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SUMOL+COMPAL Code of Conduct

INTRODUCTION
Realising SUMOL+COMPAL’s Vision and Winning Aspiration means employees must adopt impeccable behaviour, fulfilling the principles set out in this Code of Conduct.
 SUMOL+COMPAL’s stance in the market is one of a culture of respect which contributes significantly to its good reputation amongst employees, consumers, clients, suppliers and other stakeholders. This is a distinguishing feature of SUMOL+COMPAL which generates trust and value.
 SUMOL+COMPAL’s reputation is built and sustained by its employees both individually and collectively so they must commit to rigorous compliance with the principles, practices and rules in this Code.
 This Code therefore aims to clarify and contribute to disseminating the principles which should frame the behaviour of SUMOL+COMPAL’s employees and the practices and rules stemming from them.
 Committed compliance is absolutely essential and must apply across the board.
 SUMOL+COMPAL aims to ensure that these principles, practices and rules are divulged and explained and to guarantee they are complied with by all company employees. However, the main responsibility for complying with the Code of Conduct belongs to each and every one of us.

 

SCOPE OF APPLICATION
This Code of Conduct is intended for all SUMOL+COMPAL employees.
By “SUMOL+COMPAL” is meant all of the businesses that fall within the scope of consolidation of SUMOL+COMPAL, S.A.
In this Code, “employees” is deemed to signify the members of the governing bodies, workers, those who have signed a service provision agreement with the company, and all those who, at any time, act in the name of or on behalf of SUMOL+COMPAL.
 

 

OBJECTIVES OF THE CODE OF CONDUCT
The Code of Conduct aims to identify a set of principles, rules and practices that must be observed by all employees.
The Code of Conduct aims to ensure appropriate professional and relational behaviour and is designed to:

  • Clarify the practices and rules of conduct all employees must comply with in their relationships between themselves and with any stakeholders;
  • Strengthen the trust in SUMOL+COMPAL’s principles and mode of operation by all those with whom it deals;
  • Guarantee SUMOL+COMPAL’s good reputation.

 

 

PRINCIPLES
The following principles are especially important to SUMOL+COMPAL:
Professionalism: applying the necessary skills and effort to fulfil the tasks entrusted to each employee. Seeking to update and develop skills to improve professional abilities. Respecting others and leading by example;
Integrity: acting honestly, abstaining from seeking or accepting from third parties any compensation, favour or advantage for actions taken in the service of SUMOL+COMPAL and informing society of any situations in which there is, or may be, a conflict of interests [1] , withdrawing oneself whenever said conflict jeopardises protection of the company’s interests;
Independence: protecting SUMOL+COMPAL’s interests with impartiality with regard to third parties;
Good faith: acting in a trustworthy, appropriate, fair and collaborative manner with internal and external agents;
Non-discrimination: ensuring no discrimination with regard to race, gender, sexual orientation, creed, marital status, disability, political opinion, ethnic or social background, place of birth or other;
Responsibility: acting in line with the responsibilities and autonomy assigned. Protecting and preserving SUMOL+COMPAL’s assets through sensible and careful use of resources;
Confidentiality: maintaining the confidentiality of all information accessed by employees while completing their duties and ensuring said information is not used to obtain advantages for themselves or third parties;
Non-competition: ensuring no direct or indirect involvement in activities that compete with those of SUMOL+COMPAL;
Loyalty: safeguarding SUMOL+COMPAL’s good image, credibility and prestige and those of its brands in all situations;
Legality: complying at all times with the law and applicable regulations;
Non-harassment: preventing and combating all forms of workplace harassment.

 

[1] A conflict of interest is understood to exist when an employee is asked to intervene in assessing, deciding on and executing business in which there is a direct or indirect interest by i) the employee themselves, ii) any individual to which the employee is connected through links of kinship or affinity of any kind, iii) businesses in which any one of them, either directly or indirectly, has a relevant interest, or iv) anyone with whom the employee has relations that are liable to affect their impartiality and the protection of SUMOL+COMPAL’s interests.

 

 

 

APPLICATION OF 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 way in particular:

COMPANY

  • Adopt behaviour that does not cause any patrimonial or non-patrimonial damage to the company, especially if it may affect the company’s good name.
  • Act in the best interests of SUMOL+COMPAL at all times and not in the interests of individuals or departments.
  • Attend training, which SUMOL+COMPAL regards as compulsory.
  • Declare any potential conflict of interest in writing in advance to the head of the Legal and Compliance Department. A conflict of interest is not necessarily a violation of the code, but non-disclosure is. Whenever Compliance considers that this conflict prevents an employee from acting solely in the interests of the company, the employee must withdraw him/herself.
  • Keep all information to which they have access while performing their respective duties confidential. All relevant information must be kept absolutely confidential.
  • Use company resources appropriately with no altering, falsifying or limiting of information to benefit the employee or third parties.
  • Ensure SUMOL+COMPAL’s brands and other intellectual property rights are protected, as well as any other assets.
  • Use any means of company communication (namely email and telephone) and all information systems responsibly.

 

SHAREHOLDERS AND OTHER INVESTORS

  • Act at all times to safeguard the interests of all shareholders.
  • Ensure the thoroughness and accuracy of the information made available to shareholders and other investors, and in real time.

 

EMPLOYEES

  • Foster a good working environment in which relations with colleagues are governed by cordiality, friendliness and a lack of discrimination or harassment of any kind regardless of hierarchy.
  • Develop and maintain an open and frank dialogue in dispute resolution with total respect for different opinions.
  • Not work under the influence of any substance that may represent a security risk for the employee or third parties.
  • Not accept and expose the use of child and/or forced labour, as well as all other forms of abusive working practices in any organisation with which SUMOL+COMPAL has relations.

 

COMMUNITIES

  • Assure the transparency and accuracy of the information made available.
  • Adopt practices to foster wellbeing in collaboration with relevant institutions in the communities.
  • Maintain a relationship of cooperation with educational institutions, fostering SUMOL+COMPAL’s greater visibility and appeal with students and helping to draw these bodies and the companies together.

 

CLIENTS

  • Treat clients with professionalism, respect, openness and loyalty under conditions of equality and without any type of discrimination, namely in providing information and handling complaints.

 

SUPPLIERS

  • Maintain a healthy partnership with suppliers based on good professionalism and respect, fulfilling commitments established at all times.
  • Select suppliers based on criteria of impartiality and without any type of discrimination, but prioritising those governed by ethical principles equivalent to those used by SUMOL+COMPAL.

 

FINANCIAL BODIES

  • Foster a fair and frank relationship with financial bodies, ensuring the thoroughness and accuracy of the information provided.

 

CONSUMERS

  • Provide accurate information about the company and its brands at all times.
  • Adopt responsible marketing practices.

 

GOVERNMENTAL, REGULATORY AND SECTORAL BODIES

  • Collaborate, under the terms of the law, with governmental and regulatory bodies in response to requests and not adopt any behaviour that may hinder these authorities from exercising their powers.
  • Cooperate closely with associations to defend the interests of the sector in which SUMOL+COMPAL operates.
  • 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 competitors’ intellectual property rights.
  • Comply with competition laws and respect SUMOL+COMPAL’s Competition Policy at all times.

 

MEDIA

  • Any declarations to the media are the sole responsibility of the communications department, except where necessary or convenient for exercising a duty.
  • Guarantee the truth and legitimate interests and rights of SUMOL+COMPAL in any communication.

 

 

 

OTHER IMPORTANT AREAS

DOCUMENTS AND REGISTERS

  • Maintain accurate and full registers of all the commitments conferring rights and/or obligations on SUMOL+COMPAL.
  • SUMOL+COMPAL’s archive of documents and registers must ensure the confidentiality, integrity and accessibility of these documents.

 

NON-CORRUPTION

  • All employees are absolutely forbidden to undertake any actions in which they, either individually or through another person (via their consent or ratification):
  • a) request or accept, for themselves or for a third party (including for SUMOL+COMPAL),
  • b) give or promise undue patrimonial or non-patrimonial advantage, or promise thereof, from any act or omission that constitutes a violation of their professional duties.

 

GIFTS, INVITATIONS AND OTHER BENEFITS

  • Any gift or invitation accepted by an employee worth more than an estimated amount of €150 (either from a single gift or from various accumulated gifts from a body over a period of twelve months) must be approved in writing by the member of the Executive Board responsible for the operating area/executive officer, who, should an Executive Board exist, must inform the chair of the same board of their decision in writing. The procedure applicable to any gift or invitation made to the directors is set out in the Regulations of the Board of Directors.

 

PROCESSING OF PERSONAL DATA

  • SUMOL+COMPAL takes the privacy of its employees and third parties very seriously. Consequently, an Employee Data Protection Policy and Privacy Policy (for clients, suppliers and users of various websites) have been established to regulate the use of personal data created within SUMOL+COMPAL’s activities, establishing and maintaining a certain level of data protection in line with the applicable legal provisions, as well as the needs and expectations of all stakeholders.
  • SUMOL+COMPAL refers its employees and any third parties to the aforementioned policies.

 

ANTI-MONEY LAUNDERING AND ANTI-TERRORISM

  • Any business with third parties involving the movement of money whose source may not be legitimate or legal must be carefully analysed. These cases must be handled lawfully.

 

 

 

CLARIFICATION AND DISCLOSURE
The Code of Conduct will be provided to all employees and will be available on the company website and intranet.
Training on the Code of Conduct will be held. Unjustified absence from this training may infringe the Code and result in disciplinary action and/or impact an employee’s performance assessment. Under no circumstances may a lack of familiarity with the content of the Code of Conduct justify non-compliance.


Whenever doubts exist about the correct interpretation of the Code of Conduct, they should be addressed to the Compliance Department. Employees are responsible for asking questions and raising doubts when they exist.
Employees must also report any practices and actions they consider breach, or which they suspect may breach, SUMOL+COMPAL’s principles, as well as the legal rules or other commitments accepted by the company.


Any communications must be addressed directly to the head of the Legal and Compliance Department:

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

Complaints may be made anonymously but always with sufficient detail so that the issue may be duly and rapidly clarified by SUMOL+COMPAL.
 

 

INVESTIGATIONS AND SANCTIONS
All complaints suggesting irregularities will be investigated. Employees who make complaints in good faith will not suffer any consequences.
Infringement of the Code, our policies or the law may result in disciplinary action.