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Anti-Corruption Policy
and Bribery

I. OBJECTIVE

The Anticorruption and Bribery Policy (“Policy”) aims to guide and assist the conduct of AMG’s employees regarding bribes to be offered and received in their internal and external relationships, as well as corruption-related phenomena.
This means that this policy seeks to provide AMG with a structure composed of integrated and transparent procedures, along with guidelines that direct the company's behavior, enabling open and participatory dialogue with beneficial results, both within the company and in its relationships with third parties, business partners, clients, service providers, and others.

II. SCOPE

This Policy applies, without exception, to all employees, business partners, service providers, clients, and third parties.

III. DEFINITIONS

To clarify this policy, some key concepts are listed alphabetically below, without prejudice to other relevant terms not included:

  1. AMG: Includes AMG Services, S.A., corporate entity no. 510689337, headquartered at Centro Empresarial Vilar do Pinheiro, nº 300, 4485-947 Vilar do Pinheiro, Vila do Conde.

  2. EMPLOYEE: All employees, directors, members of all organizational bodies of the company, including interns or others cooperating with the company in its ongoing activities.

  3. ACTIVE CORRUPTION: When someone, either directly or indirectly, with their consent or ratification, gives or promises to a public servant or third party (with the knowledge of the public servant) a material or non-material advantage to carry out any act or omission contrary to the duties of their position.

  4. PASSIVE CORRUPTION: An employee who, directly or indirectly, with their consent or ratification, requests or accepts, for themselves or a third party, a material or non-material advantage, or its promise, for the practice of any act or omission contrary to the duties of their position, even if before the request or acceptance.

  5. CLIENT: A natural or legal person who purchases a product, uses a service, or consumes a product or service.

  6. POLITICAL DONATION: Any donation made to a political campaign, politically exposed person, political party, or candidate for public office, either during or outside of an election period, in money or something of equivalent value.

  7. GOVERNMENT OFFICIAL: Includes any person holding an official position in or for agencies or entities owned or controlled by the government, political parties, party employees, political candidates, or public international organizations with governments as members (e.g., World Bank). This also includes consultants, employees of government-controlled companies, political party employees, and others.

  8. INTERPOSED PERSON: A person with a close relationship (spouse, partner, relatives in the direct ascendant or descendant line, or collateral) or third party, used to conceal the identity of the person they represent.

  9. LOBBYING: Activities that involve the illegitimate representation of interests, aiming to influence, directly or indirectly, the development or execution of public policies, legislative and regulatory acts, administrative actions, public contracts, and the decision-making processes of public entities.

  10. FACILITATION PAYMENT: Typically includes "anything of value" requested or offered to a government official to expedite or ensure the completion of a routine and legitimate governmental action.

  11. BUSINESS PARTNER: A natural or legal person that forms strategic alliances, sharing common goals with the company, and involved in a dynamic business agreement.

  12. SERVICE PROVIDER: A natural or legal person that provides a service to the company.

  13. ANYTHING OF VALUE: This term should be interpreted broadly to include anything (monetary or non-monetary) that results in a benefit, such as favors, contract awards, loans, guarantees for loans, payment of expenses or debts, discounts, gifts, use of materials, facilities, equipment, entertainment, drinks, meals, transportation, accommodation, insurance benefits, privileged information, political contributions, future job promises, etc.

  14. BRIBERY: Includes payments, offers, promises of payment, or authorizations to pay or provide anything of value made by the company or on its behalf, directly or indirectly, with the aim of obtaining an improper advantage, either personal or business-related.

  15. THIRD PARTIES: All persons/entities who have a relationship with the company (social, commercial, business, or otherwise) who do not fall under any of the definitions above.

IV. RESPONSIBILITIES

  1. ADMINISTRATION:

    • Approve the anticorruption and bribery policy.

    • Implement the anticorruption and bribery policy.

    • Appoint the person responsible for the anticorruption and bribery policy.

  2. RESPONSIBLE FOR THE ANTICORRUPTION AND BRIBERY POLICY:

    • Safeguard all documents related to corruption and bribery phenomena in the company.

    • Submit any issues considered to be signs of corruption or bribery to the Administration.

    • Draft the minutes of the Administration's meetings discussing corruption and bribery matters.

    • Submit any relevant legal issues to the legal team.

    • Assist the Administration in decision-making.

    • Ensure the compliance with this Policy.

    • Oversee training, communication, and dissemination of the policy.

V. GENERAL PROVISIONS

  • All those covered by this policy must strictly comply with applicable laws and the principles of AMG’s Code of Conduct and Ethics.

  • AMG does not tolerate any form of corruption or bribery.

  • Exceptions or non-compliance situations must be reported directly to the Administration and the responsible person for the anticorruption and bribery policy.

  • Amendments to this policy can be proposed by the Administration after consulting the person responsible for the anticorruption and bribery policy.

  • This policy should always be considered alongside AMG’s Code of Conduct and Ethics, especially in relation to corruption and related violations.

VI. GUIDELINES

  1. BRIBERY:

    • AMG strongly condemns any payment, offer, or promise of payment or authorizations to pay or provide anything of value made by the company or on its behalf, directly or indirectly, aiming to obtain an improper advantage.

    • AMG will not tolerate anyone accepting a financial or any other type of advantage with the intent to execute an improper function or activity.

  2. GIFTS AND HOSPITALITY:

    • Gifts, presents, and other items offered or accepted, as well as hospitality, are regulated by the Gifts and Hospitality Policy and must strictly follow the guidelines therein.

  3. FACILITATION PAYMENTS:

    • All employees are prohibited from making or authorizing any facilitation payments, directly or indirectly.

    • If an employee doubts whether a payment could be considered a facilitation payment, it should only be made if the government official can issue a formal receipt or written confirmation of the payment’s legality.

  4. CHARITABLE CONTRIBUTIONS AND SOCIAL RESPONSIBILITY:

    • Sponsorships, donations, and events within the company’s social community activities, aligned with objectives such as poverty reduction, social inclusion, human rights, and environmental protection, are allowed if they follow the procedures outlined in the Sponsorships and Donations Policy.

  5. POLITICAL DONATIONS:

    • Donations to public officials, political parties, campaigns, and candidates are absolutely prohibited, as per the Sponsorships and Donations Policy.

  6. LOBBYING:

    • AMG condemns any lobbying activities aimed at influencing the development or execution of public policies, legislative acts, administrative actions, or public contracts.

VII. RESPONSIBILITY FOR NON-COMPLIANCE WITH THE ANTICORRUPTION POLICY

  • All employees, business partners, service providers, clients, and third parties are responsible for adhering to this policy.

  • Those who do not comply will be subject to disciplinary action, in addition to potential civil or criminal consequences.

VIII. REPORTING

  • The company's compliance mechanism includes a reporting channel where violations of the policy can be denounced.

  • Whistleblowers are protected as per the Whistleblower Protection Policy.

IX. TRAINING, COMMUNICATION, AND DISCLOSURE

  • The person responsible for the anticorruption and bribery policy must ensure periodic training sessions for employees.

  • This policy must be communicated to all employees, clients, service providers, business partners, and third parties and be made available on the company website.

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X. REFERENCES

  • AMG Code of Conduct and Ethics

  • Law No. 93/2021, December 20 – General Regime for the Protection of Whistleblowers

  • Decree-Law No. 109-E/2021, December 9 – General Regime for the Prevention of Corruption

  • Decree-Law No. 89/2017, July 28 – Transposition of Directive 2014/95/EU – Non-financial Information Disclosure

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