The purpose of this Code of Conduct is to establish the principles and standards of the company Extrunorte, Lda. and also to comply with the obligation contained in Article 127(1)(k) of the Labor Code, introduced by Law 73/2017 of August 16, which stipulates that "the employer must adopt codes of good conduct for preventing and combating harassment at work, whenever the company has seven or more employees".

1. Scope and objective

1. a) This Code of Conduct applies to all Extrunorte, Lda. employees, and to all persons and companies that provide services to Extrunorte, Lda. on a permanent or occasional basis.
2. b) The purpose of the Code of Conduct is to formalize the company's actions in guiding the daily conduct of its employees in the workplace, as well as preventing and combating harassment in the workplace.

2. General Principles/Norms

Employees of Extrunorte, Lda., in the performance of their duties, activities and competencies, must conduct themselves in accordance with the following rules:

1. a) Carry out its activity with integrity and professionalism, respecting the values, principles and internal procedures, as well as the legislation in force in all aspects of the activity;
2. b) Taking responsibility for their actions at all times, showing dedication in carrying out the tasks entrusted to them and continually seeking to improve and update their professional knowledge and skills;
3. c) Maintain a relationship of full and total trust between colleagues, the company and partners;
4. d) Maintain and cultivate a correct relationship and cordial conduct among themselves, in order to develop a strong spirit of cooperation and cohesion, using all their skills in carrying out the actions entrusted to them and using loyalty to the company and to the rest of their colleagues;

5. e) Respect the inherent value of each individual regardless of their sex, marital status, education, physical or mental disability, caste, nationality, race, religion, sexual orientation, political or trade union conviction or affiliation;
6. f) Promote a respectful and safe environment in every workplace, free from discrimination and harassment of any kind;
7. g) To behave honestly and with dedication at all times in their work and to respect their commitments to other employees, superiors and the company itself, striving to safeguard its prestige, professionalism and credibility, and always acting in accordance with the law;
8. h) Carrying out their duties with zeal and efficiency, scrupulously respecting the responsibilities and duties required of them by the hierarchy, and being accountable to the hierarchy for any failure to respect them;

3. Harassment

a) Harassment of any kind (moral or sexual), in the workplace or outside it, but for reasons related to it, by employees, employers or their representatives, service providers or third parties, is prohibited.

b) According to Article 29(2) of the Labor Code, "harassment is defined as unwanted behavior, in particular that based on discrimination, practiced at the time of access to employment or in employment, work or vocational training, with the purpose or effect of disturbing or embarrassing the person, affecting their dignity, or creating an intimidating, hostile, degrading, humiliating or destabilizing environment".

c) Unwanted verbal, non-verbal or physical behavior of a sexual nature constitutes sexual harassment.

d) By way of example, the following attitudes will be considered harassment:

1. Deterioration of working conditions: not passing on useful information to carry out tasks; criticizing their work unfairly or excessively; depriving them of access to work tools; giving them tasks that are beyond their competence; giving them tasks that are incompatible with their health; misleading them.
2. Isolation and refusal to communicate: superiors and colleagues do not talk to the person; communication with them is only in writing; they are kept apart from others; colleagues are forbidden to speak to them.

3. An attack on dignity: they use dismissive insinuations to qualify her; they make contemptuous gestures towards her (sighs, dismissive looks, raising of shoulders); she is discredited in front of colleagues, superiors or subordinates; they make fun of her physical disabilities or her physical appearance; she is imitated or caricatured; they criticize her private life; they make fun of her origins or her nationality; they pick on her religious beliefs or political convictions; they assign her humiliating tasks; she is insulted with obscene or degrading terms.
4. Verbal, physical or sexual violence: threats of physical violence; they physically assault her, even lightly; they don't take her health problems into account; she is harassed or sexually assaulted (gestures or proposals).

4. Complaints

1. a) Employees must report any behavior that conflicts with this Code of Conduct, including situations of harassment in the workplace.
2. b) Reporting or witnessing non-compliance with this code and situations of harassment does not constitute the complainant or witness liable for disciplinary, judicial or administrative offenses, unless they act intentionally.
3. c) The employer has a duty to initiate disciplinary proceedings whenever it becomes aware of alleged harassment at work, against the person or persons accused of harassment, under penalty of committing a serious administrative offense.
4. d) The entire procedure will be carried out in accordance with the law and will be dealt with fairly, with the target of the disciplinary procedure for harassment having the right to an adversarial hearing.

5. Civil and administrative liability

a) Harassment is a very serious offense, without prejudice to any criminal liability the perpetrator may incur.

2. b) The victim of harassment is entitled to compensation for pecuniary and non-pecuniary damage.
3. c) The employer is liable for damages arising from occupational illnesses resulting from harassment.
4. d) In turn, Social Security is responsible for the payment of said damages, and the latter is subrogated to the employee's rights, to the extent of the payments made, plus interest on arrears.

6. dismissal / termination of contract

7. Whistleblower Protection Policy

a) Extrunorte, Lda. has created an internal whistleblowing channel so that all employees, service providers, subcontractors, members of the management and supervisory bodies, volunteers and trainees, whether paid or unpaid, can report possible infringements of European Union law, granting them the status of whistleblowers and, by granting this status, guaranteeing them, as well as third parties identified in the respective reports, adequate protection, materialized in the conditions of security, secrecy, confidentiality of identity or anonymity that Extrunorte, Lda. grants them.

b) In order to reinforce these guarantees, Extrunorte, Lda. guarantees the aforementioned whistleblowers and third parties identified in the respective complaints that access to the complaints made by persons not authorized for this purpose will be prevented, and undertakes to adopt the appropriate procedures for this purpose. Extrunorte, Lda. also guarantees complainants the right to know how their complaints are being processed, unless any complainant expressly requests otherwise or this knowledge may compromise the protection of their identity.

c) The e-mail address to which complaints should be sent is: canaldedenuncia@extrunorte.pt

8. Policy for Preventing and Combating Money Laundering and Terrorist Financing

a) Extrunorte, Lda. has implemented a Money Laundering and Terrorist Financing Prevention Policy (BCFT Policy), which is directly applicable to all Extrunorte, Lda. employees, service providers, subcontractors, management, volunteers and trainees, whether paid or unpaid.

b) This policy creates mechanisms for reporting situations/suspicions of BCFT within Extrunorte, Lda., as well as creating the figure of the BCFT officer, who, in coordination with management, ensures compliance with procedures and the correct assessment of BCFT risks, including carrying out due diligence activities resulting from monitoring systems, filtering platforms or any other BCFT controls.

c) Extrunorte, Lda. will also ensure a Training Plan, with a structured training program, applicable to all its employees to ensure the renewal of knowledge and respond to the specific needs of the different lines of defense, as well as standards and technical documentation on BCFT controls - A set of up-to-date documents that describe all the configurations and characteristics of the processes and controls that lead to the prevention and management of BCFT risks.

9. Validity / Disclosure

a) This code of good conduct shall be applied for an indefinite period of time and shall come into force on the date of commencement of activity, and its contents shall have been made known to all employees and other interested parties.