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Code of Conduct and Ethics

This Code of Conduct and Ethics establishes a set of principles, values, and rules of ethics and professional conduct, and aims to express AMG's commitment to its internal and external partners, with the objective of promoting a work environment based on respect, integrity, fairness, transparency, dialogue, and the ethical behavior of AMG and its employees.

II. SCOPE OF APPLICATION

This Code applies to all employees of AMG, regardless of their employment status, role, or hierarchical position, and must be respected in the fulfillment of daily activities.

For the purposes of interpreting this Code, AMG refers to the universe of companies that make up the BDC Group, including:

  • AMG Services, S.A., corporate entity number 510689337, located at Centro Empresarial Vilar do Pinheiro, No. 300, 4485-947 Vilar do Pinheiro, Vila do Conde;

  • D´ACCORD R&S – TEMPORARY WORK, LDA., corporate entity number 514175338, located at Centro Empresarial Vilar do Pinheiro, No. 300, 4485-947 Vilar do Pinheiro, Vila do Conde;

  • D´ACCORD HOSPITALITY SOLUTIONS, LDA., corporate entity number 517898969, located at Rotunda Edgar Cardoso, No. 23, Floor 11, G, 4400-676 Vila Nova de Gaia;

  • SOGEFIN PORTUGAL, Unipessoal Lda, corporate entity number 516257854, located at Rotunda Edgar Cardoso, No. 23, Floor 11, G, 4400-676 Vila Nova de Gaia.

III. STANDARDS OF CONDUCT

  1. External Activities
    Employees of AMG must commit to defending the interests of the company they belong to, with AMG owning the results of the work developed, including intellectual property.
    While respecting the legal framework and internal rules, AMG employees are prohibited from engaging in professional activities with external entities when such activities interfere with the fulfillment of their duties as employees of AMG, or are incompatible or likely to interfere with or harm the interests, objectives, or activities of the company they work for or any other company in the AMG Group.

  2. Principle of Equality of Treatment, Diversity, and Non-Discrimination
    AMG rejects any form of discrimination, whether based on race, gender, ethnicity, age, nationality, social class, sexual orientation, physical disability, religious beliefs, political opinions, or affiliation, condemning any form of sexual or psychological harassment, verbal or physical humiliation, coercion, or threat.
    AMG prioritizes the principle of equal opportunities for professional development, diversity, and individual merit.

  3. Child Labor and Forced Labor
    AMG does not accept any form of child labor or any exploitation of children or adolescents, forced, slave, or analogous work in its facilities, among its suppliers, manufacturers, or clients. Suppliers, manufacturers, and clients must not hire minors.
    AMG has a practice of recruiting young employees, ensuring that the minimum legal age requirement is always met.

  4. Diligence, Efficiency, and Responsibility
    Recipients of this Code must always perform their duties with diligence, efficiency, professionalism, and responsibility in the scope of their professional relationship with AMG. Employee performance should be evaluated based on merit and the results achieved through the execution of their tasks.

  5. Confidentiality and Professional Secrecy
    Professional secrecy applies to all employees, particularly in situations where, due to their importance or existing legislation, certain information should not be made public. The disclosure of such information could affect the reputation, interests, or business of any company within the BDC Group.
    AMG employees must always act with discretion regarding facts and information obtained during the course of their duties, maintaining absolute confidentiality and secrecy with respect to friends, family, or any third parties.
    The obligation of confidentiality remains in effect even after the termination of the contractual relationship with AMG.

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6. Corporate Governance
The management of the companies that are part of the BDC Group and the exercise of senior management functions should be carried out with rigor, diligence, and transparency, adhering to the highest standards of good corporate governance.

7. Prevention of Corruption and Related Offenses
AMG does not tolerate any form of corruption or bribery, adopting a robust Compliance Program aimed at mitigating the risks of corruption and related offenses faced in the course of its daily activities.
AMG employees are required to act in accordance with the rules established within the Compliance Program, under penalty of being held accountable according to Chapter V of this Code.

8. Prevention of Potential Conflicts of Interest
AMG employees have the responsibility to avoid any situation that may directly or indirectly lead to a conflict of interest with the company they work for or any company within the BDC Group.
A conflict of interest is understood as any situation where an employee has a personal interest, directly or indirectly, that could benefit themselves, a family member, friend, or acquaintance, and which could influence their performance in the exercise of their duties.
Whenever it is foreseeable that such a situation may arise, or if there is a possibility of perceived personal interest, the employee must inform their hierarchical superior in writing about the suspicion, in order to ensure impartial, objective, and transparent performance, as defined in AMG’s Conflict of Interest Prevention Policy.
Employees are prohibited from using any privileged information obtained in the course of their duties for personal gain.

9. Use of Illegal or Unlawful Activities
The use of illegal or unlawful activities by an employee, whether or not for personal benefit or for the benefit of others, is condemned by AMG.

10. Relationships with Clients, Suppliers, and Other Entities
AMG employees must:

  • Condemn all forms of corruption, whether active or passive, paying special attention to any form of payment, favor, or complicity that may lead to the creation of illicit advantages, including subtle forms of corruption such as gifts or receiving benefits from clients or suppliers;

  • Reject all offers from third parties, as defined in AMG’s Gifts and Hospitality Policy.

AMG must maintain a cooperative and participative stance in institutional relationships with other national and international entities or organizations, supporting initiatives that align with its activities and add value to the organization and its employees.

11. Relationships Between Employees
AMG employees must:

  • Be responsible and cooperative in the exercise of their functions, fostering a positive work environment, respect, and good personal relations with both colleagues and hierarchical superiors, and vice versa with their subordinates;

  • In their professional relationships, promote the exchange of information, cooperation, and team spirit;

  • Guide their actions within the company with motivation to increase productivity, involvement and participation, maintaining a healthy and trusting atmosphere, respecting the hierarchical structure, proactively collaborating, sharing knowledge and information, and cultivating team spirit;

  • Refrain from any conduct or practices of harassment at work, in accordance with the concept of workplace harassment as defined in the Labor Code.

12. Relationships with Regulatory Entities and Compliance with the Law
AMG is committed to collaborating with regulatory, supervisory, and enforcement authorities, responding to any requests made by them and refraining from any actions that could impede the exercise of their competencies.
AMG and its employees must comply with all legal and regulatory norms applicable to the activities of the companies within the BDC Group.

13. Corporate Social Responsibility
AMG commits to:

  • Practices that contribute to the progress and well-being of communities, improving the quality of life of citizens, and making a decisive contribution to environmental, economic, and social sustainability;

  • Rejecting child or forced labor, promoting respect for human rights, labor rights, and freedom of association.

14. Health, Safety, and Well-Being at Work
AMG ensures compliance with health, safety, hygiene, and well-being standards in the workplace.
Adherence to safety rules is the responsibility of everyone, and it is the duty of AMG employees to promptly report any irregular situation to their superior or responsible services that could jeopardize the safety of people, facilities, or equipment within the BDC Group companies.
AMG employees are prohibited from performing their duties under the influence of any substance that could impair their performance or endanger their safety or that of others. This includes substances such as alcohol or drugs, which may include illegal drugs, controlled substances, or the improper use of prescription medications.
Violent behavior in the workplace is not accepted, and employees are prohibited from engaging in any act that could make another person feel threatened or unsafe, including verbal attacks, threats, or any expressions of hostility, intimidation, aggression, or mistreatment.

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15. Use of AMG Resources
AMG resources must be used efficiently to achieve the defined objectives and cannot be used for personal purposes or other unrelated activities. Employees must ensure the protection and proper maintenance of the company's assets within the BDC Group, always seeking to maximize their productivity.

16. Environmental Commitment
AMG continuously seeks to contribute to sustainable development and environmental preservation, prioritizing the use of non-polluting techniques, environmental monitoring, and rational use of available resources.

17. Reporting Irregularities and Violations
Any employee, shareholder, customer, supplier, or any other directly interested party may report any irregularities or violations of this Code of Conduct through:

  • Written communication, either on paper or in digital format (email), directed to the Human Resources Department, Compliance Officer, and/or AMG Management;

  • A report submitted via AMG’s Whistleblower Channel.

IV. COMPLIANCE PROGRAM

1. Compliance Program Overview
To ensure the highest standards of integrity in its activities, as well as the dissemination and compliance of its values by all, AMG establishes a set of legal and ethical principles and commitments reflected in this Code of Conduct and Ethics, which will serve as the guiding point for the policies and procedures created within the Compliance Program.
In accordance with the General Regime for the Prevention of Corruption (RGPC), attached to Decree-Law No. 109-E/2021, of December 9 (hereinafter referred to as "RGPC"), AMG’s Compliance Program includes, in addition to this Code of Conduct and Ethics, a Corruption and Related Offenses Risk Prevention Plan (PPR), a Training Program, a Compliance Officer, and a Whistleblower Channel to prevent, detect, and sanction acts of corruption and related offenses committed against or through AMG.
All employees are encouraged, without exception, to provide suggestions for improving the Compliance Program.

2. Compliance Officer
To ensure daily monitoring of the Compliance Program, as well as its enhancement and development, AMG designates a Compliance Officer, who can be contacted at any time by employees, suppliers, customers, partners, and others who seek clarification about any situation or document related to the AMG Compliance Program.
The Compliance Officer is tasked with continuously evaluating the risks to which AMG is exposed, monitoring daily activities, ensuring that the Compliance Program is sufficient, up-to-date, and effective in preventing and detecting situations that are non-compliant with the law, this Code of Conduct and Ethics, and the policies and procedures that complement it.
AMG ensures that the Compliance Officer performs their duties independently, continuously, and with decision-making autonomy, providing them with all necessary internal information and the human, financial, and technical resources required to perform their duties effectively.
The functions of the Compliance Officer are detailed in the Compliance Officer Job Description at AMG.
AMG’s appointed Compliance Officer is Cristina Moreira, who can be contacted at: cristinamoreira@amg-services.pt.

3. Whistleblower Channel
Each employee is responsible for complying with this Code, the related policies, and procedures, as well as the law. Employees may report any violation or suspicion of violation of the provisions of this Code and related documents. Supervisors have a special duty to ensure compliance with the Code and its supplementary documents.
AMG implements a Whistleblower Channel under Law No. 93/2021 of December 20, accessible to anyone, for the immediate reporting of any violation or suspicion of violation of legal provisions, the rules established in this Code, or the policies and procedures adopted by AMG.
AMG ensures that the reporting of illegal activities and/or non-compliance is handled by independent and impartial departments, ensuring confidentiality throughout the process, especially regarding the identity of the whistleblower, the person reported, and any third parties mentioned in the report.
AMG does not tolerate any retaliation against individuals who, in good faith, report improper practices, including, as defined in Article 21, Paragraph 2 of Law No. 93/2021 of December 20, "any act or omission, directly or indirectly, occurring in a professional context and motivated by an internal or external report or public disclosure, which unjustifiably causes damage to the whistleblower, either patrimonial or non-patrimonial."
To this end, AMG adopts a Whistleblower and Non-Retaliation Policy, which not only prohibits acts of retaliation but also sets out the rules for using the Whistleblower Channel, defines the process for receiving and handling reports, and identifies the various participants in this process.
AMG’s Whistleblower Channel is available at: https://whistleblowersoftware.com/secure/canal_de_denuncias_.

V. SANCTIONS FOR NON-COMPLIANCE

AMG maintains a zero-tolerance approach to violations of this Code. Without prejudice to any civil and/or financial liability, the following sanctions apply:

  • AMG employees with a labor contract: Violations of this Code are considered a disciplinary offense, subjecting the employee to the corresponding disciplinary procedure as outlined in Article 328 of the Labor Code.
    Disciplinary sanctions may include:

    • Reprimand;

    • Recorded reprimand;

    • Financial penalty: If applied to an employee for violations committed on the same day, the penalty cannot exceed one-third of the daily wage and, in each calendar year, the equivalent of 30 days’ wage;

    • Loss of vacation days, with no impact on the enjoyment of 20 working days;

    • Suspension from work with loss of pay and seniority, not exceeding 30 days per violation, and a total of 90 days per calendar year;

    • Dismissal without indemnity or compensation.

  • AMG’s Board members: Violations of this Code by Board members will be assessed by the Compliance Officer, who will propose the appropriate measures to AMG.
    In addition to the described responsibilities, criminal and/or administrative sanctions may apply, as set forth in relevant legal provisions.

Criminal Liability:

For compliance with Article 7, Paragraph 2 of the RGPC, the following criminal sanctions are outlined for acts of corruption and related offenses.

VI. FINAL PROVISIONS

1. Training and Awareness Programs
AMG provides training and awareness programs, creating a Training Program to help employees understand the content of all documents in the Compliance Program, as well as the responsibilities of the Compliance Officer.

2. Interpretation
Whenever an employee has doubts about the application and/or interpretation of this Code of Conduct and Ethics, as well as related policies and procedures, they should address these concerns to the Compliance Officer, who will review and provide clarification.

3. Monitoring
For each violation of this Code, as required by Article 7, Paragraph 3 of the RGPC, the Compliance Officer will prepare a report identifying the violated rules and the sanction applied.

4. Review
The content of this Code is reviewed by the Compliance Officer every three years, ensuring it remains up-to-date. It will also be reviewed whenever there is a change in the responsibilities or structure of AMG that justifies a revision, as stipulated in Article 7, Paragraph 4 of the RGPC.
Any revisions should be made public within 10 days of their occurrence, in compliance with Article 7, Paragraph 5 of the RGPC.

5. Publication
The AMG Code of Conduct and Ethics is available at all times to anyone interested on AMG’s official website, amg-services.pt, and on the intranet – Employee Portal.
The Compliance Officer ensures that this Code is made available within 10 days of its implementation at AMG.

6. Approval and Entry into Force


The AMG Code of Conduct and Ethics was approved on May 15, 2024, the same day it came into effect and was implemented at AMG.


However, it will be published on May 21, 2024.

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