Reports and Codes

INTRODUCTION

To ensure the success of Sumol Compal’s Vision and Winning Aspiration, the behaviour of the company’s employees must be irreproachable, in line with the principles set out in this Code of Conduct. ​
  In its approach to the market, Sumol Compal believes in a culture of respect, which relates closely to its good reputation among employees, consumers, clients, suppliers and other stakeholders. This element, which generates trust and value, is distinctive to Sumol Compal. ​
  Sumol Compal’s reputation is built on and maintained through its employees, both individually and collectively. Consequently, they must strive to comply rigorously with the principles, practices and rules set out in this Code.
  This Code therefore aims to clarify and contribute to spreading the principles which should frame the behaviour of Sumol Compal employees and the ensuing practices and rules. ​
  The commitment to comply is indispensable and must apply to everyone. ​
  Sumol Compal aims to ensure that these principles, practices and rules are communicated and explained and to promote the compliance thereof by all employees working within the organisation. However, the greatest responsibility for complying with the Code of Conduct belongs to each and every one of us.
 

SCOPE OF APPLICATION

This Code of Conduct applies to all Sumol Compal employees.
By “Sumol+Compal” is understood to mean each of the companies or the companies as a whole which comprise the consolidated interests of Sumol+Compal, S.A..
In this Code, by “employees” is meant the members of the governing bodies, workers, those who have signed a provision of service contract with the company and all those who, at any particular moment, act in the name or on behalf of Sumol Compal.
 

AIM OF THE CODE OF CONDUCT

The aim of the Code of Conduct is to identify a set of principles, rules and practices that all employees must observe.
The Code of Conduct aims to ensure suitable professional and relational behaviour and intends to:

• Stipulate clearly which practices and rules of conduct all employees must follow in their relations between each other and with stakeholders;
• Boost trust in the principles and actions of Sumol Compal among those with whom it deals;
• Ensure Sumol Compal’s good reputation.
   

PRINCIPLES

The following principles are of particular importance to Sumol Compal:
Professionalism: Applying the skills and effort necessary to comply with the tasks entrusted to each employee. Seeking to update and develop skills with a view to improving professional capacities. Respecting others and leading by example.
Integrity: Acting with honesty, abstaining from seeking or accepting from third parties any reward, favour or advantage when working for Sumol Compal and notifying the company of any situations where there is, or may be, a conflict of interests,1 refusing involvement whenever this conflict does not allow the company’s interests to be defended;
Independence: Defending Sumol Compal’s interests impartially with regard to third parties;
Good will: Acting confidently, correctly, loyally and cooperatively towards inhouse and external partners;
Non-discrimination: Practising non-discrimination on the basis of race, genre, sexual orientation, creed, marital status, physical disability, political leanings or opinion, ethnic and social origins, birth or other;
Responsibility: Acting in correspondence with the responsibility and autonomy granted. Protecting and preserving Sumol Compal property by using resources sensibly and carefully;
Confidentiality: Not disclosing information which an employee may have access to as a result of their duties and declining to use said information to obtain benefits for themselves or third parties;
Non-competition: Not engaging, directly or indirectly, in activities that compete with those of Sumol Compal;
Loyalty: Safeguarding Sumol Compal’s good image, credibility and prestige, and those of its brands, at all times;
Legality: Always acting in compliance with the law and the regulations applicable;
Non-harassment: Promoting the prevention of all forms of workplace harassment.

[1] A conflict of interests is considered to exist when an employee is involved in assessing, deciding upon or executing business in which a direct or indirect interest is held by i) he or she, ii) any individual to whom i) is related through ties of parentage or affinity, iii) companies which have either a relevant direct or indirect interest, or iv) people with whom the employee has any relationship that may affect his or her ability to act in defence of the interests of Sumol Compal.
 

APPLYING SUMOL COMPAL’S PRINCIPLES IN RELATIONS WITH THE COMPANY AND STAKEHOLDERS
All employees must apply Sumol Compal’s principles in their relations with the company and stakeholders in the following manner:

COMPANY

• All employees must adopt behaviour that does not cause any patrimonial or non-patrimonial damage to the company, specifically as regards affecting its good name.
• All employees are obliged to act at all times in Sumol Compal’s best interests and not on behalf of individual, sectoral or departmental interests.
• Employees must attend all training considered compulsory by Sumol Compal.
• Any potential conflict of interests must be communicated in advance and in writing to the head of the Legal and Compliance Department. A conflict of interests does not necessarily breach the code, but a failure to notify does. Whenever the Compliance Department deems a conflict to affect an employee’s ability to act exclusively in the company’s interests, the employee must excuse themselves from the case.
• Information to which you have access when carrying out your duties must not be disclosed. All relevant information must be kept absolutely confidential.
• Company resources must always be used appropriately and information must not be altered, falsified or limited for the benefit of the employee or a third party.
• Sumol Compal brands and other intellectual property rights, as well as any other assets, must be protected.
• Company communication resources (namely email and telephone) and all of its information systems must be used responsibly.
   

SHAREHOLDERS AND OTHER INVESTORS

• Always act in such a way as to safeguard the interests of all shareholders.
• Ensure all information provided to shareholders and other investors is thorough and accurate and supplied in a timely manner.
   

EMPLOYEES

• Foster a good working environment, ensuring relations between colleagues, regardless of their position within the company, are cordial and free of animosity, discrimination or harassment.
• Develop and maintain open and frank dialogue when resolving disputes with total respect for different opinions.
• Do not work under the influence of any substances that might represent a risk to the safety of employees or third parties.
• Expose and refuse to accept the use of child and/or forced labour, or any other forms of exploitative labour, by any entity Sumol Compal has relations with.
   

COMMUNITIES

• Ensure the transparency and accuracy of the information provided.
• Adopt practices that promote well-being in collaboration with relevant community institutions.
• Maintain cooperative relations with educational institutions, promoting the greater visibility and attractiveness of Sumol Compal among students and contributing to increasing the proximity between these institutions and the companies.
   

CLIENTS

• Treat clients with professionalism, respect, honesty and loyalty in equal conditions and without discrimination, namely when providing information and handling complaints.
   

SUPPLIERS

• Maintain a heathy partnership with suppliers based on professionalism and respect, complying fully with the commitments made.
• Select suppliers based on the criteria of impartiality and non-discrimination, favouring those governed by ethical principles equivalent to those applied by Sumol Compal.
   

FINANCIAL ENTITIES

• Promote fair and honest relations with financial entities, ensuring the precision and accuracy of the information provided.
   

CONSUMERS

• Always provide true information about the brands and companies.
• Adopt responsible marketing practices.
   

GOVERNMENTAL, REGULATORY AND SECTORAL BODIES

• Collaborate, under the law, with government and regulatory bodies in response to requests received and do not adopt any behaviour that may hinder the work of the competent authorities.
• Cooperate closely with trade associations that are relevant for Sumol Compal.
• Maintain cordial relations governed by principles of exemption, impartiality, clarity and respect.
   

COMPETITORS

• Foster and practice fair competition.
• Maintain cordial institutional relations based on mutual respect.
• Respect the intellectual property rights of competitors.
• Always comply with competition laws and respect Sumol Compal’s Competitions Policy.
   

MEDIA ORGANISATIONS

• The press department is responsible for all statements to the media, except when these are necessary or convenient for occupational execution.
• Ensure all communications are true and guarantee all of Sumol Compal’s legitimate interests and rights.
   

OTHER HIGHLY RELEVANT THEMES

DOCUMENTS AND RECORDS

• True and complete records must be kept of all commitments resulting in rights and/or obligations for Sumol Compal.
• Sumol Compal’s archive of documents and records must be organised so as to ensure their confidentiality, integrity and accessibility.
   

NON-CORRUPTION

• All employees are completely forbidden to take any action whereby they, alone or via an intermediary (through their consent or ratification),
  a) request or accept, for themselves or for a third party (including for Sumol Compal), or
  b) give or pledge
  undue or promised patrimonial or non-patrimonial benefits for any act or omission constituting a violation of their occupational duties.
• Sumol Compal has approved and applies a Risk of Corruption Prevention Plan that sets out Sumol Compal’s anti-corruption principles and strategy, as well as the risks and preventive measures in force.
   

GIFTS, INVITATIONS AND OTHER BENEFITS

• No employee may accept any gift or invitation worth more than €150 (whether it be a single gift or accumulated gifts from one organisation over a period of twelve months) without approval in writing by the responsible member of the Executive Board or CEO who, if an Executive Board exists, must inform the chair of said Board of his/her decision in writing. The procedure applicable to any gift or invitation to the directors is set out in the Regulation of the Board of Directors.
   

HANDLING OF PERSONAL DATA

• The privacy of its employees and third parties is very important to Sumol Compal. Accordingly, it has adopted an Employee Data Protection Policy, Personal Data Handling Manual and Privacy Policy (for clients, suppliers and users of various websites) governing the use of personal data in Sumol Compal’s activities, establishing and maintaining a certain level of data protection that complies with the applicable legal provisions, as well as the needs and expectations of all stakeholders.
• Sumol Compal requests that all employees and third parties read said policies carefully.
   

MEASURES TO FIGHT MONEY LAUNDERING AND TERRORISM

• Any dealings with third parties that involve moving quantities of money whose origins may not be legitimate or lawful must be carefully analysed. These cases must be handled in accordance with the Money-Laundering Prevention Policy.
   

CLARIFICATION AND DISSEMINATION

All employees will be supplied with the Code of Conduct, which will also be available on the company website and intranet.

Training based on this Code of Conduct will be given. Failure to attend without explanation may be considered a violation of the Code and result in disciplinary action and/or affect performance evaluation. A lack of awareness of its contents shall in no way justify non-compliance with the Code.

Whenever doubts arise concerning the correct interpretation of the Code of Conduct, they should be put to the Compliance Department. If in doubt, employees are responsible for asking questions and raising issues.

Employees must also report any practices or actions deemed to violate, or that they suspect may violate, Sumol Compal’s principles, as well as legal rules or other commitments made by the company.

All communication must be submitted directly to the head of the Legal and Compliance Department:

• by letter, care of the head of the Legal and Compliance Department, to: Rua Dr. António João Eusébio, nº 24, 2790-179 Carnaxide;
• by telephone: 00 351 935 101 061;
• by email: Compliance@sumolcompal.pt.

Complaints may be submitted anonymously but must always include sufficient detail so that the matter can be addressed by Sumol Compal in a timely and rapid manner.
 

INVESTIGATIONS AND PENALTIES

All complaints of irregular behaviour will be investigated. Employees will suffer no consequences for bona fide complaints.

Any violation of the Code, company policies or the law may result in disciplinary action.

 

Sumol Compal is a highly regarded international company which is concerned about ensuring a sustainable future in all aspects. In that sense, Sumol Compal’s suppliers are invited to subscribe to this document and to commit to the principles contained within it.

By accepting this Code, suppliers recognise that all current and future agreements, contracts and commercial relations with Sumol Compal will be subject to the provisions contained within it.

 

• Compliance with the applicable legislation and rules

In their business dealings, suppliers must comply with the applicable legislation and rules in force in all their relations with Sumol Compal.

 

• Ethics in negotiations

Sumol Compal aims to treat all suppliers fairly and expects that its suppliers demonstrate the same high ethical standards and conduct all their business transactions with integrity, accuracy and impartiality in the aim of obtaining mutual benefits.

In all their activities, suppliers may never offer or promise any personal or improper advantage, of whatever kind, to obtain or maintain a deal, benefits or advantages in exchange for the preferential treatment of Sumol Compal’s employees.

 

• Environment

O Sumol Compal’s suppliers must comply with the legislation in force, as well as comply with international environmental protection standards.

Sumol Compal’s suppliers must conduct their business in an environmentally conscious and respectful manner in an attempt to minimise the negative impacts of their operations at all times.

 

• Compliance

Sumol Compal has the right to verify, at any moment, whether its suppliers are complying with this Code, namely by means of questionnaires and audits.

Failure to comply with any of the aforementioned principles shall result in the rectification of the breach. If the rectification is not made by a determined deadline, it may lead to the cancelling of orders underway or even the termination of the contract.

It is each supplier’s responsibility to ensure that its workers and representatives are familiar with and understand this Supplier Code of Conduct and that they act in compliance with it in their relations with Sumol Compal.

 

• Workers

Sumol Compal respects human rights and in that light seeks to ensure that its suppliers comply with international standards relating to occupational health, safety and hygiene.

Sumol Compal's suppliers may not therefore make discrimination of any kind when hiring based on race, religion, gender, sexual orientation, age, disability or origin.

Suppliers must pay employees suitable wages and set hours that comply with applicable legislation, as well as, where applicable, provide suitable accommodation.

Sumol Compal is against the use of child and/or forced labour, as well as all other forms of abusive labour.

 

• Product quality and safety

All products and services provided by suppliers must comply with the quality and safety standards demanded by current legislation. Said products must also comply with the quality requirements established by Sumol Compal.

 

• Confidential/exclusive information

Suppliers must respect the intellectual property, business secrets and other confidential information obtained as a result of their relationship with Sumol Compal.