Bacalhôa Group Code of Ethics and Conduct
1. INTRODUCTION
The Culture of the Bacalhôa Group
"Art, Wine, and Passion"
It is in the culture of the Bacalhôa Group that we find the foundations of our code of ethics and conduct.
Our PURPOSE
The Bacalhôa Group aims to contribute sustainably to a happier society by providing healthy and enjoyable cultural experiences with the quality of its products, the passion of its team, and the beauty of its properties.
Our VALUES
? Team Spirit: We build strong bonds among ourselves and the surrounding community, ensuring quality experiences and products;
? Ambition: We innovate in what we set out to do, aiming for excellence;
? Commitment: We commit to delivering our best, honoring our history;
? Loyalty: We promote an environment of safety and mutual trust;
? Inclusion: We respect diversity.
Our MISSION
Our mission is to produce and market quality wines that honor the specific characteristics of various wine regions of Portugal and promote the richness of our natural and cultural heritage, respecting the country's winemaking tradition.
2. The Code of Ethics and Conduct in Practice
This code of ethics and conduct serves as a guide for the Bacalhôa Group, its people, and business partners, outlining the fundamental ethical guidelines for the Bacalhôa Group's operations and how they should be implemented. It applies to all members of the Administration, Employees (regardless of contractual relationship), Customers, and all Stakeholders with whom the Bacalhôa Group interacts.
The commitments of our code reflect the criteria of conduct that the Bacalhôa Group and its people must adopt and enforce, promoting an appropriate working environment, protecting the company's reputation and sustainability, in accordance with our values, with integrity and respect for others, in strict compliance with the Code.
Reporting Violations of the Code of Ethics and Conduct
Whenever there is knowledge or suspicion of potential irregularities, they should be reported through the established channels.
Communications related to ethics and conduct violations should preferably be directed through the electronic communication channel indicated below, which aims to prevent, investigate, and address irregularities within the Bacalhôa Group and is also used to handle other ethics and conduct issues permitted by law, besides those outlined in the code.
The Sharing Channel ensures the strictest confidentiality of the conveyed information, guaranteeing the rights to access and rectify data, in compliance with the legal regulations in force. It is available to all employees, customers, suppliers, or other interested parties.
Any communications should be made through the following available means:
- By email, to the address sharing@bacalhoa.pt
- By mail, to the following postal address:
Grupo Bacalhôa
Attn: Sharing Manager - Bacalhôa Group Reporting Channel
EN 10 – Apartado 54
2925-901 Vila Nogueira de Azeitão, Setúbal
Reports to the Sharing Channel are received on behalf of the Bacalhôa Group by the Sharing Channel Manager, who ensures their confidential handling.
Handling Ethics and Conduct Communications
All received communications falling within the scope of the Sharing Channel are analyzed to determine all pertinent and truthful facts. The handling process includes:
- Listening to the person who identified the potential irregularity;
- Listening to the reported person, without revealing any information about the identity of the reporting person;
- Listening to other relevant entities considered necessary for fact-finding;
- Conducting other appropriate measures;
- Preparing a report on the findings with recommendations or measures to be taken or promoting the closure of the investigation and handling process;
- Notifying the reporting person, the reported person, and all involved entities about the outcome of the process.
Cooperation in investigations and handling communications is a duty of all recipients of this code, including any external entities supporting the measures taken.
The fundamental rights of the reported person, including the defense of their good name, privacy, and the right to file a complaint for malicious reporting, cannot be prejudiced in any case, and the Bacalhôa Group guarantees the necessary protection to the recipient who fulfills their duty to report.
Consequences of Code Violation or Abusive Use
Without prejudice to applicable criminal and civil procedures, behaviors contrary to the code, when the agent is a person from the Bacalhôa Group, are subject to censure within the scope of internal procedures.
If it is verified by the Bacalhôa Group, by legal or contractually available means, that an act or omission concerning the Code was committed by a business partner, supplier, or customer, the Bacalhôa Group will strive to determine the extent of preventive actions taken to avoid such a breach in the future and the consequences for their agents, evaluating the potential impact of this fact on commercial or partnership relations with them.
3. Commitments Regarding Our People
The Bacalhôa Group is committed to ensuring its people a healthy and pleasant work environment, fair and adequate compensation, promoting their motivation for work and a sense of personal and professional fulfillment. This commitment strengthens the organizational culture, with engaged and committed employees and motivated teams, in a healthy organizational climate and results-oriented environment, contributing to the company's good external reputation and a sustainable future.
Responsible Social Environment
Sustainability is vital to the DNA of the Bacalhôa Group, and it is fully embraced through the adoption of good economic, environmental, and social practices throughout its value chain, for a sustainable future, strategically focusing on essential management components such as:
- Promoting inclusive and sustainable economic growth, full and productive employment, and decent work for all;
- Ensuring equal career opportunities for all employees, fostering diversity, creating an equitable reality, which is the basis for long-term corporate success;
- Ensuring full and effective participation of women and equal leadership opportunities based on meritocracy, and reducing wage inequalities between men and women;
- Empowering and developing employees, equipping them with new tools for adaptation and evolution. Investing in education and retraining of people and talent.
Safety, Health, Hygiene, and Well-being
The Bacalhôa Group ensures a safe and healthy work environment and conditions for its employees, prohibiting any forms of harassment, bullying, or mobbing, and promotes the dissemination of essential principles, values, and norms for maintaining and consolidating a risk prevention culture in the workplace.
All recipients are committed to preventing workplace accidents and maintaining safety, complying with and enforcing current norms, and implementing active policies to promote health, hygiene, and well-being in the workplace, ensuring people's well-being and productivity and compliance with applicable legal obligations in this matter.
Use of Drugs, Narcotics, and Alcohol
In the exercise of their duties, our people are obligated not to use drugs, narcotics, or other illicit substances, nor consume alcohol during work hours, to preserve each employee's health and well-being and ensure the maintenance of safety conditions in the workplace, preventing professional risks and minimizing the likelihood of workplace accidents.
The prohibition on alcohol consumption does not apply to special events that occur for work-related reasons (wine tasting, events, etc.), which should always be done in moderation to avoid the aforementioned risks.
Non-Discrimination
In the exercise of their activities, duties, and competencies, the Administration and Employees must act in respect of the principles of non-discrimination and combating workplace harassment, not acting discriminatorily towards our or any people, particularly regarding race, religion, sex, sexual orientation, ancestry, age, language, territory of origin, political or ideological convictions, physical characteristics and/or disabilities, economic situation, social context, or contractual relationship. Policies and measures are also promoted to prevent discriminatory actions, including those aimed at deepening gender diversity within the organization.
Harassment
Our work environment should be based on mutual respect, sharing experiences and knowledge, and mutual assistance, with any behaviors that may constitute harassment, whether moral or sexual, including forms of intimidation, such as bullying, and bad-faith reporting, not being tolerated.
Our people's commitment must be to reject any intimidating behaviors and to report, through established channels, any situations they become aware of or have reasonable suspicion, which may constitute harassment and/or bullying.
Considering the provisions of Article 29 of the Labor Code, the following behaviors, by way of example, are expressly prohibited as they may be considered workplace harassment:
• Systematically devalue and disqualify the work performed;
• Promote social isolation;
• Ridicule, directly or indirectly, a physical or psychological characteristic;
• Repeatedly threaten dismissal;
• Not assign any professional functions, which constitutes a violation of the right to effective occupation of the job position;
• Systematically set unattainable work goals and objectives or impossible deadlines;
• Systematically assign functions unrelated or inadequate to the professional category;
• Systematically appropriate ideas, proposals, projects, and work without identifying the author;
• Systematically disseminate rumors, malicious comments, or repeated criticism about workers;
• Systematically give confusing and imprecise work instructions;
• Repeatedly request urgent work without necessity;
• Transfer the worker from department or workplace with the clear intention of promoting their isolation;
• Constantly speak in a way that intimidates people;
• Systematically create objective situations of stress to provoke loss of control in the worker's conduct, such as systematic changes or transfers of workplaces.
Equal Opportunities
At the Bacalhôa Group, we hold our people accountable and value them based on merit, allowing them to assume the autonomy and responsibility associated with their capacity and commitment.
Training
The Bacalhôa Group provides adequate training to its people, including regarding this code, to ensure continuous learning, promoting their personal and professional development. Employees must attend the training sessions proposed to them.
Privacy and Data Protection
The Bacalhôa Group commits to strict compliance with data protection legislation in force at all times and to ensure the effectiveness of the rights arising from it for its people, who must scrupulously comply with the data protection principles set out in applicable legislation and internal regulations in the exercise of their functions.
All Bacalhôa Group employees must:
? Be responsible for handling personal data, ensuring that any data processing is always carried out in accordance with applicable legislation and internal regulations on data protection;
? Access and process only the personal data necessary for the performance of their functions;
? Implement the appropriate security measures to protect personal data and mitigate the risk of data breaches.
Confidentiality
Confidentiality is a fundamental commitment for the Bacalhôa Group and its people. Employees should safeguard all business and personal information they access or become aware of in the performance of their duties, ensuring it is not disclosed to unauthorized individuals or used for purposes other than those for which it was intended.
Social Responsibility
The Bacalhôa Group assumes social responsibility as an integral part of its corporate culture, promoting initiatives that contribute to the well-being and development of the community and fostering partnerships with social and cultural institutions.
4. Commitments Regarding Customers
Customer Satisfaction
Customer satisfaction is a priority for the Bacalhôa Group. We are committed to providing high-quality products and services that meet the expectations and needs of our customers.
Product Quality and Safety
The Bacalhôa Group ensures that its products comply with all relevant quality and safety standards. We continuously monitor and improve our processes to ensure that our products are safe and of the highest quality.
Customer Service
We strive to offer excellent customer service, providing clear and accurate information about our products and services, and responding promptly to customer inquiries and complaints.
Privacy and Data Protection
We respect the privacy of our customers and are committed to protecting their personal data. We ensure that all customer data is processed in accordance with applicable data protection legislation and our internal policies.
Ethical Marketing
The Bacalhôa Group is committed to ethical marketing practices. We ensure that all marketing communications are honest, transparent, and do not mislead our customers.
5. Commitments Regarding Suppliers and Business Partners
Fair Competition
The Bacalhôa Group is committed to fair competition and complies with all applicable competition laws and regulations. We avoid any anti-competitive practices and ensure that our business relationships are based on mutual respect and fairness.
Supplier Selection
We select our suppliers based on objective criteria such as quality, reliability, and sustainability. We seek to establish long-term partnerships with suppliers who share our values and commitment to ethical business practices.
Integrity in Business Relationships
We conduct our business relationships with integrity, ensuring that all agreements and contracts are fair and transparent. We do not engage in or tolerate any form of corruption, bribery, or unethical behavior.
Respect for Human Rights
The Bacalhôa Group is committed to respecting human rights in all its operations. We expect our suppliers and business partners to adhere to the same standards and to ensure that their operations do not involve any form of forced labor, child labor, or other human rights abuses.
Environmental Responsibility
We are committed to minimizing our environmental impact and promoting sustainable practices throughout our supply chain. We encourage our suppliers and business partners to adopt environmentally responsible practices and to continuously improve their environmental performance.
6. Commitments Regarding the Community
Environmental Sustainability
The Bacalhôa Group is committed to environmental sustainability and to minimizing its impact on the environment. We strive to adopt environmentally friendly practices in all our operations and to promote the sustainable use of natural resources.
Community Engagement
We actively engage with the communities where we operate, supporting local initiatives and contributing to the social and economic development of the region. We encourage our employees to participate in community activities and to volunteer their time and skills for the benefit of the community.
Cultural Heritage
The Bacalhôa Group is committed to preserving and promoting the cultural heritage of Portugal. We support cultural initiatives and projects that contribute to the preservation and dissemination of our rich cultural history.
Transparency and Accountability
We are committed to transparency and accountability in all our activities. We communicate openly with our stakeholders and provide regular reports on our social and environmental performance.
7. Implementation and Compliance
Communication and Training
The Bacalhôa Group ensures that this Code of Ethics and Conduct is communicated to all employees and relevant stakeholders. We provide regular training to ensure that everyone understands their responsibilities under the Code and is aware of the standards of behavior expected of them.
Monitoring and Reporting
We regularly monitor compliance with this Code of Ethics and Conduct and encourage employees and stakeholders to report any violations or concerns. We have established reporting channels to facilitate this process and ensure that all reports are treated confidentially and investigated promptly.
Disciplinary Actions
Any violations of this Code of Ethics and Conduct may result in disciplinary actions, including termination of employment or business relationships. We are committed to enforcing this Code and ensuring that all employees and stakeholders adhere to its principles.
Continuous Improvement
The Bacalhôa Group is committed to continuously improving its ethical standards and practices. We regularly review and update this Code of Ethics and Conduct to ensure that it remains relevant and effective in guiding our behavior and decision-making.
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By adhering to this Code of Ethics and Conduct, the Bacalhôa Group demonstrates its commitment to ethical behavior, social responsibility, and sustainable development. We believe that by following these principles, we can build a stronger, more resilient organization that contributes positively to society and the environment.