Introduction
1. Our Values
2. Compliance with laws and regulations
3. Responsibilities
4. Communication
5. Preventing and combating harassment [article 127 of the Labor Code]

Our values are the cornerstone of Marques Pereira, Edgar Torrão & Associados. Do it well and correctly. By incorporating these values into our daily behavior, we will be a reference in what we do and in the way we do it. 

1. Integrity:  We are honest, righteous in our words and actions. We act with honesty, ethics and transparency in all our activities and interactions, ensuring the trust of customers and partners. 

2. Independence: We maintain independence and impartiality, ensuring objectivity in our conclusions and recommendations. 

3. Excellence: Search for excellence in each project or work carried out, maintaining high standards of quality, precision and technical rigor. 

4. Confidentiality: We respect the confidentiality of all information obtained. Professional secrecy is present in everything we do. 

5. Social and Environmental Responsibility: We are committed to responsible practices that consider the social and environmental impact, contributing to a sustainable development of the community and the environment

The sum of individual responsibilities gives rise to collective responsibility towards everyone.

Individual responsibilities

All employees must keep themselves informed of the laws, regulations, professional standards and internal policies of Marques Pereira, Edgar Torrão & Associados. They must also

1. Resist any pressure to act unethically and contrary to this Code of Conduct and our Values;
2. Decisions and matters in the personal or private sphere of employees must be consistent with this Code of Conduct and our Values;
3. Courage to say no to matters that are not right or inconsistent with this Code of Conduct; and
4. Consult partners whenever there are matters that seem wrong.

Partners' responsibility

The partners of Marques Pereira, Edgar Torrão & Associados must

1. Lead by example. Their actions and decisions must be upright and in accordance with the values and principles of this Code of Conduct.
2. Lead by service. Serve the firm, the teams and their clients with independence and quality.
3. Lead with responsibility. Take personal responsibility for mistakes in your own behavior and that of the people you lead.
4. Lead carefully. Be fair, considerate and exercise a duty of care towards all those who raise their concerns in good faith.

Preamble

This chapter of the Code of Conduct of Marques Pereira, Edgar Torrão & Associados intends to constitute, under the terms of Law no. 73/2017, of August 16, a reference for all its members of the Governing Bodies and Employees and contributing to its recognition as an example of integrity, responsibility and rigor, aiming to ensure the safeguarding of the moral integrity of its employees by ensuring their right to working conditions that respect their dignity individual, establishing a set of principles that must be observed in the fulfillment of the activities and organization of the work developed in Marques Pereira, Edgar Torrão & Associados, constituting a self-regulatory instrument, as well as the expression of an active policy in order to make known, avoid, identify, eliminate and punish situations and behaviors likely to substantiate harassment at work. The chapter "Preventing and Combating Harassment" should be analyzed in addition to the firm's Quality Management Manual, in accordance with the ISQM1 and ISQM2 Quality Management Standards.

Article 1 (scope) 

The Code of Conduct for the Prevention and Combating of Harassment at Work is applicable to all members of the governing bodies of Marques Pereira, Edgar Torrão & Associados and its employees and workers, regardless of the modality or duration of the relationship under which they exercise functions, which must comply with the principles and rules described therein and the duty to collaborate in the prevention and repudiation of harassment behaviors whatever their form,  the cause that determined them or their author. 

Article 2 (general principles) 

Marques Pereira, Edgar Torrão & Associados does not admit any degree of tolerance in relation to conduct qualifying as harassment at work, in any of its forms, by the persons identified in the first article towards colleagues, clients, partners or any persons with whom they interact. The persons identified in the first article must guide their action by refraining from practicing any acts that may be understood as harassment, as provided for in the following article 3 and in article 29, paragraph 2 and paragraph 3, of the Labor Code. In the exercise of their activities, functions and competences, the persons identified in the first article must govern their performance at Marques Pereira, Edgar Torrão & Associados in accordance with the following principles: Equality and non-discrimination; Respect for the dignity of the human person and for his physical and moral integrity; Respect for the professional dignity of each employee; Promotion of a safe, positive and civically responsible work environment; Loyalty and cooperation in the pursuit of the public interest of the institution, respecting the principles of non-discrimination and combating harassment in the workplace; Rejection of any discriminatory practice, whether on the basis of ancestry, age, sex, sexual orientation, gender identity, marital status, family situation, economic situation, education, origin or social condition, genetic heritage, reduced work capacity, disability, chronic disease, nationality, ethnic origin or race, territory of origin, language, religion, political or ideological convictions and trade union membership; Zero tolerance for harassment, regardless of the form it takes, gender, functional quality or hierarchical position of the person harassed and the person harassing. 

Article 3 (definitions of harassment) 

Harassment means the practice of unwanted and repeated behaviour, in particular that which is based on a factor of discrimination, committed when accessing employment or in employment, work or vocational training, with the aim or effect of disturbing or embarrassing the person, affecting his dignity or creating an intimidating environment,  hostile, degrading, humiliating or destabilizing. Moral harassment consists of verbal attacks of offensive or humiliating content, and physical, perceived as abusive, encompassing physical and/or psychological violence, with a reiterated character. Sexual harassment occurs when there is unwanted behavior of a sexual nature or other behaviors based on gender or with a sexual connotation, perceived as abusive, that affect the dignity of the worker targeted, and may include any other unwanted behavior in verbal, non-verbal or physical form, with a reiterated character. Unwanted behavior - Any gesture, word, act, which may include by way of example, invitation of sexual content, sending of messages, emails, phone calls and attempts at embarrassing physical contact. Isolated situations, even if they are not considered harassment, may constitute a crime and should be dealt with in the criminal and/or disciplinary sphere. Conduct or conduct that corresponds to the legitimate exercise by the employer of the powers legally conferred on it, namely the powers of hierarchical and disciplinary management, do not constitute harassment 

Article 4 (internal procedure and complaint) 

The worker who considers to be the target of harassment at work must report the situation to management. All those who have knowledge of irregular practices that may indicate situations of harassment or that an employee has committed a disciplinary offense for harassing practices can/should report it to management and should provide due cooperation in the disciplinary process and in any other proceedings that may take place 

Article 5 (form, content and means to present a complaint) 

The complaint or participation should be addressed to management. The complaint or participation must be as detailed as possible, containing a precise description of the facts constituting or likely to substantiate the practice of harassment, in particular, as to the circumstances, time and place of the same, identity of the victim and the harasser, as well as the means of testimonial, documentary or expert evidence, if any. The complaint or participation, if merely verbal, will be reduced to writing. The report, participation or complaint regarding situations of harassment at work, can be directed to the email address of any of the managers (marques.pereira@marquespereira.pt and edgar.torrao@marquespereira.pt). A specific protection regime will be guaranteed for the whistleblower and witnesses in proceedings related to harassment situations, namely in terms of confidentiality, impartiality, efficiency and speed in the process. Except when they act with intent, special protection is guaranteed to whistleblowers and witnesses in judicial or administrative proceedings triggered by harassment, and these persons may not be disciplined until the final decision has been made. Persons to whom this Code of Conduct is addressed and who report infringements of this Code of Conduct of which they have become aware in the performance of their duties or because of them may not, in any way, be harmed, and they shall be assured anonymity until charges are filed. All persons involved in internal procedures related to harassment at work must guide their actions by principles of good faith, confidentiality, discretion, secrecy and impartiality, respecting the dignity of the person, and are obliged not to disclose any information accessed within the scope of such procedures Under the Labour Code, dismissal or other sanction applied to punish an offence is presumed to be abusive if it takes place within one year of the complaint or after another form of claiming or exercising rights relating to equality, non-discrimination and harassment. 

Article 6 (disciplinary offences and sanctions) 

Whenever the employer becomes aware of the violation of the provisions of this Code of Conduct, it will open a disciplinary procedure, which must begin within 60 days of the one in which the employer, or the hierarchical superior with disciplinary competence, becomes aware of the infraction (paragraph 2, Art. 329 of the Labour Code). The Governing Bodies, workers and collaborators of Marques Pereira, Edgar Torrão & Associados will denounce any irregular practices of which they are aware, providing due collaboration in any disciplinary proceedings or criminal investigation by the respective competent entities. 

Article 7 (Reports of complaints in the context of work) 

Under its own regulations, the Authority for Working Conditions (ACT) will make available and disclose its own e-mail addresses for the reception of harassment complaints in the context of work. The practice of harassment by the employer, or by a representative of the same, reported to the Authority for Working Conditions (ACT), will be among the examples of just cause of termination of the employment contract by the worker. 

Article 8 (publicity and disclosure) 

This Code of Conduct shall be published by posting it in the workplace and shall be communicated to workers at the time of conclusion of the contract Article 9 (revision) This chapter "Preventing and Combating Harassment" should be revised whenever there are supervening facts that justify its revision. 

Approval and entry into force of the Code of Conduct

This Code of Conduct was approved by the Management of Marques Pereira, Edgar Torrão & Associados, S.R.O.C., Lda. on 30 July 2023, communicated to all workers and entered into force immediately.