Index

1. ACRONYMS AND ABBREVIATIONS
2. INTRODUCTION
2.1 Legislative framework
2.2. Objectives
2.3 Scope of the PPR
3. VIZELPAS FLEXIBLE FILMS, SA
3.1 ORGANIZATIONAL STRUCTURE
3.2 History
3.3 Internal Regulations
3.4 Code of Ethics and Conduct
3.5 Code of Conduct for Preventing and Combating Harassment at Work
3.6 Reporting Channel
4. CONCEPTS OF CORRUPTION AND RELATED OFFENSES
5. MANAGEMENT METHODOLOGY AND RISK ASSESSMENT AND MANAGEMENT
6. RISK ASSESSMENT
7. IMPLEMENTATION OF THE PPR
7.1 Implementation, monitoring and evaluation of the PRP
7.2 Publicizing the PRP

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1. ACRONYMS AND ABBREVIATIONS

VIZELPAS - VIZELPAS FLEXIBLE FILMS, SA
AG - General Meeting
CA - Board of Directors
CÓDIGO PENAL - Portuguese Penal Code
GR - Risk Level
IP - foreseeable impact
MENAC - National Anti-Corruption Mechanism
PO - Probability of occurrence
PPR - Plan for the Prevention of Risks of Corruption and Related Offenses
RCN - Responsible for Regulatory Compliance
RGPC - General Regime for the Prevention of Corruption

2. INTRODUCTION

2.1 Legislative framework

On March 18, 2021, following a long period of reflection and extensive public hearings, involving academia, the judiciary, legal professionals and other branches of knowledge, the government approved the final version of the National Anti-Corruption Strategy 2020-2024, under the terms of Council of Ministers Resolution no. 37/2021, of April 6.
The Strategy, which views the prevention, detection and prosecution of corruption as equally important and necessary, sets out seven priorities:

1. improve knowledge, training and institutional practices in the area of transparency and integrity;
2. prevent and detect the risks of corruption in public action;
3. committing the private sector to the prevention, detection and repression of corruption;
4. strengthening the links between public and private institutions;
5. ensure a more effective and uniform application of legal mechanisms for the repression of corruption, improve the response time of the judicial system and ensure the adequacy and effectiveness of punishment;
6. periodically produce and disseminate reliable information on the phenomenon of corruption; and
7. cooperate internationally in the fight against corruption.

Within this framework, Decree-Law 109-E/2021 of December 9 was also published, establishing measures to combat corruption and related offenses:

1. the creation of the National Anti-Corruption Mechanism ("MENAC"), and,
2. the approval of the General Regime for the Prevention of Corruption ("RGPC").

In addition, as part of the transposition of Directive (EU) 2019/1937, Law no. 93/2021 of December 20 was approved, establishing the General Regime for the Protection of Whistleblowers.
According to the provisions of Decree-Law no. 109-E/2021, of December 9, corruption and related offenses are defined as the crimes of corruption, undue receipt and offer of advantage, embezzlement, economic participation in business, concussion, abuse of power, prevarication, influence peddling, money laundering or fraud in obtaining or misappropriating a subsidy, grant or credit, as set out in the Penal Code, approved in annex to Decree-Law no. 48/95, of March 15.º 48/95, of March 15, in its current wording, in Law no. 34/87, of July 16, in its current wording, in the Code of Military Justice, approved in annex to Law no. 100/2003, of November 15, in Law no. 50/2007, of August 31, in its current wording, in Law no. 20/2008, of April 21, in its current wording, and in Decree-Law no. 28/84, of January 20, in its current wording.

The aforementioned RGPC, with the aim of preventing, detecting and sanctioning acts of corruption and related offenses, stipulates that legal persons employing 50 or more employees are obliged to implement a compliance program that includes at least:

1. a plan to prevent risks of corruption and related offenses;
2. a code of conduct;
3. a training program; e,
4. a reporting channel.

In accordance with the aforementioned legislation, VIZELPAS has implemented a regulatory compliance program, of which this Plan for the Prevention of Risks of Corruption and Related Infractions ("PPR") is an integral part.

Under the terms of article 7 of the RGPC, the PPR must cover all functions and organizational units, including top management, in terms of identifying risks of this nature, since all of them are known to be exposed to the possibility of being exercised by people who are less competent from the point of view of integrity.

To this end, and in strict compliance with article 6.2 of the aforementioned law, the PPR includes:
a) The areas of activity of the entity at risk of committing acts of corruption and related infractions;
b) The probability of occurrence and the foreseeable impact of each situation, so as to allow the risks to be graded;
c) Preventive and corrective measures to reduce the likelihood of occurrence and the impact of the risks and situations identified;
d) In situations of high or maximum risk, the most exhaustive preventive measures, with priority given to their implementation;
e) The designation of the general person responsible for the implementation, control and review of the RAP, who is responsible for regulatory compliance.

2.2. Objectives

The purpose of this PPR is to identify and manage VIZELPAS' risks of corruption and related offenses.

It applies to all employees, service providers and other collaborators, regardless of their legal status, including senior management, and aims to implement procedures and mechanisms for the prevention and detection of corruption and related infractions.

2.3 Scope of the RFP

The Board of Directors of VIZELPAS designates the Chairman of the Board of Directors as the person responsible for compliance with the regulations:
- Coordinating the work of surveying and systematizing the ethical values or principles of action of the entity or organization, as well as the most appropriate indications of conduct with a view to complying with them, promoting and ensuring the participation and involvement of all, in particular senior managers and the intermediate structure, in relation to the processes of drawing up and updating the Code of Ethics and Conduct;
- Coordinating the work of surveying the risks of corruption and related infractions and the corresponding risk analysis and identification of preventive measures, ensuring the involvement and collaboration of the hierarchical structure of the entity or organization in the processes of drawing up and updating the Risk Prevention Plan as well as evaluating its implementation;
- Ensuring compliance with the deadlines for communicating, disseminating and publicizing the Code of Ethics and Conduct, the Risk Prevention Plan and the corresponding reports assessing its implementation;
- Monitoring and verifying compliance with the Internal Whistleblowing Channel's own operating requirements, including guarantees of protection for whistleblowers, confidentiality and reservation duties, compliance with deadlines and prevention of conflicts of interest;
- Gathering and systematizing information on training needs in the areas of ethics, integrity and prevention of risks of corruption and related infractions and involvement in the process of producing training programmes and monitoring compliance, and
- Verifying the need to update the various instruments of the Regulatory Compliance Program.

The RCN is ensured that it carries out its duties independently, permanently and with decision-making autonomy, and it is ensured that it has the internal information and the human and technical resources necessary for the proper performance of its duties.

3. VIZELPAS

3.1 ORGANIZATIONAL STRUCTURE

VIZELPAS, with the Corporate Identification Number 503844969, and the same registration number, was incorporated in 1997 and its corporate purpose is "Manufacture and wholesale and retail sale of plastic articles and various stationery items", and the main CAE 22292.
It is incorporated as a public limited company and has its head office in the parish of Vilarinho, in the municipality of Santo Tirso, more specifically at Rua da Fundição, nº 8, 4795 792 Vilarinho STS.
It currently employs 210 people.
VIZELPAS is organized according to the nominal organization chart attached as Annex I.

3.2 History

VIZELPAS has been operating since 1999 and is an audacious, daring, enthusiastic, innovative, transparent company, focused on its objectives and always supportive of its partners.
In this way, it has shown unusual growth, putting its strategic vision and mission into practice.
Its mission is based on 6 key principles:

1. Partnerships with customers and suppliers. It is the partnerships we foster with our customers and suppliers that allow us to add value to our products, develop and innovate.
2. Supplying quality products that are safe and suitable for contact with foodstuffs.
3. In the development and innovation of products that can respond to increasingly demanding, evolving and concerned markets.
4. Effective management of our human resources, promoting teamwork, loyalty and commitment to the company's mission.
5. In sustainability policies undertaken not only to create value for the company, but also for society and the environment.
6. In policies with as little environmental impact as possible, either by using materials with less environmental impact and Oxo-biodegradable products, or by using thinner technical films.

Throughout its history, VIZELPAS has always honored its commitments:

Compliance with current legislation;
With customers;
With suppliers;
With employees;

Thus maintaining the image of a "good person" and a company endowed with the necessary balance to overcome the most diverse vicissitudes.

On the other hand, it is also committed to the principles of the RGPC, as well as to adopting and implementing a compliance program in order to prevent, detect and sanction acts of corruption and related infractions carried out against or through the entity.

3.3 Rules of Procedure

VIZELPAS has implemented Internal Regulations, which impose on all employees a personal/social attitude and all the rules of internal operation to be complied with by everyone.
It defines the policies to be complied with by all, as well as the rules of conduct, rights and obligations of employees and the respective disciplinary framework.
It also imposes policies on food quality and safety, hygiene and ethics and the environment.
The Internal Regulations are given to all employees on their arrival.

3.4 Code of Ethics and Conduct

VIZELPAS has also approved a Code of Ethics and Conduct, which is a guide for the actions of the company and its employees, containing principles of action, as well as the values and objectives to be followed.
The Code is aimed at all those who work in and for VIZELPAS, and extends to all business partners.
It imposes a set of principles aimed at establishing 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.
It aims to sustain a culture of ethics and integrity, in a climate of rigor and total transparency in order to:

• Presenting 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 the values assumed by VIZELPAS are taken into account in all commercial relations.
• Ensure full respect for people and their rights.
• Ensuring high standards of health and safety at work.
• Minimize the environmental impact of VIZELPAS' activities by integrating the environmental perspective into processes and the management system.

VIZELPAS is committed to the following principles of Social Responsibility:

#Prohibition of Forced or Involuntary Labor and Human Trafficking
#Prohibition of Child Labor
#Prohibition of Discrimination
#Prohibition of Harassment:

VIZELPAS also undertakes to defend the values of non-discrimination and combating harassment at work, which are broken down:

• 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:

They ensure that there is no conflict of interest and that VIZELPAS' image is not damaged. Under no circumstances can business commitments be used to satisfy personal interests.

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

• Offers, bonuses, benefits and advantages

VIZELPAS employees 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 could 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.

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

Business partners may not exercise any kind of bribery for the purpose of influencing any act or failure on the part of a VIZELPAS employee or representative, nor may they accept improper payments that seek to influence any act or failure towards VIZELPAS.

Within this framework, a Suggestion Policy has also been implemented, which operates as follows:

• 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:

The right to anonymity, should they so 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 obligation on the part of the C.A. to give reasons for its decisions.

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 and also by posting on the internal communications board.
The following annexes form an integral part of the 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 corresponding sanctioning framework
Annex III Model structure of the report on infringements of the Code of Ethics and Conduct

3.5 Code of Conduct for Preventing and Combating Harassment at Work

VIZELPAS has also approved and implemented a Code of Conduct for Preventing and Combating Harassment at Work, which sets out employees' rights and guarantees in this area and aims to defend the values and principles of non-discrimination and combat harassment at work.

This Code is a self-regulatory instrument, as well as the expression of an active policy to publicize, prevent, identify, eliminate and punish situations and behaviors that could constitute harassment at work.

The Code of Conduct for Preventing and Combating Harassment at Work applies to all individuals who perform permanent or casual duties at VIZELPAS, of whatever nature, as well as other people who participate in its activity and prohibits the adoption of discriminatory behavior towards any person, namely on the basis of race, gender, age, physical disability, sexual orientation, opinions, political ideology and religion.

According to this instrument, employees who consider they are being harassed at work should report the situation to their hierarchical superior, human resources or the Chairman of the Board of Directors.

The same applies to anyone who becomes aware of irregular practices that may indicate harassment, or that a worker has been disciplined for harassment, and they must report them to any of the worker's superiors and cooperate in the disciplinary process and any other proceedings that may take place.

Situations and behaviors that could constitute harassment practiced by third parties who do not perform duties at VIZELPAS will be the subject of a complaint, to be made by the Chairman of the Board of Directors to the competent authority.

The Code of Conduct for Preventing and Combating Harassment at Work came into force on November 16, 2021 and has been disseminated to all Employees, as well as being made available on the Vizelpas website.

3.6 Complaints channel

VIZELPAS, in accordance with the provisions of Law No. 93/2021, of September 20, which establishes the general regime for the protection of whistleblowers, transposing into the internal legal order Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019 on the protection of persons who report breaches of Union law, has an internal whistleblowing channel.

It allows for the secure submission and follow-up of complaints, in order to guarantee the completeness, integrity and preservation of the complaint, the confidentiality of the identity or anonymity of the complainants and the confidentiality of the identity of third parties mentioned in the complaint, and to prevent unauthorized persons from accessing the information.

A "Whistleblowing Channel Regulation" has also been drawn up, which establishes the set of principles and rules that regulate the operation of this channel and applies to all employees, including all members of the governing bodies, managers, all other employees, suppliers and customers.

The Regulation will be included in VIZELPAS's Internal Regulations, and this new version has been made available for consultation by all employees, as will any employees who may be hired in the meantime.

It is also published on the respective website under the Whistleblowing Channel link at https://vizelpas.pt/portal-de-denuncias/.

The internal whistleblowing channel implemented works via the link https://vizelpas.pt/portal-de-denuncias/, located on the respective website, allowing complaints to be lodged anonymously and guaranteeing confidentiality in cases where the whistleblower identifies themselves.

4. CONCEPTS OF CORRUPTION AND RELATED OFFENSES

The concepts of corruption and related offenses need to be outlined at the outset.

Thus, for the purposes of the general regime for the prevention of corruption, and of this Plan for the Prevention of Risks of Corruption and Related Offenses, the following definitions apply:

• Passive corruption (Article 373 of the Criminal Code): An official who, 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, 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.
• Active corruption (Article 374 of the Criminal Code): 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 with their knowledge, a pecuniary or non-pecuniary advantage for the purpose indicated in Article 373(1).
• Undue receipt and offer of an advantage (Article 372 of the Criminal Code): 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. Whoever, by himself or through an intermediary, with his consent or ratification, gives or promises to an official, or to a third party on his recommendation or knowledge, a pecuniary or non-pecuniary advantage which is not due to him, in the performance of his duties or because of them.
• Peculato (Article 375 of the Criminal Code): 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 given to him, is in his possession or is accessible to him by reason of his duties.
• Economic participation in business (Article 377 of the Criminal Code): An official who, with the intention of obtaining, for himself or for a third party, illicit economic participation, harms in a legal transaction the property interests which, in whole or in part, he is obliged, by reason of his function, to administer, supervise, defend or carry out.
• Concussion (Article 379 of the Criminal Code): An official who, in the exercise of his functions or of 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 financial advantage that is not due to him, or is greater than that due, namely a contribution, fee, emolument, fine or penalty.
• Abuse of power (Article 382 of the Criminal Code): 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.
• Prevarication (Article 369 of the Criminal Code): An official who, in the context of a procedural investigation, judicial proceeding, administrative offense or disciplinary proceeding, knowingly and against the law, promotes or fails to promote, conducts, decides or fails to decide, or performs an act in the exercise of powers arising from the office he or she holds.
• Bribery (Article 363 of the Criminal Code): Anyone who persuades or attempts to persuade another person, by means of a gift or promise of a pecuniary or non-pecuniary advantage, to carry out the acts provided for in articles 359 or 360, without them being committed.
• Trafficking in influence (Article 335 of the Criminal Code): Whoever, by himself or through an intermediary, with his consent or ratification, requests or accepts, for himself or for a third party, a financial or non-financial advantage, or the promise thereof, in order to abuse his influence, real or supposed, with any public entity, national or foreign.
• Laundering (Article 368-A of the Criminal Code): Anyone who converts, transfers, assists or facilitates any operation to convert or transfer 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 from being criminally prosecuted or subjected to a criminal reaction. The same penalty applies to anyone who conceals or disguises the true nature, origin, location, disposition, movement or ownership of advantages, or the rights relating thereto. The same penalty applies 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 this capacity.

5. MANAGEMENT METHODOLOGY AND RISK ASSESSMENT AND MANAGEMENT

In accordance with the provisions of MENAC GUIDE No. 1/2023, after assessing the likelihood and foreseeable impact of each risk, the risk level is classified according to the combinatorics shown in the analysis matrix below:

Degree of risk		Probability of occurrence
		High (3)	Average (2)	Low (1)
Expected impact	High (3)	Maximum	High	Moderate
	Medium (2)	High	Moderate	Weak
	Bass (1)	Moderate	Weak	Minimum

The assessment and classification of risks is based on a combination of the probability of occurrence of the situations involving the risk and the severity of their expected impact, which results in a degree of risk that follows a scale with five levels (minimum, weak, moderate, high and maximum), according to which different response strategies will be defined.

The foreseeable impact can be understood as the expected consequence of the occurrence of an event that affects the strategic objectives of VIZELPAS, and is graded as follows:

- Low - The occurrence of the risk could result in a reduction in the efficiency of the procedure or function to which it is associated, requiring a review of the procedure itself. This is an internal impact, with procedural implications for the entity or organization.
- Medium - The occurrence of the risk could result in a reduction in the efficiency and effectiveness of the procedure or function to which it is associated, requiring a review of the procedure and the corresponding objectives associated with it. This is an internal impact, with implications for the process and production of the entity or organization.
- High - The occurrence of the risk may result in a reduction in the efficiency and effectiveness of the procedure or function to which it is associated and may be the subject of media coverage. This is an impact with internal implications at the procedural and production level of the entity or organization, and with external implications, media coverage of the occurrence, with reputational impacts on its credibility.

As for the probability of the risk occurring indicator, which is mainly associated with the existence of preventive measures and the history of their effectiveness, it can be measured on a scale with three positions - low, medium and high, according to the following table and the explanatory considerations it contains:

- Low - Risk prevention is adequately based on the preventive/corrective measures adopted previously.
- Medium - Adequate risk prevention may require and justify additional preventive measures to those already in place.
- High - Adequate risk prevention requires additional corrective measures to those already in place.

On the other hand, the treatment to be implemented has also been considered according to the degree of risk that may be determined in each of the situations listed below: