders and the market, in a timely manner. Keep information you become privy to during the performance of your duties confidential. |
| Employees | Establish friendly and respectful relationships with co-workers and Line Managers. Establish and maintain open and direct dialogue during conflict resolution, respecting differences of opinion. Foster a good working environment, always defending Endirpev’s interests. Treat all employees fairly, ensuring there is no discrimination of any kind. |
| Customers | Be professional when dealing with customers and treat them with respect, sincerity and loyalty, on equal footing and without any discrimination of any kind, namely when providing information and handling complaints. Offer customers products and services of excellence, always honoring commitments |
| Suppliers | Maintain a healthy partnership with suppliers based on professionalism and respect, always honoring commitments. Select suppliers based on objective criteria and without any discrimination of any kind but favor those who share similar ethical principles |
| Communities | Ensure that information provided on the environment is transparent. Adopt practices that foster non-discriminatory well-being |
| Competitors | Encourage and practice fair competition. Maintain cordial relations with institutions, based on mutual respect and honesty. |
| Public and regulatory entities | Cooperate with public and regulatory entities, responding to requests that are made and not behaving in any way that could prevent such authorities from performing their duties. Maintain a cordial relationship guided by principles of neutrality, impartiality, clarity and respect. |
ENDIPREV GOLD RULES
Endiprev provides services to its customers according to the 6 Golden Rules:
- Be punctual, conveying an image of rigor and professionalism.
- Daily delivery of work of excellence, complying with the client’s requirements and seeking improvement by indicating suggestions and acting proactively on suggestions and/or changes.
- Zero tolerance for unethical behavior.
- Healthy team spirit with added value for everyone.
- Encouraging clear, transparent and sharing communication.
- Culture of daily safety, taking care of all work equipment and compliance with procedures.
RESPECT THE HIERARCHY
Endiprev’s employees must adopt a behavior guided by respect for the Hierarchy, as a fundamental pillar for the processes to flow in a productive and efficient way. This is how the work is organized. It is important that all the employees understand the division of roles and responsibilities, and that the giving and receiving of orders occur without oppression and based on the professionalism of all involved.
COMMUNICATE RESPECTING THE HIERARCHY
The first and best way for employees to manifest themselves is with their Superior or their project manager. Part of the role as a supervisor is to listen to the employees, understand their doubts and concerns, and take appropriate measures.
In the event of a serious violation, employees can go directly to the People Manager. Regardless of how concerns are communicated, either anonymously, in person or through the JITA form, confidentiality will be guaranteed as far as possible. Limited disclosure will only occur for investigation purposes or in cases where it is legally required. All complaints will be investigated, and all investigations will be conducted independently, reflecting Endiprev’s values and respecting all parties involved, as well as the applicable legislation.
No retaliation
The adhesion to Endiprev’s values by the employees implies full agreement with this Code of Conduct.
Endiprev encourages all the employees to speak, in the sense of defending what is fair when something is wrong. In no case can any employee that presents a complaint be subject to retaliation. No action will be taken against an employee that denounces, in good faith, facts that prove to be inaccurate.
However, false or abusive accusations will not be tolerated and may result in disciplinary action under applicable law and may ultimately lead to dismissal.
Non-discrimination
Discrimination, which is unfair treatment of employees based on prejudice, will not be tolerated.
Endiprev promotes an inclusive workplace, with openness and respect, welcoming individual perspectives. Endiprev values and respects its employees for their diversity, for their visible and invisible differences, beliefs and convictions, experiences and social backgrounds, and for their unique ability to contribute to a thriving, sustainable and winning company.
Endiprev always tries to create a work environment that promotes equal opportunities, diversity and inclusion at all levels of employment. All employees should respect each other and contribute to the Group’s objectives, collectively and in collaboration with their colleagues, without a distinction of race, ethnic origin, religion, nationality, color, gender, sexual orientation, disability, age, political opinion, family status or any other nature.
CONFLICT OF INTEREST
Employees must avoid engaging in any situation that may give rise to a conflict of interest, either directly or indirectly, or that could reasonably lead a third party to presume its existence, even if such a situation does not actually occur. For the purposes of this Code of Conduct, a situation likely to give rise to a conflict of interest is understood to be any circumstance where the employee’s position involves professional, financial, familial, political, or personal interests that could interfere with their critical judgment in fulfilling their duties within the organization and where there could reasonably be serious doubt about the impartiality of their conduct or decision.
For the purposes of the preceding paragraph, a conflict of interest is deemed to exist, including but not limited to when:
Any employee who finds themselves in an actual or potential conflict of interest, as defined in the preceding paragraphs, must immediately take the necessary steps to avoid, resolve, or terminate the conflict, and report such conflict, as soon as possible, to their direct superior.
OUTSIDE POSITION
Although Endiprev respects our personal and private affairs and activities, we should never participate in activities that compete with Endiprev, even outside of working hours.
INTIMATE OR FAMILY RELATIONSHIPS OUTSIDE THE COMPANY
Doing business on behalf of Endiprev with family members, whether the family member is an actual or potential client, competitor or supplier, may give rise to a conflict of interest, so the fact must be immediately disclosed. Likewise, we must ensure that the friendships we maintain outside of Endiprev do not affect our ability to act in the best interests of Endiprev, in accordance with Section 2.5 above.
INTIMATE OR FAMILY RELATIONSHIPS INSIDE THE COMPANY
Intimate or family relationships between co-workers can also create actual or potential conflicts of interest. To prevent these problems, we should avoid a hierarchical relationship with a member of our family or a person with whom we have a loving relationship. However, if the situation arises, it should be communicated to People and Endiprev will do its best to manage with independency this actual or potential conflict of interest situation.
OFFERS WHEN DEALING WITH EXTERNAL ENTITIES
Employees must refrain from accepting offers, in any form, from private individuals or entities, whether domestic or foreign, and from foreign public entities, of material goods, consumables, or durable goods, or services that may compromise the impartiality and integrity of the performance of their duties.
For the purposes of this Code, it is understood that there is a compromise of impartiality and integrity in the performance of duties when goods with an estimated value equal to or greater than €150.00 are accepted.
Any offers that constitute or may be interpreted, by their refusal, as a breach of respect, particularly in the context of professional courtesy inherent in Endiprev’s commercial relationships, should be accepted, without prejudice to the duty of reporting and communicating to the respective hierarchical superior.
MEDIA
Only members of Management or an employee expressly authorized by Management may communicate with the media.
HUMAN RIGHTS
Endiprev is committed to respect and support human rights to its employees, the communities where it operates and its business partners, as stipulated in internationally recognized principles such as the United Nations Universal Declaration of Human Rights and the United Nations Guiding Principles for Business and Human Rights. Endiprev does not employ any person against their will, nor does it deprive them of their rights.
Endiprev expressly condemns any form of exploitation of children and respects the minimum legal age requirements as defined in the International Labor Organization (ILO) conventions and the laws of the countries where we operate and/or are present.
We always try to ensure that working hours and remuneration comply with legislation, which are fair and equitable. Endiprev takes seriously any indication that human rights are not properly safeguarded in our sphere of influence. We must understand the human rights issues that may arise in Endiprev’s workplaces and prevent any violation of these rights.
WORKPLACE CONDUCT
Endiprev works to maintain a positive work environment. Each employee plays a role in promoting this environment. Consequently, we all must respect certain rules of conduct, based on honesty, common sense, and fair play.
Since not everyone may have the same idea about proper conduct in the workplace, it is helpful to adopt and enforce rules that everyone can follow.
The following are examples of some, but not all, conduct that may be considered unacceptable:
- Obtaining employment based on false or misleading information.
- Stealing, removing or defacing Endiprev property or the property of a co-worker.
- Disclosure of confidential information.
- Completing another employee’s time records, without the express authorization of the superior
- Violation of security rules and policies.
- Violation of Endiprev’s drug-free and alcohol-free workplace principles.
- Fighting, threatening, or disrupting the work of others.
- Failure to comply with the instructions of a supervisor.
- Failure to perform assigned duties.
- Violation of Endiprev principles relating to Punctuality and Attendance, including but not limited
to habitual tardiness, or unexcused absences. - Gambling and gaming within Company property.
- Waste of work materials.
- Performance of personal work during working hours.
- Misuse of the means of payment, such as credit cards, that Endiprev makes available to the worker.
- Violation of Endiprev’s Harassment or Equal Employment Opportunity principles.
- Violation of the Policy on the Use of Mobile Resources and Devices (END-CPD-0009).
- Violation of Endiprev’s Internal Privacy Policy (END-CPD-0008).
- Unsatisfactory job performance.
- Any other violation of Endiprev’s policy.
Obviously, not every type of misconduct can be listed.
CORRUPTION AND RELATED OFFENSES (ONLY FOR PORTUGAL)
Endiprev condemns any practice of corruption or related offenses, enforcing strict compliance with the law in all its internal and external relations, whether with private entities or public entities.
Under the General Regime for the Prevention of Corruption, approved by Decree-Law Nr. 109-E/2021, of December 9, corruption and related offenses are understood to include crimes of corruption, corruption with harm to international trade, corruption in the private sector, improper receipt and offering of advantages, embezzlement, misuse of public funds, economic participation in a business, extortion, abuse of power, misconduct, influence peddling, money laundering, or fraud in obtaining or diverting subsidies, grants, or credits, as provided in the Penal Code, Law Nr. 34/87, of July 16, Law Nr. 20/2008, of April 21, and Decree-Law No. 28/84, of January 20, as well as disciplinary offenses in the private sector as provided in Article 128 of the Labor Code
For the purposes of this Code of Conduct, and under the previous paragraph, the concepts of corruption and related offenses and their respective framework are as follows:
- Crimes provided for in the Penal Code (Decree-Law Nr. 48/95 of 15 March)
| LEGAL TYPE | CONDUCT | REGULATORY FRAMEWORK |
|---|---|---|
| Corruption | Practice of any act or omission, whether in both cases lawful or illicit, in exchange for the receipt of an undue patrimonial or non-patrimonial advantage, for oneself or for a third party. | Articles 372 to 374a of the Criminal Code |
| Improper receipt or offer of advantage | When the official, in the exercise of his duties or because of them, by himself, or through an intermediary, with his consent or ratification, requests or accepts, for himself or for a third party, a patrimonial or non-patrimonial advantage, which is not due to him. | Article 372(1) of the Criminal Code |
| Embezzlement | When the official illegitimately appropriates for his own benefit or that of another person, money or any movable thing, public or private, which has been given to him, is in his possession or is accessible to him by reason of his duties. | Article 375(1) of the Criminal Code |
| Embezzlement of use | When the employee uses or allows another person to make use of immovable property, vehicle, or other movable object or animal of appreciable value, public or private, which has been delivered to him, is in his possession or is accessible to him because of his duties. | Article 376 of the Penal code |
| Economic participation in business | When an official who, with the intention of obtaining, for himself or for a third party, unlawful economic participation, harms in a legal transaction the patrimonial interests that, in whole or in part, he is responsible for, by virtue of his function, to administer, supervise, defend or carry out. | Article 377(1) of the Criminal Code |
| Concussion | Where an official, in the exercise of his duties or of the de facto powers deriving therefrom, by himself or through an intermediary with his consent or ratification, receives, for himself, for the State or for a third party, by inducing error or taking advantage of the victim’s error, a financial advantage which is not due to him, that is, greater than that due, namely contribution, fee, emolument, fine or fine. | Article 379 of the Criminal Code |
| Abuse of power | When the official abuses powers or violates duties inherent to his duties, with the intention of obtaining, for himself or for a third party, an illegitimate benefit or causing damage to another person. | Article 382 of the Criminal Code |
| Influence Peddling | When someone by themselves or through an intermediary, with their consent or ratification, requests or accepts, for themselves or for a third party, a patrimonial or non-patrimonial advantage, or their promise, to abuse their influence, real or supposed, with any public entity. | Article 335 of the Criminal Code |
| Bleaching | When the official converts, transfers, assists or facilitates any operation of conversion or transfer of advantages, obtained by him or by a third party, directly or indirectly, with the purpose of concealing its illicit origin, or to prevent the perpetrator or participant of such offenses from being criminally prosecuted or subjected to a criminal reaction. | Article 368 a of the Criminal Code |
- Crimes provided for in Law Nr. 34/87 of 16 July (crimes under the responsibility of holders of political office)
| LEGAL TYPE | CONDUCT | REGULATORY FRAMEWORK |
|---|---|---|
| Corruption | When the holder of a political office, by himself or through an intermediary, with his consent or ratification, requests or accepts, for himself or for a third party, a patrimonial or non-patrimonial advantage, which is not due to him, in return for taking a decision contrary to the duties of the office, within the scope of his functions. | Article 17 of Law Nr. 34/87 of 16 July |
| Improper receipt or offer of advantage | When the holder of a political office, in the exercise of his functions or because of them, by himself or through an intermediary, with his consent or ratification, requests or accepts, for himself or for a third party, a patrimonial or non-patrimonial advantage, which is not due to him. | Article 16 of Law Nr. 34/87 of 16 July |
| Embezzlement | When the holder of a political office, in the exercise of his functions illegitimately appropriates for his own benefit or that of another person, money or any movable thing, public or private, which has been delivered to him, is in his possession or is accessible to him by reason of his functions. | Article 20 of Law Nr. 34/87 of 16 July |
| Embezzlement of use | When the holder of the political office uses or allows another person to make use of immovable property, vehicle, or other movable thing or animal of appreciable value, public or private, which has been delivered to him, is in his possession or is accessible to him by reason of his functions. | Article 21 of Law Nr. 34/87 of 16 July |
| Embezzlement due to another’s mistake | When the holder of a political office, in the exercise of his functions, but taking advantage of the circumstantial error of another, receives for himself or for a third-party fees, emoluments or other amounts not due or of an amount higher than that due | Article 22 of Law Nr. 34/87 of 16 July |
| Economic participation in business | When the holder of a political office who, with the intention of obtaining, for himself or for a third party, an illicit economic participation, harms in a legal transaction the patrimonial interests that, in whole or in part, he is responsible for, by virtue of his functions, to administer, supervise, defend or carry out, as well as when the holder of a political office receives a patrimonial advantage by entering into an act relating to interests over which, by virtue of his position, he has at that moment the powers of disposition, administration or supervision, even if he does not harm them. | Article 23 of Law Nr. 34/87 of 16 July |
| Abuse of power | When the holder of a political office abuses powers or violates duties inherent to his functions, with the intention of obtaining, for himself or for a third party, an illegitimate benefit or causing damage to another person. | Article 26 of Law Nr. 34/87 of 16 July |
| Malfeasance | When the holder of political office, in the exercise of his functions, intervenes in a process in which he makes unlawful decisions with the intention of harming or benefiting someone. | Article 11 of Law Nr. 34/87 of 16 July |
| Violation of secrecy | When the holder of a political office reveals a secret of which he or she has been aware or entrusted to him by virtue of his or her duties, with the intention of obtaining an undue benefit for himself or a third party or to cause damage to a public interest or that of a third party. | Article 27 of Law Nr. 34/87 of 16 July |
- Crimes provided for in Law Nr. 20/2008 of 21 April (criminal regime of corruption in international trade and the private sector)
| LEGAL TYPE | CONDUCT | REGULATORY FRAMEWORK |
|---|---|---|
| Corruption to the detriment of international trade | Practice of any act or omission thereof, directly or indirectly, in order to give or promise to an official, national, foreign or international organization, or to a holder of a political office, national or foreign, or to a third party with knowledge of them, an undue patrimonial or non-patrimonial advantage, with a view to obtaining or preserving business, contract or other undue advantage in international trade. | Article 7 of Law Nr. 20/2008 of 21 April |
| Corruption in the private sector | Practice of any act or omission, directly or indirectly, in the sense of soliciting or accepting, for oneself or for a third party, an advantage or promise of undue patrimonial or non-patrimonial advantage, in exchange for any act or omission that constitutes a violation of one’s functional duties. | Article 8 of Law Nr. 20/2008 of 21 April |
- Crimes provided for in Decree-Law Nr. 28/84 of 20 January (anti-economic and public health offences)
| LEGAL TYPE | CONDUCT | REGULATORY FRAMEWORK |
|---|---|---|
| Fraud in obtaining a subsidy or subsidy | Where the official provides the competent authorities or entities with incorrect or incomplete information about himself or a third-party concerning fact relevant to the award of a subsidy or subsidy; omitting information about important facts; use a supporting document obtained through inaccurate or incomplete information; to obtain a subsidy or subsidy. | Article 36 of DecreeLaw 28/84 of 20 January |
| Procurement fraud credit | When the employee submits a proposal for granting, maintaining or modifying credit conditions, containing: (a) inaccurate or incomplete written information intended to give you credit or relevant to the decision on the credit application. b) Documentation, relating to the economic situation, inaccurate or incomplete, namely balance sheets, profit and loss accounts, general descriptions of assets or expert opinions. c) The concealment of deteriorations in the economic situation that have occurred in the meantime in relation to the situation described at the time of the credit application and that are important for the decision on it. | Article 38 of DecreeLaw 28/84 of 20 January |
| Deviation of subsidy, subsidy or subsidized credit | When the official uses benefits obtained by way of subsidy or subsidy, a benefit obtained by way of subsidized credit, for purposes other than those for which they are legally intended. | Article 37 of DecreeLaw 28/84 of 20 January |
For the purposes of this Code of Conduct, and under the previous paragraph, the concepts of corruption and related offenses and their respective framework are as follows:
For the purposes of criminal provisions relating to crimes committed by employees, under Article 386 of the Penal Code, employees include:
a. Civil and military public employees.
b. Those holding a public office by special appointment.
c. Those temporarily or permanently engaged in public administration functions or in any other public authority position, including voluntary roles.
d. Judges of the Constitutional Court, judges of the Court of Auditors, judicial magistrates, public prosecutors, the Attorney General of the Republic, the Ombudsman, members of the Superior Council of the Judiciary, members of the Superior Council of Administrative and Fiscal Courts, and members of the Superior Council of the Public Ministry.
e. Arbitrators, jurors, experts, technicians who assist the court in judicial inspections, translators, interpreters, and mediators.
f. Notary.
g. Those who, even temporarily or provisionally, with or without remuneration, voluntarily or obligatorily, perform or participate in performing a public administrative function or exercise authority in a public utility organization, including private social solidarity institutions.
h. Those who perform or participate in performing public functions in public associations.
i. Members of management or administration bodies, or supervisory bodies, and employees of public, nationalized companies, companies with public capital or majority public participation, as well as companies’ concessionaires of public services.
j. Those designated by the State or another public entity for management or administration positions in companies with equal or minority public capital participation.
k. Magistrates, employees, agents, and equivalents from public international law organizations, regardless of nationality and residence.
l. National employees of other states.
m. All those who perform functions like those described in item 1 within any public international law organization of which Portugal is a member.
n. Magistrates and employees of international courts provided Portugal has declared to accept the jurisdiction of these courts.
o. All those who perform functions in the context of extrajudicial conflict resolution procedures, regardless of nationality and residence.
p. National jurors and arbitrators from other states.
In accordance with and for the purposes of the provisions of Law Nr. 34/87 of July 16 (crimes of responsibility of holders of political offices), it is specified that, under Article 3 of the same law, the following are considered political offices:
a. The President of the Republic.
b. The President of the Assembly of the Republic.
c. Member of the Assembly of the Republic.
d. A member of the Government.
e. Member of European Parliament.
f. The Representative of the Republic in the autonomous regions.
g. A member of the governing body of an autonomous region.
h. A member of the representative body of a local authority; and
i. Holders of political offices in public international law organizations, as well as holders of political offices in other states, regardless of nationality and residence, when the offense has been committed, wholly or partially, on Portuguese territory.
Without prejudice to criminal liability as specified in the previous paragraphs, the following actions, as set out in Article 128, paragraph 1, of the Labor Code, constitute duties of the employee, and failure to comply with them may trigger disciplinary liability under the terms of Article 328 of the Labor Code:
a. To respect and treat the employer, superiors, coworkers, and individuals interacting with the company with civility and integrity.
b. To attend work with regularity and punctuality.
c. To perform the work with care and diligence.
d. To participate diligently in professional training actions provided by the employer.
e. To comply with the orders and instructions of the employer regarding the execution or discipline of the work, as well as safety and health at work, provided they do not contradict their rights or guarantees.
f. To remain loyal to the employer, particularly by not negotiating on their own or others’ behalf in competition with the employer, nor by disclosing information related to the organization, production methods, or business.
g. To ensure the preservation and proper use of work-related goods entrusted to them by the employer.
h. To promote or carry out actions aimed at improving the productivity of the company.
i. To cooperate in improving safety and health at work, particularly through the worker representatives elected for this purpose.
j. To comply with safety and health regulations at work as required by law or collective bargaining agreements
In accordance with the provisions of Article 128, paragraph 2, of the Labor Code, it is clarified that the duty of obedience in the workplace pertains both to orders or instructions from the employer as well as from the worker’s superior, within the powers assigned to them by the employer.
The reporting of conduct that may constitute the commission of corrupt crimes or related offenses, as outlined in the previous paragraphs, within Endiprev or through it, must be made through the internal whistleblowing channel, in accordance with the provisions of the Whistleblowing Channel Regulations.
REPORTING OF OFENSES
Endiprev employees must report any facts, of which they have knowledge or reasonable suspicion, that may constitute a violation of the rules established in this Code of Conduct, to prevent or stop any unethical practice or actions contrary to the law.
The reporting of violations should be done through the internal reporting channel, in accordance with the provisions of the Whistleblowing Channel Regulation.
DRUG AND ALCHOOL-FREE ENVIRONMENT
To help ensure a safe, healthy, and productive work environment for our employees and others, to protect Endiprev property, and to ensure efficient operations, Endiprev has adopted a policy of maintaining a workplace free of drugs and alcohol. This policy applies to all employees and other individuals who perform the work for the Endiprev.
The unlawful or unauthorized use, abuse, solicitation, theft, possession, transfer, purchase, sale, or distribution of controlled substances (including medical marijuana), drug paraphernalia or alcohol by an individual anywhere on Endiprev premises, while on Endiprev business (whether on Endiprev premises) or while representing the Endiprev, is strictly prohibited. Employees and other individuals who work for the Endiprev also are prohibited from reporting to work or working while they are using or under the influence of alcohol or any controlled substances, which may impact the employee’s ability to perform their job or otherwise pose safety concerns, except when the use is pursuant to a doctor’s instructions and the doctor authorized the employee or individual to report to work. However, this exception does not extend to reporting to work under the influence of medical marijuana or to use medical marijuana as a defense to a positive drug test, to the extent the employee is subject to any drug testing requirement, except as permitted by and in accordance with applicable law. Violation of this policy will result in disciplinary action, up to and including discharge.
Endiprev maintains a policy of non-discrimination and will endeavor to make reasonable accommodations to assist individuals recovering from substance and alcohol dependencies, and those who have a medical history which reflects treatment for substance abuse conditions. However, employees may not request accommodation to avoid discipline for a policy violation.
Prevention and detection of excessive consumption of alcohol and other substances in the workplace
The use/abuse of psychoactive substances such as alcohol and other drugs is not a particular aspect of a working reality, but rather a social phenomenon with a scope that transcends the local, with numerous implications and changes such as, for example, the emergence of new drugs, new patterns of alcohol consumption, the increase in poly-consumption, among others. It is, therefore, a reality that cannot be ignored and in which the consequences are felt with acuity and concern in the field of work.
Endiprev’s policy is based on the following guiding principles:
- Prevention, through awareness/information actions, aiming to alert to the harmful consequences of the use/abuse of substances that cause physical and psychological dependence.
- Detection, through the application of the regulation for the prevention and detection of the excessive consumption of alcohol and other substances in the workplace with the aim of referring cases.
- Treatment, enabling the support and follow-up of detected cases with the purpose of recovery, relapsing prevention and consequent reintegration into the labor market.
The tests are carried out under the responsibility of the occupational health service or the Occupational Health and Safety Department of Endiprev, under its direction and control, by other health professionals bound by professional confidentiality and trained in the use of the equipment.
HARASSMENT-FREE ENVIRONMENT
Endiprev employees must not engage in discriminatory behavior towards other employees or third parties, whether they are recipients of Endiprev’s services and activities, particularly based on ethnicity, gender, age, physical disability, sexual orientation, ancestry, language, beliefs, political affiliations, religion, social condition, or economic situation.
Employees should demonstrate mutual consideration and respect, avoiding behaviors that may reasonably be considered harassment by other employees or third parties
Harassment is a form of undesirable and/or unacceptable behavior by one or more individuals. The following behaviors are expressly prohibited as they may be considered harassment in the workplace:
a. Systematically devaluing and disqualifying the work performed.
b. Promoting social isolation.
c. Ridiculing, either directly or indirectly, a physical or psychological characteristic.
d. Making repeated threats of dismissal or applying another disciplinary sanction.
e. Failing to assign any professional duties, which constitutes a violation of the right to effectively occupy the job position.
f. Systematically setting unattainable work goals or unrealistic deadlines.
g. Assigning duties unrelated to the professional category.
h. Systematically appropriating ideas, proposals, projects, and works without identifying the author, except as permitted by the Copyright and Related Rights Code and the Industrial Property Code.
i. Consistently spreading rumors, malicious comments, or repeated criticism of employees.
j. Giving consistently unclear and imprecise work instructions.
k. Repeatedly requesting urgent tasks without necessity.
l. Transferring the employee to a different sector or workplace with the clear intention of promoting isolation.
m. Constantly speaking at high volumes (i.e., shouting) in a way that intimidates others.
n. Systematically creating objective situations of “stress” to provoke the loss of control in the employee’s behavior, such as constant changes or transfers of work locations.
Whenever Endiprev becomes aware of a violation of the provisions in this Code of Conduct regarding prohibited behaviors that may constitute harassment or discrimination, it will initiate a disciplinary procedure. This must begin within 60 (sixty) days from the date the employer or the authorized disciplinary supervisor becomes aware of the violation.
Endiprev employees must cooperate as necessary in any disciplinary or criminal investigation procedures by the competent authorities.
The possibility of the additional sanction of publicizing the condemning decision cannot be waived when harassment is involved and constitutes a very serious offense that may lead to criminal responsibility.
Endiprev is responsible for compensating for damages resulting from occupational diseases caused by harassment, and may, with respect to compensation already paid, be subrogated to the employee’s rights.
The reporting of behaviors that may constitute harassment or discrimination by Endiprev employees must be made through the internal reporting channel, as set out in the Whistleblowing Channel Regulation.
PUNCTUALITY AND ATTENDANCE
Employees are hired to perform important functions at Endiprev. As with any group effort, operating effectively takes cooperation and commitment from everyone. Therefore, attendance and punctuality are very important. Unnecessary absences and lateness are expensive, disruptive, and place an unfair burden on fellow employees and Supervisors. We expect excellent attendance from all employees. Excessive absenteeism or tardiness will result in disciplinary action up to and including discharge.
We do recognize there are times when absences and tardiness cannot be avoided. In such cases, employees are expected to notify supervisors as early as possible, but no later than the start of the workday. Asking another employee, friend or relative to give this notice is improper and constitutes grounds for disciplinary action. Employees should call, state the nature of the illness, and its expected duration, for every day of absenteeism.
WORKPLACE FREE OF VIOLENCE
Endiprev is strongly committed to providing a safe workplace. The purpose of this policy is to minimize the risk of personal injury to employees and damage to Endiprev and personal property. Endiprev specifically discourages employees from engaging in any physical confrontation with a violent or potentially violent individual.
WORKPLACE FREE OF GUNS
Endiprev gun policy is designed to promote a safe workplace for all employees. Regardless of whether an employee possesses a concealed gun permit or is allowed by law to possess a gun, guns are prohibited on any company property. Employees may not, at any time while on any property owned, leased, or controlled by Endiprev, including anywhere Endiprev company business is conducted, such as on wind farms, work sites, training facilities, and/or in hotels purchased by Endiprev, possess, use, or carry a gun.
SMOKING
Smoking, including the use of e-cigarettes, is prohibited within Endiprev premises and in all Endiprev vehicles. Smoking is prohibited while working on a job site, except in the proper signposted places. Smoking is generally prohibited in lodging (including hotels, motels, and houses facilities) and vehicles rented by Endiprev. Any fines incurred for smoking in a non-smoking location will be charged to the employee.
FOLLOW-UP AND MONITORING
The Code of Conduct is monitored by the Regulatory Compliance Officer and the Compliance Department, who are responsible for assessing compliance with the principles, values and rules of conduct established for all Endiprev employees.
TRAINING
Endiprev ensures the implementation of an internal training program for all its members, so that the rules and procedures for preventing corruption and related offenses, as well as the other conduct rules established in the Code of Conduct and internal policies, which must guide their behavior, are duly known.
The training will be conducted annually, tailored to the functions performed by the members, considering the roles they hold and, consequently, their different exposure to identified risks.
PUBLICITY AND REVIEW
The Code of Conduct is published on Endiprev’s website (www.endiprev.com) and on the Endiprev Intranet channel. Training sessions on its content will be promoted as specified in the previous article or whenever relevant changes are made to its content.
Endiprev takes the necessary measures to ensure that its Code of Conduct is known by all its employees, especially by those who are starting their roles.
The Code of Conduct is reviewed at least every three years and, before that, whenever there is a change in the company’s assignments or organizational structure, applicable legislation, or due to the implementation of improvements that justify a revision of the rules stated within it.
ANEXXES
Attached to this Code of Conduct, and forming an integral part thereof, is the document Internal Whistleblowing Channel Regulation.
Annex I – Internal Whistleblowing Channel Regulation
A. INTRODUCTION
This Regulation defines the procedures and rules to be followed regarding the communication, reception, follow-up, and archiving of reports of violations committed at ENDIPREV, S.A., hereinafter referred to as ENDIPREV, or through the company.
By Decree-Law Nr. 109-E/2021, dated December 9th, approved within the framework of the National Anti-Corruption Strategy 2020-2024 (which was itself approved by the Resolution of the Council of Ministers Nr. 37/2021, dated April 6th), the National Anti-Corruption Mechanism was created, and the General Regime for the Prevention of Corruption (hereinafter referred to as RGPC) was established.
The RGPC introduced new compliance obligations, including the adoption and implementation of a compliance program that must include at least a risk prevention plan for corruption and related offenses, a code of conduct, a training program, and a whistleblowing channel.
The procedures outlined in this Regulation also align ENDIPREV’s practices with the General Regime for the Protection of Whistleblowers, as stipulated by Law Nr. 93/2021 of December 20th, ensuring effective protection for Whistleblowers reporting violations.
The Internal Whistleblowing Channel allows for the safe submission and follow-up of reports, ensuring thoroughness, integrity, and preservation of reports, the confidentiality of the Whistleblower’s identity or their anonymity, and the confidentiality of the identity of third parties mentioned in the report.
At ENDIPREV, as a responsible organization governed by high ethical standards, we recognize that the safe reporting of potential violations committed within or through the company is essential to its success and reputation. Therefore, compliance with the provisions of this Regulation is absolutely fundamental.
B. WHISTLEBLOWERS
The following individuals have the legitimacy to use ENDIPREV’s Internal Whistleblowing Channel as “Whistleblowers”:
a. Employees.
b. Service providers, contractors, subcontractors, suppliers, and any individuals acting under their supervision or direction.
c. Shareholders and members of the management or governing bodies or supervisory or fiscal bodies of ENDIPREV, including non-executive members; and
d. Interns and volunteers.
C. VIOLATIONS
“Violations” refer to acts or omissions that are contrary to the law and can be reported through the Internal Whistleblowing Channel, and include issues related to the following areas:
a. Public procurement.
b. Services, products, and financial markets, as well as the prevention of money laundering and the financing of terrorism.
c. Product safety and compliance.
d. Transport safety.
e. Environmental protection.
f. Radiation protection and nuclear safety.
g. Food safety for human and animal consumption.
h. Animal health and welfare.
i. Public health.
j. Consumer protection.
k. Protection of privacy and personal data, as well as network and information system security.
l. Fraud and any other illegal activities that harm financial interests.
m. Internal market rules, including competition rules and state aids, as well as corporate taxation rules.
n. Cases of violent crime, especially violent and highly organized crimes; and
o. Cases of organized crime and economic-financial crime (corruption, undue advantage receipt, involvement in a business, embezzlement, influence peddling, money laundering).
The Whistleblower may also use ENDIPREV’s Internal Whistleblowing Channel to report acts they are aware of, committed within the company, related to violations beyond the aforementioned areas (e.g., harassment, discrimination, conflicts of interest, retaliation, or violations of rules in the Code of Conduct that do not fall under the listed topics).
However, reports that exceed the aforementioned scope are not covered by the protection provided under the General Regime for the Protection of Whistleblowers, as stipulated in Law Nr. 93/2021 of December 20, nor will their processing necessarily follow the legally established procedures for receiving and following up on reports.
Reports submitted through the Internal Whistleblowing Channel may relate to violations in the areas mentioned above that have already been committed, are being committed, or can reasonably be predicted to occur, as well as attempts to conceal such violations.
A report of a violation may be based on information obtained from a terminated professional relationship, as well as during the recruitment process or at another stage of pre-contractual negotiation, whether or not a professional relationship has been established.
When submitting a report, Whistleblower should consider the following:
The matter/factual content being reported (a brief and clear description of the facts subject to
the report).
- The time(s) the facts occurred (indication of whether the facts have already occurred, are occurring, or are expected to occur, and, in any case, the relevant dates and times).
- Who is involved in the facts (indication of the identity(ies) and roles/positions of the individuals involved or suspected).
- In which department(s) or organizational unit(s) the facts occurred, are occurring, or are expected to occur.
- How the Whistleblower became aware of the facts (indication of whether the Whistleblower witnessed the facts—saw or heard them—or if they were reported by another person(s), in which case the Whistleblower should provide the identity of the individual(s) and how or where they can be contacted).
- Who else is aware of the facts (indication of the identity(ies) and roles/positions of these individuals).
- Where evidence of the reported facts can be found (indication of the location of documents and/or other elements that support the reported facts, if any).
- Attachment of files with supporting or indicative evidence of the reported facts, if available.
D. WHISTLEBLOWING CHANNEL
Reports must be submitted through the Internal Whistleblowing Channel. The follow-up of the reports will be handled internally by ENDIPREV’s Compliance Department. ENDIPREV’s Internal Whistleblowing Channel accepts written reports, which should be submitted electronically via the form available on the ENDIPREV website (www.endiprev.com), through the link at the bottom labeled “Whistleblowing Channel.”
If facts are reported that involve the participation of a member(s) of the Compliance Department as a suspect(s) of committing the violation, the report will be brought to the attention of the Management, and a person or service will be designated to handle the internal follow-up of the report. The entire internal investigation procedure will be conducted without the participation of the accused, without prejudice against the accused’s right to be heard at the appropriate time.
E. PROCEDURE
After the submission of the report, if the Whistleblower has provided at least one contact (email address or physical address), ENDIPREV will, within 7 (seven) days:
- Notify the Whistleblower of the receipt of the internal report.
- Inform Whistleblower, in a clear and accessible manner, about the possibility of submitting an external report, providing information on the competent entities and the requirements that must be met
ENDIPREV will be responsible for the follow-up of the report, taking all necessary internal actions to verify the allegations in the report and, if applicable, to cease the reported violation. This may involve opening an internal inquiry or reporting to the competent authority (Public Prosecutor, criminal police, local authorities, among others) for investigation of the reported facts.
Within a maximum of 3 (three) months from receipt of the report, ENDIPREV will inform the Whistleblower, with justification, of the measures taken or planned to address the report.
The Whistleblower may request, at any time, to be informed of the outcome of the analysis of the report within 15 (fifteen) days after the completion of the process.
It is noted that ENDIPREV is only obligated to comply with the notifications to the Whistleblower within the established deadlines if contact details have been provided with the report submission. In the case of an anonymous report, with no contact details, no such communication will take place.
Throughout the entire procedure, the exhaustiveness, integrity, and preservation of the report will always be guaranteed, as well as the confidentiality of the Whistleblower’s identity or anonymity and the confidentiality of the identities of third parties mentioned in the report. Access to the information or investigation by unauthorized individuals will also be prevented.
F. CONFIDENTIALITY
Throughout the entire procedure, confidentiality will always be ensured, and access to data concerning the identity of the Whistleblower, as well as information that could directly or indirectly lead to deducing their identity, will be restricted.
Only the Compliance Department and Management have access to the information contained in the reports submitted through the Internal Whistleblowing Channel, as per the provisions outlined in this Regulation.
The identity of the Whistleblower may only be disclosed in compliance with a legal obligation or judicial decision.
Any disclosure of information by ENDIPREV will be preceded by written communication to the Whistleblower (who has provided contact details), indicating the substantial reasons for disclosing the confidential data in question, unless providing this information would compromise investigations or legal proceedings related to the report.
G. PERSONAL DATA PROTECTION
All communications will be handled independently and confidentially, ensuring the protection of Whistleblower’s personal data.
The processing of personal data collected within the Internal Whistleblowing Channel is carried out in accordance with the General Data Protection Regulation (GDPR) – Regulation (EU) 2016/679 of the European Parliament and Council, dated April 27, 2016 – which stipulates the rules for processing personal data for the purposes of preventing, detecting, investigating, or prosecuting criminal offenses or enforcing criminal sanctions.
All collected data will be processed solely within the scope of handling the report, and personal data that is deemed irrelevant to this process will not be retained.
H. ARCHIVING
ENDIPREV will register all reports, assigning a respective number to each report, following a sequential order, and indicating the respective reception date, analysis date, and report issuance date, as well as classifying it according to the process status (pending or closed).
ENDIPREV will maintain an up-to-date record of received reports and the corresponding file for a period of 5 (five) years and, regardless of this period, for as long as there is a pending legal or administrative process related to the report.
I. PROTECTION OF WHISTLEBLOWERS
The decision to report a wrongdoing should be made consciously, thoughtfully, and honestly, and it presupposes good faith on the part of the Whistleblower.
Protection is only guaranteed to the Whistleblower who reports in good faith and has a serious basis to believe that the information reported is, at the time of submission, true.
Protection is also ensured for:
- An individual who assists the Whistleblower in the reporting procedure, whose assistance must remain confidential, including union representatives or employee representatives.
A third party who is connected to the Whistleblower, such as a coworker or family member, and may be subject to retaliation in a professional context; and
Legal entities or equivalent entities that are owned or controlled by the Whistleblower, for which the Whistleblower works or is professionally connected in some way.
It should be noted that a Whistleblower who intentionally makes a false report or fabricates evidence to initiate an internal investigation, especially with the intention of harming someone, acts in bad faith. A Whistleblower acting in bad faith does not benefit from the legal protection provided by the Whistleblower Protection Law (Law Nr. 93/2021, December 20) and may be held disciplinarily, criminally, and civilly responsible for their actions.
ENDIPREV guarantees the protection of Whistleblowers by establishing measures that, if violated, could lead, in addition to legal liability, to civil responsibility and the obligation to indemnify the damage caused.
All forms of retaliation are prohibited, whether they are obvious or subtle, including sanctions, acts of persecution or discrimination, whether direct or indirect. To assist in understanding and identifying situations that may represent retaliation, here are some examples of acts that, if they occur within 2 (two) years of the report being submitted, could constitute acts of retaliation:
a. Changes to working conditions, such as job roles, hours, work location, or compensation, failure to promote the worker, or failure to meet labor duties.
b. Suspension of employment contract.
c. Negative performance evaluation or negative reference for employment purposes.
d. Failure to convert a fixed-term contract into a permanent contract, whenever the worker had legitimate expectations for such conversion.
e. Failure to renew a fixed-term employment contract.
f. Dismissal.
g. Inclusion on a list, based on sector-wide agreements, that may prevent the Whistleblower from finding employment in the relevant sector or industry in the future; and
h. Termination of a supply or service contract.
Any disciplinary sanction applied to Whistleblower, or a colleague who assists the Whistleblower in the reporting process, within 2 (two) years of the report or its public disclosure, will be presumed abusive.
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