Chapter I

(General Provisions)

Article 1

(Scope)

1. This Code of Conduct, hereinafter referred to as the Code, establishes the principles and rules on ethics and professional behaviour to be observed, in relations with each other and with third parties, by all those who, in any legal and labour capacity, exercise functions in the companies Panigest, SGPS, S.A., Meat Heritage, Lda, Raízes do Prado, Lda (companies), hereinafter referred to as “addressees of this Code” or “employees”. 2. The members of the board of directors/management shall be subject to the provisions of this Code, mutatis mutandis.

Article 2

(Duties)

This Code is without prejudice to the legal rules to which all those who exercise functions in companies are subject, namely:

• a) Collective Bargaining Agreements;
• b) Labour Code, complementary legislation;
• c) Rules of private law.

Chapter II

(Principles)

Article 3

(Ethics)

The addressees of this Code must carry out their activities in accordance with the following principles:

• a) Legality – they must always act in accordance with the legal and regulatory rules in force, within the limits of the powers conferred on them and in accordance with the purposes for which they were conferred on them.
• b) Impartiality and Impartiality – they must act towards all those who relate to companies in a neutral, objective and fair manner.
• c) Equality – they must not practice any type of discrimination on the basis of race, sex, age, ancestry, language, political, ideological or religious convictions, social condition or economic situation.
• d) Loyalty – they must always act according to the principle of good faith, with a permanent view to achieving the public interest, without neglecting the consideration of the rights, legitimate interests and claims of those who relate to the companies;
• e) Information – they must provide the information and/or clarifications that are due in a fast, clear, rigorous and affable manner.
• f) Integrity – they must act, in all circumstances, with rectitude of character, honesty and respect for others.
• g) Responsibility – they must perform the functions or tasks assigned to them in a competent and committed manner, with rigor, zeal and constructive critical spirit.

Article 4

(Social Responsibility)

In the development of their activity, companies and their employees must respect the values of human dignity and the preservation of heritage, the environment and sustainability, paying particular attention to the themes of social responsibility of organizations, innovation, the permanent updating of knowledge and professional development.

Chapter III

(Confidentiality)

Article 5

(Professional Secrecy)

1. The addressees of this Code shall be subject to professional secrecy under the terms of employment contracts and other applicable legislation. 2. Violation of the duty of professional secrecy shall be sanctioned in accordance with the provisions of the law.

Article 6

(Personal Data)

The recipients of this Code who access, work or in any way become aware of personal data relating to natural or legal persons are obliged to comply with the legal provisions provided for by law regarding the protection of such data, and may only use them for the purposes imposed or inherent to the functions they perform in companies and in accordance with the applicable internal regulations.

Article 7

(Misuse of Information)

1. The addressees of this Code must refrain from using the information to which they have access exclusively in the context of, and consequently, the functions they perform in companies (“inside information”) in a context other than the performance of those duties, under conditions that are abnormally advantageous as a result of access to such information. 2. It is also considered illegal to obtain any advantage and/or patrimonial/financial benefit arising from access to “privileged information”, unless the use of such information in the context of work of an intellectual nature, such as academic studies or others, is at stake and there is prior authorization from the board of directors.

Chapter IV

(Acting)

Article 8

(Conflict of Interest)

1. The addressees of this Code are obliged to inform at the beginning of their functional relationship with the companies the existence of any conflicts of interest, by which they are generally understood to be any facts, situations or other factors that, objectively or subjectively, directly or indirectly, are likely to jeopardize, or in any way affect, the duty of impartiality and impartiality to which the addressees of this Code are subject in the performance of their duties. 2. The employees of the companies may not intervene in any procedure, act or contract of the companies when they have an interest in them, or such an interest exists on the part of:

• a) Of the respective spouse or person with whom the employee of the companies lives in conditions similar to those of spouses;
• b) Of a relative or relative in a direct line or up to the second degree of the collateral line;
• c) Any person with whom the employee of the companies lives in a common economy or with whom he or she has an adoption, guardianship or civil sponsorship relationship.

3. The impediment provided for in the preceding paragraph shall also occur by reference to representatives and business managers of the persons referred to in that paragraph.

Article 9

(Excuse)

1. The addressees of this Code must request exemption from intervening in a company’s procedure, act or contract when a circumstance arises by which the impartiality of their conduct or decision may reasonably be doubted, namely in the following cases:

• a) When they are creditors or debtors of a natural or legal person with a direct interest in the procedure, act or contract of the companies;
• b) When they have received a gift from a natural or legal person with a direct interest in the procedure, act or contract;
• c) If there is serious enmity with the person with a direct interest in the procedure, act or contract;
• d) If there is great intimacy with the person with a direct interest in the procedure, act or contract;
• e) When an action is pending before the Court in which the parties are employees of the companies, on the one hand, and, on the other, the natural or legal person with a direct interest in the procedure, act or contract of the companies.

2. The provisions of the preceding paragraph shall also apply by reference to the spouses of the employees of the companies, relatives or relatives in a direct line, or persons with whom the employees of the companies live in a common economy. 3. Requests for exemption under the provisions of the preceding paragraphs shall be addressed to the board of directors/management of the companies, indicating the facts justifying them, and the board of directors shall be responsible for determining whether or not there is a decisive circumstance of excuse and/or suspicion.

Article 10

(Disciplinary sanction)

Failure by the employees of the companies to comply with the provisions of articles 8 and 9 constitutes serious misconduct for disciplinary purposes.

Article 11

(Gifts and other Benefits)

The addressees of this Code may not request or accept, in the context of the performance of their corporate duties, any offers or benefits of any nature that do not fit into the usual practice followed within the scope of the normal, typical and necessary institutional relationship of companies with external entities.

Article 12

(Suspicions)

1. The addressees of this Code must inform their superiors of any suspicions they have regarding behaviour and situations that violate the provisions of this Code. 2. The hierarchical superiors to whom the suspicions referred to in the preceding paragraph are informed shall promptly communicate them to the board of directors, which shall examine them and, if necessary, decide on the steps to be taken. 3. The information of suspicions provided for in this Article shall enjoy the protection recognized by law.

Article 13

(Heritage and Environment)

1. The addressees of this Code shall safeguard the assets of companies by not allowing the misuse by third parties of the facilities and material resources available. 2. Appropriate environmental protection practices must be adopted, namely in the separate collection of solid waste.

Article 14

(Resource Utilization)

1. The addressees of this Code, in the exercise of their functions in companies, shall use the material resources and equipment available in the most economical and efficient manner possible. 2. Communication technological resources, namely fax and the internet, must be used for professional purposes, and websites or files from websites that are not reputable and secure must not be consulted. 3. It is forbidden to copy, modify or transfer, for personal use, software made available for the exercise of functions in the companies, as well as the installation of games or the like on individual workstations that are not included in the installed software.

Chapter V

(Relations with Third Parties)

Article 15

(Relationship with the Public)

The addressees of this Code, in their relationship with third parties to the companies (clients and interested parties in situations in progress in the companies and others) shall respect the principles described in the previous article 3, seeking that their performance is permanently characterized by technical rigor, efficiency, availability and correctness in personal treatment.

Article 16

(Suppliers)

Relations with suppliers of goods and services comply with the rules established in the legal regime of public procurement and are permanently subject to the principles of transparency, impartiality and impartiality.

Article 17

(Social Communication)

1. The addressees of this Code may only grant interviews to the media, publish opinion articles, provide information or publish texts of any nature, whatever the means of dissemination, relating to matters related to the duties and mission of the companies with the prior authorisation of the board of directors. 2. Cases in which the employees of the companies are acting on behalf of the companies are excluded from the previous paragraph.

TITLE II

Article 18

(Sanctioning regime)

1. Violation of this code of conduct shall result in the application of disciplinary sanctions, taking into account the seriousness and the rule violated. 2. Disciplinary sanctions may be applied to the offender:

• a) Reprimand;
• b) Recorded reprimand;
• c) Financial penalty;
• d) Loss of vacation days;
• e) Suspension of work with loss of remuneration and seniority;
• f) Dismissal without compensation or compensation.

3. The sanctioning regime follows the rules of procedure, application and decision provided for in the applicable Labour Code and RCT, with the necessary adaptations.

TITLE III

VALIDITY

Article 19

(Entry into force)

This Code enters into force on the day of its disclosure on the companies’ websites and intranets and applies, from that date, to all its addressees.