Code of Conduct

TITLE I – GENERAL PART

Capítulo I (General Provisions)

Article 1 (Scope)

This Code of Conduct, hereinafter referred to as the Code, establishes the principles and rules regarding ethics and professional conduct to be observed, in relations among themselves and with third parties, by all those who, under any legal-employment status, perform functions at the company MEAT HERITAGE, LDA, hereinafter referred to as “addressees of this Code” or “employees”. Members of management are subject to the provisions of this Code, with the necessary adaptations.

Article 2 (Duties)

This Code does not affect the legal rules to which all those performing functions at the company are subject, namely:

a) Collective Bargaining Agreements;
b) Labour Code, complementary legislation;
c) Private law rules.

Capítulo II (Principles)

Article 3 (Ethics)

The addressees of this Code must carry out their activity in compliance with the following principles:

Legality: They must always act in accordance with the legal and regulatory rules in force, within the limits of the powers assigned to them and in accordance with the purposes for which they were conferred.
Objectivity and Impartiality: They must act towards all those who interact with the company in a neutral, objective, and fair manner.
Equality: They must not practice any type of discrimination based on race, sex, age, ancestry, language, political, ideological or religious beliefs, social condition, or economic situation.
Loyalty: They must always act according to the principle of good faith, constantly aiming for the achievement of the public interest, without neglecting the consideration of the rights, legitimate interests, and claims of those who interact with the company.
Information: They must provide the information and/or clarifications that are due in a prompt, clear, rigorous, and courteous manner.
Integrity: They must act, under all circumstances, with integrity of character, honesty, and respect for others.
Responsibility: They must perform the functions or tasks assigned to them in a competent and committed manner, with rigor, zeal, and a constructive critical mindset.

Article 4 (Social Responsibility)

In carrying out its activity, the company and its employees must respect the values of human dignity and those of heritage preservation, the environment, and sustainability, paying particular attention to the topics of organizational social responsibility, innovation, permanent updating of knowledge, and professional development. The company does not tolerate, under any circumstances, the use of child labor or forced labor, nor any form of human trafficking, in any of its operations, committing to verifying the legal minimum age of admission for all employees. The company recognizes and respects the right of workers to freedom of trade union association and collective bargaining, under the terms of the law and applicable collective labor agreements, committing to maintaining a constructive and good-faith dialogue with workers’ representatives and trade union organizations whenever they exist. The company commits to ensuring good working conditions for all employees, in compliance with applicable labor legislation, namely regarding working hours, rest periods, punctuality in the payment of remuneration and benefits, and proper formalization of the employment contract. The company commits to promoting a safe and healthy working environment, providing employees with the necessary personal protective equipment and training for the safe performance of their duties, and maintaining facilities in adequate conditions of hygiene and safety.

Capítulo III (Confidentiality)

Article 5 (Professional Secrecy)

The addressees of this Code are subject to professional secrecy under the terms provided in employment contracts and other applicable legislation. The breach of the duty of professional secrecy shall be sanctioned under the terms provided by law.

Article 6 (Personal Data)

The addressees of this Code who access, work with, or in any way become aware of personal data relating to natural or legal persons are required to respect the legal provisions regarding the protection of such data, and may not use them except for the purposes imposed by or inherent to the functions they perform at the company and in accordance with applicable internal regulations.

Article 7 (Misuse of Information)

The addressees of this Code must refrain from using information to which they have access exclusively in the context, and as a consequence, of the functions they perform at the company (“inside information”) in any other scope than the performance of those duties, under abnormally advantageous conditions as a consequence of access to such information. Obtaining any advantage and/or financial/material benefit resulting from access to “inside information” is also considered unlawful, unless it concerns the use of such information in the context of intellectual work, such as academic or other studies, and there is prior authorization from Management. The addressees of this Code must adopt reasonable measures within their reach to prevent unauthorized access, use, alteration, loss, disclosure, or transmission of confidential information, personal data, internal documents, commercial, technical, or operational information of the company, its workers, clients, suppliers, or partners.

Capítulo IV (Conduct)

Article 8 (Conflict of Interest)

The addressees of this Code are required to inform, at the beginning of their respective functional relationship with the company, of the existence of any conflicts of interest, these being broadly understood as any facts, situations, or other factors that, objectively or subjectively, directly or indirectly, prove capable of compromising, or in any way affecting, the duty of objectivity and impartiality to which the addressees of this Code are subject in the performance of their duties. The disqualification provided for in the preceding paragraph also applies with reference to representatives and business managers of the persons indicated in that paragraph. Employees who maintain marital, kinship, or similar relationships with each other must communicate this to Management whenever there is a direct hierarchical relationship or functions that could generate a conflict of interest, for the purposes of evaluating and managing the situation.

Article 9 (Recusal)

The addressees of this Code must request recusal from participating in a company procedure, act, or contract when circumstances arise that could reasonably raise doubts about the impartiality of their conduct or decision, specifically in the following cases:

When they are creditors or debtors of a natural or legal person with a direct interest in the company’s procedure, act, or contract;
When they have received any gift from a natural or legal person with a direct interest in the procedure, act, or contract;
If there is severe enmity with the person with a direct interest in the procedure, act, or contract;
If there is close intimacy with the person with a direct interest in the procedure, act, or contract;
When a court action is pending in which company employees are parties on one side, and on the other, the natural or legal person with a direct interest in the company’s procedure, act, or contract.

The provisions of the preceding paragraph apply equally with reference to spouses of company employees, relatives or in-laws in the direct line, or persons with whom company employees live in a common household. Requests for recusal under the provisions of the preceding paragraphs must be addressed to company management, indicating the facts justifying them, with Management responsible for determining whether or not a circumstance determining recusal and/or disqualification exists.

Article 10 (Disciplinary Sanctions)

Non-compliance by company employees with the provisions of Articles 8 and 9 constitutes a serious offense for disciplinary purposes.

Article 11 (Gifts, Benefits, and Corruption Prevention)

The addressees of this Code may not request, accept, promise, or offer, in the context of performing their functions, any gifts, benefits, invitations, commissions, favors, payments, or other advantages that could influence, or appear to influence, their independence, impartiality, or professional decision. Only gifts or acts of courtesy of symbolic value, occasional, socially appropriate, and compatible with customary practice followed within the scope of normal, typical, and necessary institutional relationships of the company with external entities may be accepted, provided they are not associated with decision-making, contracting, negotiation, approval, supervision, evaluation, or dispute resolution processes. The addressees of this Code must refrain from practicing, promising, requesting, accepting, or tolerating any form of corruption, bribery, undue payment, illegitimate favoritism, fraud, document forgery, money laundering, or other illegal practice capable of compromising the legality, transparency, impartiality, or reputation of the company. The use of functions performed at the company to obtain personal, material, or any other nature of advantage, for oneself or for third parties, is prohibited. Whenever there is doubt regarding the admissibility of a particular gift, invitation, benefit, or situation likely to create the appearance of favoritism, the addressee must refrain from accepting it or report the situation to management or the competent hierarchical superior for evaluation.

Article 12 (Reporting of Irregularities and Whistleblowing Channel)

The addressees of this Code must report, through internally defined means or via the whistleblowing channel provided by the company through a dedicated form available on its internet portal, meatheritage.com, facts or substantiated suspicions of violation of this Code, the law, or other applicable internal rules. Matters subject to communication include, specifically, situations related to corruption, fraud, conflict of interest, harassment, discrimination, child labor, forced labor, or human trafficking, personal data breach, breach of confidentiality, misuse of information, serious labor non-compliance, or other relevant irregularities. Reports made in good faith will be handled with discretion, confidentiality, and protection against retaliation, pursuant to applicable law. The management of the whistleblowing channel is assured by the Human Resources Department, which notifies the whistleblower of the receipt of the report within seven days and communicates to them the measures envisaged or adopted, and the respective grounds, within a maximum period of three months from receipt, extendable up to six months in cases of greater complexity. The report may be submitted in writing or orally, including by telephone or, at the whistleblower’s request, in an in-person meeting, with the respective record preserved for a minimum period of five years. The abusive, intentional, or manifestly unfounded use of reporting mechanisms may constitute a disciplinary offense, without prejudice to potential legal liability.

Article 13 (Assets and Environment)

The addressees of this Code must safeguard the company’s assets, not permitting abusive use by third parties of available facilities and material resources. Appropriate environmental protection practices must be adopted, specifically in the selective collection of solid waste.

Article 14 (Use of Resources)

The addressees of this Code, in the exercise of their functions at the company, must use available material means and equipment as economically and efficiently as possible. Technological communication resources, specifically fax and internet, must be used for professional purposes, and non-reputable or unsafe websites must not be visited nor files imported from them. It is prohibited to copy, modify, or transfer software provided for the exercise of functions at the company for personal use, as well as installing games or similar applications on individual workstations that are not included in the installed software.

Chapter V (Relations with Third Parties)

Article 15 (Relations with the Public)

The addressees of this Code, in relationships with third parties external to the company (clients and interested parties in ongoing situations within the company and others), shall respect the principles described in the preceding Article 3, striving to ensure their conduct is permanently characterized by technical rigor, efficiency, availability, and courtesy in personal interaction.

Article 16 (Suppliers and Partners)

Relations with suppliers of goods and services must comply with the principles of transparency, objectivity, impartiality, legality, quality, food safety, confidentiality, and prevention of conflicts of interest. Whenever applicable, internal procedures for supplier approval, qualification, selection, evaluation, and re-evaluation must also be observed, as well as requirements defined regarding sustainable procurement and supplier conduct. The addressees of this Code who intervene in consultation, negotiation, contracting, reception, approval, or evaluation processes of suppliers must act in an objective, loyal, and documentable manner, refraining from any conduct capable of generating undue favoritism, conflict of interest, or detriment to the company.

Article 17 (Media)

The addressees of this Code may only grant interviews to media outlets, publish opinion articles, provide information, or publicize texts of any nature, whatever the dissemination medium, regarding matters related to the duties and mission of the company, with prior authorization from management. Cases in which company employees are acting in representation of the company are excluded from the preceding paragraph.

TITLE II (Sanctions Regime)

Article 18 (Sanctions Regime)

Violation of this code of conduct entails the application of disciplinary sanctions, taking into account the severity and the rule violated. The following disciplinary sanctions may be applied to the offender:

Reprimand;
Written reprimand;
Pecuniary sanction;
Loss of vacation days;
Suspension from work with loss of pay and seniority;
Dismissal without compensation or indemnity.

The sanctions regime follows the rules of procedure, application, and decision provided for in the Labour Code and applicable collective labour agreements, with the necessary adaptations.

TITLE III – ENTRY INTO FORCE

Article 19 (Entry into Force)

This Code enters into force on the day of its publication on the company’s website and intranet, and applies, from that date, to all its addressees.

Marinha Grande, April 9, 2026 Management