1. What is the Code of Ethics and Business Conduct?
The Code of Ethics and Business Conduct is the corporate document that defines the mission, values, and commitments undertaken by the Proef Group within the scope of its business activity and its relationship with employees, shareholders, members of corporate bodies, clients, suppliers, subcontractors, and other partners.
The Code of Ethics and Business Conduct is the centrepiece of Proef's Ethics & Compliance Program, in greater detail and supported by associated policies, procedures, and internal regulations.
2. What will you find in the Code of Ethics and Business Conduct?
In the Code of Ethics and Business Conduct employees shall find the values and rules of conduct to adopt as professionals of the Proef Group, always returning to the Code of Ethics and Business Conduct whenever they have doubts about what "they may or may not do" or "how they should or should not act" in specific situations.
The Proef Group's Code of Ethics and Business Conduct contains, for example, rules about the use of Proef's media, electronic equipment and assets, conflicts of interest, privacy, protection of confidential information and trade secrets, relationships amongst employees, with third parties, and/or with suppliers.
3. To whom does the Code of Ethics and Business Conduct apply?
The Proef Group's Code of Ethics and Business Conduct applies to members of the governing bodies and to all employees of the Proef Group, regardless of their employment relationship and the country where they are located, including interns or service providers whom, by the nature of their responsibilities, act on behalf of the Proef Group and/or on its premises.
The Code of Ethics and Business Conduct also applies to consultants, agents, representatives, partners or any other persons who represent and/or act in the name of and on behalf of any company part of the Proef Group or to it related.
4. Where can you find the Code of Ethics and Business Conduct?
The Code of Ethics and Business Conduct may be consulted at any time on the Employee Portal in Portuguese, English, German, and French.
5. Who’s in charge of the Code of Ethics and Business Conduct?
All Proef Group employees are responsible for the proper observance and dissemination of the Code of Ethics and Business Conduct.
Notwithstanding, the Proef Group has appointed a Compliance Officer who’s responsible for the day-to-day monitoring of the Ethics & Compliance Program and, specifically, the Code of Ethics and Business Conduct. The Compliance Officer can be contacted at any time at the following e-mail address:
compliance@proef.com
In turn, the Proef Group also relies on the help of the Ethics Committee, made up mostly of external members, to ensure and supervise, in an independent and impartial manner, the definite application of the Code of Ethics and Business Conduct.
6. Who should you contact in case of questions about the Code of Ethics and Business Conduct or about what to do in a given situation?
Employees, clients, suppliers, partners, shareholders, and other stakeholders who have questions about the standards, policies or procedures related to the matters addressed in the Code of Ethics and Business Conduct can contact, at any time:
The Proef Group Ethics Line, via the platform [put link] or by letter placed in the physical mailboxes made available at Proef's facilities;
The Compliance Officer, via the email address compliance@proef.com; or
The immediate hierarchy, via any means of communication available.
7. To whom can you turn if you become aware of any violation of the Code of Ethics and Business Conduct?
In case of becoming aware of a violation or suspected violation of the standards contained in the Code of Ethics and Business Conduct and/or the associated regulations, policies, and procedures, employees and partners should immediately report the situation or raise their concerns before the Proef Group Ethics Line, via:
Platform;
Email address;
Letter placed in the physical mailboxes made available at the Trofa, Porto, Lisbon, Paris, Hamburg, and Luanda facilities.
Reporting can be done confidentially and anonymously. The Proef Group guarantees that no report or request for clarification will go unanswered, and furthermore, that the whistle-blower will not be subject to reprisals.
8. What is the Ethics Line?
The Ethics Line is a channel for reporting irregularities and clarifying doubts made available by the Proef Group to its employees, suppliers, partners, and members of corporate bodies located in the different countries where the Group operates. The Ethics Line is operated by an external entity that guarantees not only anonymity, when requested and within the limits allowed by the law, but also independence and impartiality in dealing with the issues raised.
The Proef Group takes on the legal commitment of non-retaliation. However, the Ethics Line should always be used responsibly and in good faith, and slanderous reports or comments of illicit content or in breach of public order will not be tolerated.
9. What happens in case of violation of the Code of Ethics and Business Conduct?
The violation of the Code of Ethics and Business Conduct constitutes a disciplinary infraction by the defaulting employee, punishable under the terms of the applicable labour legislation, or a contractual violation, determining the immediate and legitimate termination of the contract entered into, as the case may be.
