Compliance Programme

Seasonalpha LDA – Engenharia e Construções, S.A. has implemented a compliance or conformity management programme, which is mandatory for all employees.

The compliance establishes a set of measures and procedures based on the Compliance Policy, the Code of Ethics and Conduct and the Mission and Values of Seasonalpha LDA, aimed at being able to more effectively demonstrate compliance with the law and internal standards, thereby contributing to a climate of integrity and ethical culture during the course of the Company’s activities.

The compliance system includes risk assessment processes and financial and non-financial internal control procedures.

Combating corruption and bribery, money laundering and terrorism financing

The compliance system also ensures the implementation and assessment of the effectiveness of the Code of Ethics and Conduct, according to which employees must act in order to assess and avoid possible conflict of interest situations, as well as to actively or passively prevent any corrupt behaviour, including facilitation payments or gifts, or the creation, maintenance or promise of irregular situations or favours.

They shall be obliged to report any information that constitutes misconduct, including those that constitute possible illegal or illicit practices in financial and accounting matters, fraud, corruption and money laundering, as well as any actions related, directly or indirectly, to terrorist entities or those that may target or support terrorist practices.

Everybody is also responsible for ensuring that indirect recipients of code also do so.

Employees must act in a manner that actively combats possible attempts at money laundering, refusing to participate in any act that as such may be considered, under current legal and regulatory standards, as well as in any attempt, complicity, facilitation or advice to carry it out.

Similarly, employees must also take actions to prevent the Group’s activity from being able to supply, collect or hold funds or assets in any way that could be used for financing and supporting criminal activities, specifically terrorists.

Relationship with the Competition

Competition is a natural and healthy market consequence that promotes business excellence and efficiency. In this sense, Employees must adopt a true and committed attitude towards the Company’s and the Group’s competitors, always in accordance with the law and applicable internal rules.

Employees must therefore assume – and encourage all Recipients of this Code to also assume – a commitment to scrupulously respect the market and competition rules, acting in a serious and loyal manner, avoiding restrictive practices or abuses of a dominant position, and must ensure that the Company interacts with the competing entities in a healthy manner, in good faith and that promotes mutual respect.