Code of Ethics and Conduct

Mod056.07 12/02/2025

 

Main Objectives of the Code of Ethics and Conduct

The Code of Ethics and Conduct is a set of principles that aims to establish a commitment among stakeholders to the principles of the Universal Declaration of Human Rights, the Conventions of the International Labor Organization and the National and Community Legislation in force, and the principles established in the General Regime for the Prevention of Corruption, considering the criminal rules relating to corruption and related offenses, and also identifying the disciplinary sanctions that may be applied in the event of non-compliance, according to Annexes I and II.

This Code applies to all employees of VIZELPASincluding senior managers.

Its aim is to sustain a culture of ethics and integrity, in a climate of rigor and total transparency in order to:

  • Introducing VIZELPAS as a company with social responsibility, complying with and enforcing the standards of good conduct of all partners, reinforcing a common socially responsible culture.
  • Promoting relationships of trust between the company and all its business partners, as well as encouraging the practice of the values assumed by VIZELPAS.
  • Ensure that in all commercial relations, the values assumed by VIZELPAS.
  • Ensure full respect for people and their rights.
  • Ensuring high standards of health and safety at work.
  • Minimizing the environmental impact of VIZELPASby integrating the environmental perspective into processes and the management system.

The purpose of this Code of Ethics and Conduct is to extend the above commitments to all VIZELPAS business partners. VIZELPAS.

Social Responsibility Policy

The work of VIZELPASin the market goes beyond the purely economic dimension. It is concerned with identifying and managing talent, developing skills in the workforce that add value to the business and asserting itself through ethical and socially responsible conduct.

In this way VIZELPAS is committed to the following principles of Social Responsibility:

  • Forced or Involuntary Labor and Human Trafficking:

It does not use or condone human trafficking or the use of forced or involuntary labor, whether through physical imposition, threats or other forced methods. It does not apply any kind of pressure or withhold identification documents.

It recognizes the right of its employees to leave their jobs by giving notice within a reasonable period of time.

It encourages and requires its business partners to comply with this principle.

  • Child labor:

It does not use or allow the use of child labor, i.e. underage employees. It requires its suppliers and subcontractors to comply with all applicable legislation on the work of minors.

  • Discrimination:

Censors any form or practice of discrimination in its partners and towards its employees in relation to hiring, remuneration, access to training, promotions and termination of employment or retirement, based, in particular, on race, color, sex, religion, age, nationality, disability, sexual orientation, social or ethnic origin, political affiliation or religion.

  • Harassment:

The Code of Conduct for Preventing and Combating Harassment at Work adopted by VIZELPAS, aims, under the terms of Law no. 73/2017, of August 16, to prevent and combat harassment at work.

A VIZELPAS, is committed to upholding the values of non-discrimination and combating harassment at work.

  • Freedom of Association:

It recognizes and respects the right of employees to freedom of association and representation, in accordance with their wishes expressed freely and without pressure.

Suppliers and subcontractors must not interfere with the exercise of employees' rights regarding Freedom of Association and their Right to Collective Bargaining.

  • Coercion, Harassment and Disciplinary Practices:

It guarantees its employees respect for their dignity and will not use corporal punishment or threats of violence, and disapproves of any kind of physical, sexual, psychological or verbal abuse or harassment. It requires its suppliers and subcontractors not to engage in any kind of coercion, harassment or acts of violence.

  • Conflict of interest:

It ensures that there is no conflict of interest or damage to the image of VIZELPAS. VIZELPAS. Under no circumstances can business commitments be used to satisfy personal interests.

Business partners may not engage in any form of bribery for the purpose of influencing any act or failure on the part of a VIZELPAS employee or representative. VIZELPAS. Nor may they accept improper payments that seek to influence any act or failure on the part of VIZELPAS.

  • Offers, bonuses, benefits and advantages

The employees of VIZELPAS may not solicit, receive or accept, for themselves or for third parties, any offers, benefits, gifts, compensations or advantages, regardless of their value or materiality, which may affect impartiality, transparency, impartiality and integrity in the performance of their duties.

  • Safety and Health at Work:

Ensures a safe and healthy working environment for its employees. It promotes compliance with safety, health and hygiene standards and requires its suppliers and subcontractors to ensure a safe and healthy working environment.

  • Remuneration:

It guarantees all legally established remuneration, requiring its suppliers and subcontractors to pay fairly and in accordance with the laws in force.

  • Working hours:

It ensures that working hours are complied with and overtime is paid in accordance with the applicable legislation, and also encourages its suppliers and subcontractors to comply with the law.

  • Legal requirements:

Comply with national and international legislation and regulations applicable to its activity, requiring its suppliers and subcontractors to comply with the same.

  • Environment:

It promotes the adoption of the necessary measures to protect the environment and conducts all its activities in accordance with the legal requirements relating to environmental protection, encouraging environmental management practices in its suppliers and subcontractors.

Suggestion Policy

All employees and other interested parties have the right to have their issues dealt with by the company impartially, fairly and within a reasonable timeframe. To this end, they can use the "Suggestions - Mod008" register and put them in the suggestions box.

This right includes:

  • To anonymity, if you wish;
  • The right of any employee to be heard before any individual measure affecting them adversely is taken;
  • The right of any employee to have access to files relating to them, while respecting the legitimate interests of confidentiality and professional and commercial secrecy;
  • The CA's obligation to give reasons for its decisions.

Obligations of Business Partners

A VIZELPAS informs all its business partners of the commitments made and the requirements to be met, mentioned in this Code of Ethics and Conduct.

They must inform their employees of the social responsibility commitments mentioned in this Code of Ethics and Conduct, ensuring full compliance with them, as well as all the legislation in force applicable to their activity.

In the event that suppliers and subcontractors subcontract operations associated with the manufacture of VIZELPASproducts, they must request prior written authorization from VIZELPAS. They are responsible for ensuring that their subcontractors comply with the minimum requirements stipulated in this Code of Ethics and Conduct.

All business partners must fully comply with the obligations arising from this Code of Ethics and Conduct. If they fail to comply, specific actions will be taken based on an assessment of the infraction, the specific circumstances and previous history. A VIZELPAS has the right to take measures up to and including termination of the business relationship, when this is necessary to protect its well-being and that of its employees.

Confidentiality of information

All business partners are obliged to preserve the integrity and confidentiality of the information they receive as a result of their business relations with VIZELPAS.

The obligation of confidentiality will remain once your relationship with VIZELPAS and will include the obligation to return all materials associated with the company in their possession.

Universal Declaration of Human Rights

The company VIZELPAS fully subscribes to the universal declaration of human rights. Any violation of these principles must be reported to VIZELPAS.

If you want to do it securely, you can use the following email address: jessicaazevedo@vizelpas.pt

This code will be reviewed and updated every three years or whenever justified, and will be made public, within 10 days of its implementation and respective revisions or drafting, by publication on the VIZELPAS website. VIZELPAS and also by posting it on the internal communications board.

The following annexes form an integral part of this Code of Ethics and Conduct:

Annex I Table of disciplinary offenses and corresponding sanctioning framework
Annex II Criminal typologies provided for in the RGPC and the corresponding sanctioning framework
Annex III Model structure for reporting infringements of the Code of Ethics and Conduct

Supplier Name: ________________________________________________________

Responsible: ____________________________________________________________

Signature and stamp: _____________________________________________________

Data: _________________________________

Annex 1 - Table of disciplinary offenses and corresponding sanctioning framework

TABLE OF DISCIPLINARY OFFENSES

Violation of the duties set out in article 128 of the Labor Code

Article 128

Workers' duties

1 - Without prejudice to other obligations, the employee must:

a) Respect and treat the employer, hierarchical superiors, work colleagues and people who have dealings with the company with urbanity and probity;

b) Attend work assiduously and punctually;

c) Carry out the work with zeal and diligence;

d) Participate diligently in professional training provided by the employer;

e) Comply with the employer's orders and instructions regarding the execution or discipline of work, as well as safety and health at work, which are not contrary to their rights or guarantees;

f) Maintain loyalty to the employer, namely by not negotiating on their own behalf or on behalf of others in competition with them, nor by divulging information regarding their organization, production methods or business;

g) Ensure the conservation and proper use of work-related property entrusted to them by their employer;

h) Promoting or carrying out actions aimed at improving the company's productivity;

i) Cooperate to improve health and safety at work, namely through the workers' representatives elected for this purpose;

j) Comply with occupational health and safety requirements arising from the law or collective bargaining agreements.

2 - The duty of obedience concerns both the orders or instructions of the employer and of the employee's hierarchical superior, within the powers attributed to him by the latter.

TABLE OF LEGALLY PRESCRIBED DISCIPLINARY SANCTIONS FOR BREACHES OF WORKERS' DUTIES

according to article 328 of the Labor Code

Article 328

Disciplinary sanctions

1 - In exercising disciplinary power, the employer may apply the following sanctions:

a) Reprimand;

b) Recorded reprimand;

c) Financial penalty;

d) Loss of vacation days;

e) Suspension from work with loss of pay and seniority;

f) Dismissal without pay or compensation.

2 - The collective bargaining agreement may provide for other disciplinary sanctions, as long as they do not affect the worker's rights and guarantees.

3 - The application of sanctions must respect the following limits:

a) Financial penalties imposed on a worker for infractions committed on the same day may not exceed one third of the daily wage and, in each calendar year, the wage corresponding to 30 days;

b) The loss of vacation days may not jeopardize the enjoyment of 20 working days;

c) Suspension from work may not exceed 30 days for each infraction and a total of 90 days per calendar year.

4 - Whenever justified by special working conditions, the limits set out in points a) and c) of the previous paragraph may be doubled by a collective bargaining agreement.

5 - The sanction may be aggravated by its disclosure within the company.

6 - Violation of paragraphs 3 or 4 shall constitute a serious administrative offense.

ANNEX 2 - Criminal typologies provided for in the RGPC and the corresponding penalty framework

Crime Legal definition and punitive framework

Illustrative examples of practical situations
Corruption (Art. 373) - An official who, by him/herself or through an intermediary, with his/her consent or ratification, requests or accepts, for him/herself or for a third party, a pecuniary or non-pecuniary advantage, or the promise thereof, for the performance of any act or omission contrary to the duties of the office, even if prior to that request or acceptance, shall be punished with imprisonment of one to eight years.

2 - If the act or omission is not contrary to the duties of office and the advantage is not due to him, the agent shall be punished with imprisonment of one to five years.

 When an officer or employee of an organization solicits or receives a bribe, or the promise thereof, in exchange for taking a decision, within the scope of their duties, that unduly benefits the person who bribed them.
Undue receipt and offer
of an advantage (Art. 372)		 1 - An official who, in the performance 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 pecuniary or non-pecuniary advantage which is not due to him, shall be punished with imprisonment of up to five years or a fine of up to 600 days.

2 - Anyone who, by themselves or through an intermediary, with their consent or ratification, gives or promises an official, or a third party on their recommendation or knowledge, a pecuniary or non-pecuniary advantage that is not due to them, in the course of their duties or because of them, shall be punished with imprisonment of up to three years or a fine of up to 360 days.

3 - The preceding paragraphs do not apply to conduct that is socially appropriate and in accordance with custom.

 When a manager or employee of an organization, in the performance of their duties, requests or receives from another person, directly or indirectly, property or financial assets that are not owed to them and that are likely to affect their duties of integrity and impartiality.
Peculato (art. 375) 1 - An official who unlawfully appropriates, for his own benefit or for the benefit of another person, money or any movable or immovable property or animal, whether public or private, which has been handed over to him, is in his possession or is accessible to him by reason of his duties, shall be punished with a penalty of

imprisonment of 1 to 8 years, if a more serious penalty is not imposed by virtue of another legal provision.

2 - If the valuables or objects referred to in the previous paragraph are of low value, under the terms of Article 202(c), the perpetrator shall be punished with imprisonment for up to 3 years or a fine.

3 - If the official lends, pledges or in any way encumbers the valuables or objects referred to in paragraph 1, he shall be punished with imprisonment of up to 3 years or with a fine, if a more serious penalty is not imposed by virtue of another legal provision.

 When a manager or employee of an organization appropriates property or assets belonging to the organization in which they hold office.
Peculato de uso (art. 376) 1 - An official who uses or allows another person to use, for purposes other than those for which they were intended, immovable property, vehicles, other movable property or animals of appreciable value, whether public or private, which are handed over to him, are in his possession or are handed over to him

Any person who has access to information that is accessible by virtue of their duties shall be punished with imprisonment of up to one year or a fine of up to 120 days.

2 - If the official, without special reasons of public interest justifying it, gives public money a destination for public use other than that to which it is legally assigned, he shall be punished with imprisonment of up to one year or a fine of up to 120 days.

 When a manager or employee of an organization uses property, equipment or valuables, material or financial, belonging to the organization in which they hold office or which are in their custody, on their behalf or authorizes third parties to do so.
Economic participation in
business (Art. 377)		 - An official who, with the intention of obtaining, for himself or for a third party, unlawful economic participation, damages in a legal transaction the property interests which, in whole or in part, he is responsible for administering, supervising, defending or realizing by virtue of his function, shall be punished with imprisonment of up to 5 years.

2 - An official who, in any way, receives, for himself or for a third party, a pecuniary advantage as a result of a legal-civil act relating to interests of which he had, by virtue of his duties, at the time of the act, total or partial control, administration or supervision, even without harming them, shall be punished with imprisonment of up to 6 months or a fine of up to 60 days.

3 - The penalty provided for in the preceding paragraph shall also apply to an official who receives, for himself or for a third party, in any form whatsoever, a financial advantage as a result of the collection, assembly, liquidation or payment which, by virtue of his duties, in whole or in part, he is charged with ordering or making, provided that there is no damage to the Public Treasury or to the interests entrusted to him.

 When a manager or employee of an organization, in the exercise of their duties, makes decisions that benefit a particular interest, their own or that of a third party, harming the interest or causing damage to the organization or entity.
Concussion (Art. 379) 1- An official who, in the exercise of his duties or de facto powers deriving from them, by himself or through an intermediary with his consent or ratification, receives, for himself, for the State or for a third party, through inducement into error or taking advantage of the victim's error, a pecuniary advantage that is not due to him, or is greater than what is due, namely a contribution, fee, emolument, fine or fine, shall be punished with imprisonment of up to 2 years or a fine of up to 240 days, if a more serious penalty does not apply to him by virtue of another legal provision.

2 - If the act is committed by means of violence or threats of serious harm, the perpetrator shall be punished with imprisonment from 1 to 8 years, if a more serious penalty is not imposed by virtue of another legal provision.

 When a manager or employee of an organization, in the performance of their duties, appropriates value or property that is not due, and whose existence is the result of a circumstantial error or has been deliberately induced by them.
Abuse of power (Art. 382) An official who, outside the cases provided for in the previous articles, abuses his powers or violates the duties inherent in his functions, with the intention of obtaining, for himself or for a third party, an illegitimate benefit or causing harm to another person, shall be punished with imprisonment of up to 3 years or with a fine, if a more serious penalty is not imposed by virtue of another legal provision. When a manager or employee of an organization takes advantage of the functional power at their disposal to unduly satisfy their own interests or those of a third party.
Influence peddling (Art. 335) 1 - Anyone who, by themselves or through an intermediary, with their consent or ratification, requests or accepts, for themselves or for a third party, a pecuniary or non-pecuniary advantage, or the promise thereof, in order to abuse their influence, real or supposed, with any public entity, national or foreign, shall be punished: a) With imprisonment of 1 to 5 years, if a more serious penalty does not apply to them by virtue of another legal provision, if the purpose is to obtain any unlawful favorable decision;

b) With imprisonment of up to 3 years or a fine, if a more serious penalty is not imposed by virtue of another legal provision, if the aim is to obtain a favorable legal decision.

2 - Anyone who, by themselves or through an intermediary, with their consent or ratification, gives or promises a pecuniary or non-pecuniary advantage to the persons referred to in the previous paragraph: a) For the purposes set out in point a), shall be punished with imprisonment for up to 3 years or a fine; b) For the purposes set out in point b), shall be punished with imprisonment for up to 2 years or a fine of up to 240 days.

 When someone requests or receives a material or financial good or value in exchange for moving their influence with a public entity or service with a view to a certain illicit purpose of that entity or service.
Laundering (Art. 368a) 3 - Anyone who converts, transfers, assists or facilitates any operation of conversion or transfer of advantages, obtained by themselves or by a third party, directly or indirectly, with the aim of concealing their illicit origin, or of preventing the perpetrator or participant of such offenses from being criminally prosecuted or subjected to a criminal reaction, shall be punished with imprisonment of up to 12 years.

4 - The same penalty shall apply to anyone who conceals or disguises the true nature, origin, location, disposition, movement or ownership of advantages, or the rights relating thereto.

5 - The same penalty shall also apply to anyone who, while not being the perpetrator of the typical unlawful act from which the advantages originate, acquires, holds or uses them, with knowledge, at the time of acquisition or at the initial moment of holding or use, of that capacity.

 When someone intentionally conceals the illicit origin of property, financial or material assets.

Annex 3 - Model structure for reporting infringements of the Code of Ethics and Conduct

Circumstantial factuality Violated standard Date Sanction applied Preventive/corrective measures adopted
Column 1 Value Column 2 Value Column 3 Value Column 4 Value Column 5 Value