This Code of Conduct is intended to establish the principles and standards of Extrunorte, Lda., while also complying with the requirement set forth in subparagraph k), paragraph 1 of Article 127 of the Labor Code, introduced by Law No. 73/2017 of August 16, which stipulates that “the employer must adopt codes of good conduct to prevent and combat harassment in the workplace whenever the company has seven or more employees.”

1. Scope and Purpose

1. a) This Code of Conduct applies to all employees of Extrunorte, Lda., as well as to all individuals and companies that provide services to the company on a permanent or occasional basis.
2. b) The Code of Conduct is intended to formalize the company’s approach to guiding the day-to-day conduct of its employees in the workplace, as well as to prevent and combat harassment in the workplace.

2. General Principles/Standards

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

1. a) Conduct their business with integrity and professionalism, respecting the company’s values, principles, and internal procedures, as well as applicable laws in all aspects of their work;
2. b) Take responsibility for one’s actions at all times, demonstrate dedication in carrying out the tasks entrusted to one, and continuously seek to improve and update one’s professional knowledge and skills;
3. c) Maintain a relationship of complete and total trust among colleagues, the company, and partners;
4. d) Maintain and foster proper relationships and cordial conduct with one another, in order to develop a strong spirit of cooperation and cohesion, applying all their abilities to carry out the tasks entrusted to them and acting with loyalty toward the company and their fellow employees;

5. e) Respect the inherent value of every individual, regardless of gender, marital status, education, physical or mental disability, caste, nationality, race, religion, sexual orientation, political or union affiliation, or beliefs;
6. f) Promote a respectful and safe environment in every workplace, free from discrimination and harassment of any kind;
7. g) Conduct oneself with honesty and dedication at all times in the course of one’s work, and honor one’s commitments to fellow employees, supervisors, and the company itself, striving to uphold its reputation, professionalism, and credibility, and always acting in accordance with the law;
8. h) Perform their duties with diligence and efficiency, scrupulously adhering to the responsibilities and duties required of them by their superiors, and being accountable to them for any failure to comply with such responsibilities and duties;

3. Harassment

a) Harassment of any kind (psychological or sexual) is prohibited, whether it occurs in the workplace or outside of it but for reasons related to the workplace, and whether it is committed by an employee, an employer or the employer’s representative, a service provider, or a third party.

b) According to Article 29(2) of the Labor Code, “harassment is defined as unwanted conduct, particularly that based on a ground of discrimination, occurring in the context of access to employment or in the workplace, at work, or during 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) Sexual harassment is defined as unwanted conduct of a sexual nature, whether verbal, nonverbal, or physical.

d) By way of example only, the following behaviors shall be considered harassment:

1. Deterioration of working conditions: failing to provide information necessary to perform tasks; criticizing an employee’s work unfairly or excessively; denying access to work tools; assigning tasks that exceed an employee’s skills; assigning tasks that are incompatible with an employee’s health; leading an employee to make mistakes.
2. Isolation and refusal to communicate: superiors and coworkers do not speak to the person; communication with them is solely in writing; they are kept separate from others; coworkers are forbidden from speaking to them.

3. Attacks on her dignity: they use disparaging remarks to describe her; they make gestures of contempt in her presence (sighs, scornful glances, shrugging); she is discredited in front of colleagues, superiors, or subordinates; they mock her physical disabilities or her physical appearance; she is imitated or caricatured; they criticize her private life; they mock her background or nationality; they make fun of her religious beliefs or political convictions; they assign her humiliating tasks; she is insulted with obscene or degrading language.
4. Verbal, physical, or sexual violence: threats of physical violence; they physically assault her, even if only slightly; they do not take her health issues into account; she is sexually harassed or assaulted (through gestures or propositions).

4. Complaint

1. a) Employees must report any behavior that violates this Code of Conduct, including instances of workplace harassment.
2. b) Reporting or testifying regarding violations of this code or instances of harassment does not subject the reporter or witness to disciplinary, judicial, or administrative liability, unless they act with intent.
3. c) The employer is required to initiate disciplinary proceedings whenever it becomes aware of alleged instances of workplace harassment, against the person or persons accused of harassment, under penalty of committing a serious administrative offense.
4. d) The entire procedure will follow legal channels, be handled fairly, and ensure that the individual subject to disciplinary proceedings for harassment has the right to a fair hearing.

5. Civil and Administrative Liability

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

2. b) A victim of harassment is entitled to compensation for pecuniary and non-pecuniary damages.
3. c) The employer is liable for damages arising from occupational diseases resulting from harassment.
4. d) In turn, Social Security is responsible for paying such damages and is subrogated to the employee’s rights to the extent of the payments made, plus any accruing interest on late payments.

6. Termination / Termination of the Contract

7. Whistleblower Protection Policy

a) Extrunorte, Lda. has established an internal reporting channel to enable all employees, service providers, subcontractors, members of the management and supervisory bodies, volunteers, and interns—whether paid or unpaid—to report possible violations of European Union law, grantingthem the status of whistleblowers and, upon granting this status, ensuring that they, as well as any third parties identified in their reports, receive adequate protection, in the form of security, secrecy, confidentiality of identity, or anonymity, as provided by Extrunorte, Lda.

b) To reinforce these guarantees, Extrunorte, Lda. ensures that the aforementioned whistleblowers and third parties identified in the respective reports are protected from access to the reports by persons not authorized for that purpose, and undertakes to adopt the appropriate procedures to that end. Extrunorte, Lda. further guarantees whistleblowers the right to be informed of the progress of their reports, unless a whistleblower expressly requests otherwise or such disclosure could compromise the protection of their identity.

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

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

a) Extrunorte, Lda. has implemented an Anti-Money Laundering and Counter-Terrorist Financing Policy (AML/CTF Policy), which applies directly to all employees, service providers, subcontractors, management, volunteers, and interns—whether paid or unpaid—of Extrunorte, Lda.

b) This policy establishes mechanisms for reporting situations or suspicions of BCFT within Extrunorte, Lda., and creates the role of BCFT Officer, who, in coordination with management, ensures compliance with procedures and the proper assessment of BCFT risks, including the performance of due diligence activities resulting from monitoring systems, filtering platforms, or any other BCFT controls.

c) Extrunorte, Lda. will also implement a Training Plan, featuring a structured training program applicable to all its employees to ensure that their knowledge is kept up to date and to address the specific needs of the various lines of defense, as well as standards and technical documentation regarding BCFT controls – A set of up-to-date documents describing all the configurations and characteristics of the processes and controls that lead to the prevention and management of BCFT risks.

9. Term / Disclosure

a) This code of conduct is in effect for an indefinite period and takes effect on the date operations begin; all employees and other interested parties have been made aware of its contents.