Code of Ethics and Conduct

The commercial, institutional and social activities of VALA & VIEIRA – Montagem de Caixilharias em Alumínio, Lda., generate a legitimate interest in transparency, dialogue, and the ethical behaviour of the Company and its employees.

This Code of Ethics and Conduct (CEC) aims to broadly define the behaviour expected of all Company employees regarding the conduct to be adopted in the performance of their duties.

The purpose of this Code is to provide guidance on how to protect not only the employee but also the Company itself, and to avoid situations that may compromise the Company’s interests and lead to serious disciplinary offences.

These rules must be followed by all employees, including members of the corporate bodies and other Company officials. It is each employee’s responsibility to ensure that their behaviour complies with these rules. In any doubtful situation that may lead to a conflict of interest or a breach of confidentiality or trust, the employee must report the matter to their line manager or the Human Resources Department.

All employees are bound by a duty of loyalty to the Company, as well as duties of confidentiality and professional secrecy.

FUNDAMENTAL VALUES

• Integridade: To act honestly and transparently in all professional activities;
• Qualidade: To commit to quality, rigour, and excellence in the performance of duties;
• Compromisso com a Empresa: To defend the interests of the organisation and promote its sustainable growth;
• Prevenção da Corrupção: To strictly comply with the rules and guidelines of the Anti-Corruption Regulatory Framework (RGPC), promoting ethical and transparent practices;
• Responsabilidade Social e Ambiental: To uphold mutual respect and well-being among colleagues and between the Company and the local community. To strive for the use of environmentally sustainable materials and processes, minimising waste and adopting a responsible approach;
• Transparency: The management model is based on complete integrity and honesty towards employees, customers, suppliers, stakeholders, and the general community.

TARGET AUDIENCE
This Code applies to all employees of the organisation, regardless of their contractual relationship, professional category or hierarchical position. It also applies to temporary staff, volunteers, external consultants, and other individuals who provide services to the organisation, either on a permanent or occasional basi.

RELATIONSHIPS BETWEEN EMPLOYEES
In carrying out their duties, employees must act responsibly and cooperatively, promoting a good working environment, mutual respect, and courteous interactions — with colleagues, superiors, and all individuals connected to the Company.

Employees must comply with the instructions and guidelines issued by the Company, as employer, regarding the execution and discipline of work, as well as those of their hierarchical superiors.

In their professional relationships, employees of VALA & VIEIRA – Montagem de Caixilharias em Alumínio, Lda. must foster information sharing and cooperation, promoting a team spirit. Those who contribute to a decision by any means must stand by the decision-maker, assume the corresponding responsibilities, and support its implementation.

GENERAL RELATIONSHIP WITH THE COMPANY
In their relationship with the Company, employees must remember that the Company, as employer, is responsible for paying remuneration in exchange for work provided.

Each employee must therefore perform their duties with the highest level of diligence, contributing to increased productivity and the Company’s competitiveness in the market:

In this context, employees must, in particular:

• Perform their duties with care and diligence;
• Promote a healthy, pleasant, and conflict-free working environment;
• Attend work regularly and on time;
• Actively participate in professional training offered by the Company;
• Maintain loyalty towards the Company;
• Ensure the proper care and use of the Company’s property entrusted to them.

REPORTING CHANNEL
Following the entry into force of Law no. 93/2021 of 20 December, which transposes Directive (EU) 2019/1937 of the European Parliament and of the Council, VALA & VIEIRA – Montagem de Caixilharias em Alumínio, Lda. established a Whistleblowing Channel for receiving and handling reports of irregularities or violations committed within the organisation.

This channel may be used by any employee, customer, supplier, or third party who becomes aware of facts that may constitute:

• Corruption or related offences;
• Conflicts of interest;
• Abuse of power;
• Moral or sexual harassment;
• Discriminatory practices;
• Breaches of legal or regulatory duties;
• Violations of this Code of Ethics and Conduct;
• Other illegal or illegitimate behaviours or practices.

Reports may be submitted anonymously or with identification, and the confidentiality of the whistleblower’s identity as well as protection against retaliation are guaranteed.
Access to the whistleblowing channel is available via the Company’s official website (https://denuncias.valaevieira.com) or via the dedicated email address (denuncias@valaevieira.com). The channel is managed by the designated Compliance Officer, ensuring impartiality and confidentiality.

PREVENTION OF HARASSMENT
VALA & VIEIRA – Montagem de Caixilharias em Alumínio, Lda. adopts a zero-tolerance policy towards all forms of workplace harassment, whether moral or sexual, perpetrated by superiors, colleagues, or third parties.

• Moral harassment is defined as any unwanted behaviour that affects a person’s dignity in the workplace, creating an intimidating, hostile, degrading, humiliating or destabilising environment.
• Sexual harassment is defined as any unwanted behaviour of a sexual nature, whether verbal or non-verbal, that affects a person’s dignity and creates an offensive or intimidating environment.

All employees have a duty to contribute to a respectful and inclusive work environment. If they become aware of harassment situations, they must report them via the Whistleblowing Channel or to the Human Resources Department, which will ensure confidentiality and fair and prompt handling of reported incidents.

RELATIONS WITH CLIENTS AND SUPPLIERS
VALA & VIEIRA – Montagem de Caixilharias em Alumínio, Lda. is committed to maintaining relationships with clients and suppliers based on trust, transparency, and professionalism, in accordance with the following principles:

• Maintaining clear, respectful, and effective communication;
• Strict adherence to deadlines and ensuring delivery of high-quality products;
• Rejection of any unethical practices, such as bribery, undue favouritism, or conflicts of interest;
• Ensuring that all commercial relationships comply with the RGPC (Anti-Corruption Regulatory Framework) and other applicable legal and regulatory standards for the prevention of corruption and related offences.

ENVIRONMENTAL COMMITMENT
VALA & VIEIRA – Montagem de Caixilharias em Alumínio, Lda. continuously promotes the integration of environmentally responsible practices in its operations, contributing to sustainable development and environmental protection.

In this regard, the Company prioritises:

• The use of non-polluting technologies;
• Monitoring the environmental impact of its operations;
• Adopting energy-saving measures;
• Promoting environmental awareness among employees, partners, and the surrounding community.

HEALTH, SAFETY AND WELL-BEING AT WORK
The Company guarantees full compliance with legal and regulatory standards concerning safety, health, hygiene, and well-being in the workplace.

All employees must:

• Respect the established safety rules and procedures;
• Promptly report to their superiors or the relevant departments any irregular or dangerous situations that may jeopardise the safety of individuals, facilities or equipment;
• Actively contribute to the implementation of measures aimed at the continuous improvement of occupational health and safety conditions.

VALA & VIEIRA, Lda. is committed to providing a safe, healthy, and motivating work environment, promoting the prevention of occupational risks and the well-being of its employees.

COMPLIANCE OFFICER
The Compliance Officer designated by VALA & VIEIRA – Montagem de Caixilharias em Alumínio, Lda. is responsible for independently, continuously, and autonomously monitoring and overseeing the implementation of the Company’s Compliance Programme.

To do so, the Compliance Officer has access to internal information and the technical and human resources necessary to perform their duties.

Responsibilities include:
• Preparing detailed reports on each identified breach, outlining the violated rules, imposed sanctions, and corrective measures adopted or to be adopted under the Company’s internal control system;
• Clarifying any doubts concerning the application of the Code of Ethics and Conduct;
• Promoting regular internal audits to assess the level of compliance with established standards.

INFORMAL AND FORMAL PROCEDURES
The Code of Ethics and Conduct may be promoted and enforced through informal procedures (counselling, awareness-raising, active listening, mediation, etc.) or formal ones (internal reporting, inquiries, disciplinary proceedings, legal action, among others).

It is the responsibility of the Company’s management or its appointed representatives to ensure that these procedures are carried out fairly, transparently and proportionately, respecting the rights of all parties involved.

NON-COMPLIANCE WITH THE CODE OF ETHICS AND CONDUCT
Failure to comply with the provisions of this Code may constitute a disciplinary offence under current labour legislation and may result in disciplinary sanctions, without prejudice to any civil, administrative, or criminal liability.

The Company may also terminate relationships with third parties (suppliers, service providers, etc.) who seriously or repeatedly violate the principles set out in this Code.

DISSEMINATION AND ENFORCEMENT
This Code of Ethics and Conduct is made available to all employees and stakeholders of the organisation and is disseminated through the Company’s internal and external channels.

All employees must read and commit to complying with its provisions, contributing to the consolidation of an ethical, responsible, and transparent organisational culture.