Code of Ethics
and Standards of Conduct

What we value

Identity and Ethics

In the field of companies, image and self-identity are specific characteristics that are based on compartmentalized practices and moral values assumed by by most of their employees.

Diversity

The diversity of people and experience sometimes leads to a natural divergence of concepts and values, so it is the task of an organization to inform, educate, explain and demand ideas, values and the different ways of acting that are practiced according to what our company's our company's ethical standards.

Moral values

Considering that moral values and the assimilation of principles are individual issues with a direct impact on the collective, it is necessary for PowerShield to PowerShield establish and clarify the most relevant aspects of this issue, in order to reinforce the company's company's guiding principles.

Procedures

At PowerShield, the current restructuring of procedures, professionalizing the management component and endowing it with quality principles, must therefore be accompanied by a performance benchmark that we can be proud of.

Scope and Objectives

The Code of Ethics now published is intended for all PowerShield employees, regardless of their contractual relationship or hierarchical position. position.

PowerShield's Code of Ethics is intended to clarify, recall and disseminate a set of standards of and complementary information to serve as a guiding instrument for the development of the company's internal activities. the company's internal activities.

PowerShield will consider any failure to comply with this Code to be serious misconduct. If the employee believes that they have breached the Code for any reason, they must immediately inform their superior.
Disciplinary action resulting from non-compliance with this Code may range from a verbal warning to the immediate to immediate termination of the employment contract. Certain specific breaches of the Code may result in civil and/or criminal proceedings.

Behavior patterns

Formalize the standards of behaviour expected of employees in the performance of their duties, ensuring compatibility and consistency with PowerShield's values.

Continuous growth

 Promote the internalization and values and ethical standards among all employees.

Good relationship between partners

Solidifying good relations between employees, customers, suppliers and other stakeholders in PowerShield's business.

Our values

Powershield employees must act according to the following set of core values: honesty, integrity, rigor, cooperation, commitment and loyalty. These values must be present in all interactions involving employees, customers, suppliers and the general public. This attitude of the organization should be achieved through the individual conduct of each company employee.

Powershield's employees must conduct themselves in an behavior, always contributing to the search for the truth. In the event of any irregularity, fraud or crime, they must facilitate the investigation and implementation of appropriate administrative in order to clarify the situation and preserve the honor and dignity of the position they hold. they hold.

Powershield employees must behave with integrity, correctness and honesty, faithful to the company's values established in the company, and act with loyalty, fairness, a sense of respect, seriousness and transparency in fulfilling the defined strategy.

Powershield employees must act with a sense of accuracy, in order to ensure that the projects/tasks assigned are carried out on time, with the requirements and costs defined. costs, and must carry them out with integrity and a sense of responsibility, always in accordance with the the organization's mission, objectives and standards.

Powershield employees must behave in such a way as to promote cooperation and teamwork, contributing their own teamwork, contributing their own knowledge to the collective work and building relationships of trust and solidarity necessary to achieve the common goal, which translates into the success of the success of the organization.

Powershield employees must carry out their tasks with commitment, demonstrating involvement in the definition and pursuit of the company's objectives, in an available and dedicated manner. A attitude must be proactive and dedicated in order to improve individual and team performance, facilitating the achievement of collective teams, facilitating the achievement of collective objectives.

Powershield employees must at all times, and always in compliance with the law, behave with behavior towards colleagues, superiors and the institution in general, acting in a way that protects the credibility, prestige and good image of Powershield. institution, acting in such a way as to protect Powershield's credibility, prestige and good image. They must also act with integrity, impartiality and fairness in the analysis and execution of decisions taken on behalf of the company. the company.

Compliance with legislation

Compliance with legislation and other regulations. Powershield employees must, at all times, respect and ensure compliance with internal legislation in force and other applicable regulations. Employees must not, by action or inaction, contribute to the existence of situations that constitute a violation of current legislation or regulations.

Article 35 of Law 34/2013 of May 16, amended by Law no. 46/2019 of July 8, establishes that private security entities and personnel, must provide the public authorities with any cooperation requested of them.

Article 6 of Law 34/2013 of May 16, as amended by Law 46/2019 of July 8, establishes that private security entities and personnel are bound by professional secrecy, may only be breached under the terms provided for in criminal and civil procedural legislation, or in other situations provided for by law.

Article 6-A of Law 34/2013 of May 16, as amended by Law No. 46/2019 of July 8, establishes that private security personnel must:
a) Respect the fundamental and other rights of citizens:
b) Conduct themselves with integrity and in accordance with legal principles;
c) Maintain a discreet and resilient attitude;
d) Not maintain links with illegal activities;
e) Not disturb public order;
f) Provide assistance to people in danger.

Rules of conduct

Employees must assume the responsibilities assigned to them in accordance with their duties, acting in such a way as to achieve the objectives of the company and its Structure Unit. They must perform their duties properly, diligently, diligent, loyal, assiduous, punctual and conscientious performance of their duties, in accordance with the rules and instructions received and observing the legal and customary rules of professional ethics and labor relations. Employees must use the power delegated to them sparingly, with the company's objectives in mind and not their own. the company's objectives and not their own personal ones.

All employees must contribute to creating a healthy working environment. They must adopt a cordial, cooperative and cooperative attitude, seeking to avoid conflicts and guiding their actions by the rules of common sense and respect for others.

Employees should not try to gain personal advantage at the expense of others, and should respect and make themselves respected by all those with whom they have to deal professionally.

All employees should strive for personal and professional development, making a more effective contribution to improving interpersonal interpersonal relationships and to the organization's objectives. Employees with responsibilities should provide their teams with the information and training necessary for this purpose. necessary for this purpose.

PowerShield must evaluate its employees on the basis of objective criteria that reflect the merit of their professional performance.

All employees are subject to the duty of professional secrecy, in accordance with the terms and and legal limitations, with regard to information circulating or handled within the company. a reserved and discreet attitude towards the facts and information of which they are aware. knowledge. This attitude is especially relevant when it comes to secret, confidential or restricted information, confidential or restricted information, in which case the employee is obliged to follow the rules for handling handling information classified as such. Confidential company company with unauthorized persons, not even relatives and/or friends.

Whenever, in the course of their work at Powershield, employees intervene in proceedings involving, directly or indirectly:
- other entities with which they collaborate, outside their contractual relationship with the company;
- entities where they have worked and/or maintain interests;
- entities managed by people with whom they maintain or have maintained ties of kinship or other type of affinity;

They must report any of these latent conflicts of interest to their hierarchical superior. Employees must refrain from collaborating with third parties whose objectives are competitive or otherwise contrary to the interests of Powershield's business.

Employees should avoid assuming positions that in any way infringe the principles of segregation of duties; employees themselves should recognize the imminence or existence of these existence of these situations, acting proactively and formally to avoid them.

In order to maintain irreproachable behavior, employees must refuse to get involved in ethically reprehensible situations, whether these external or internal pressures (from other employees or superiors). hierarchical). They must not accept or promote any kind of favours that could influence internal decisions or those of external entities.
Obtaining information illegally is not permitted. Offers received from third parties, including gifts or participation in events with clear entertainment components, must be declared to hierarchical superiors and refused if there are indications of dubious intentions on the part of the offerors. on the part of the offerors.

Any attitude that discriminates against the people with whom we have professional contact on the basis of color, sex, religion, origin, social class, political political beliefs, language, sexual orientation, age or physical disability. PowerShield does not accept behavior in its employees of insinuation, solicitation and/or demand of sexual favors by one individual towards another. This also applies to hostile, intimidating hostile, intimidating or offensive conduct of a sexual nature.

PowerShield expects its employees to treat each other in accordance with universal moral rules. rules. PowerShield recognizes the United Nations Universal Declaration of Human Rights.

PowerShield employees should avoid private contacts in order to obtain personal advantages with entities with which PowerShield PowerShield has a commercial relationship.

Use of company or client resources where services are provided are made available to employees for to be used for purposes directly related to PowerShield's business objectives. objectives of PowerShield. Employees must ensure the conservation of assets related to their work, within the limits of wear and tear attributable to normal use, accidents and risk of activity.

Communications to the media or should reflect the image of the company and its objectives, by truthful information. They should also promote the defense of the values of the society in which we the environment and human dignity.

All external communication of this kind must be assessed by the company's highest executive management bodies. executive management of the company.

All employees must be aware of the importance of the customer. They are an essential part of the company.
Commitment to customer satisfaction must be reflected in respect for their rights and in the search for solutions that meet their interests, always in line with the company's objectives of development and profitability. PowerShield employees must serve their customers with courtesy and customers with courtesy and efficiency, offering clear, precise and transparent information.

The customer must receive answers, even if negative, to their requests, in an appropriate manner and within the expected, without preferential treatment being given to anyone out of personal interest or feeling. interest or personal feeling.

Employees must maintain a professional, polite, respectful and diligent attitude in all contacts they have with external entities, be they clients, suppliers or others. Employees employees must do their utmost to be efficient in their contacts with the outside world, seeking to ensure that any requests addressed to them are dealt with in a timely manner.

PowerShield shall adopt an impartial attitude in its its relationship with suppliers and service providers, selecting them not only on the basis of criteria of quality and efficiency, but also on their ethical stance as perceived by society at large. perceived by society in general. Contracts with suppliers and service providers must be drawn up in good faith, without ambiguity or omission, and in compliance with the legislation in force and other internal internal rules in force at PowerShield.

PowerShield shall provide the regulatory, supervisory, judicial and police authorities with all the collaboration within its reach, providing them with the information requested in a clear and timely manner, providing them with the information requested in a clear and timely manner, making itself available for further clarification and, in general, not adopting any behavior that could impede the actions of these entities. The provision of third parties may require their prior authorization.

Fair competition must be the basic element in all operations and relationships with other companies in the same industry as PowerShield. A competitiveness must be exercised on the basis of this principle. No comments should be made that may affect the image of competitors or contribute to spreading rumors about them. Other other institutions should be treated with the same respect with which the company expects to be treated.

It is forbidden to provide PowerShield's proprietary information to competitors.

CHARACTERIZATION OF HARASSMENT

Regardless of the form, the following are common characteristics of harassment:

- Repetition - harassment presupposes the repeated practice of a set of acts / behaviors;
- Intentionality - the acts / behaviors are directed at the victim with the intention of affecting their dignity and deteriorating their moral and / or physical integrity, and may cause the victim's ability to resist or repel a situation they do not want by placing them in a position of embarrassment, subjection or fragility;
- Taking advantage of a weakness - harassment means taking advantage of the victim's weakness or professional/hierarchical position.

The following situations do not constitute harassment
a) the decisions of the hierarchy that are legitimized in the rules of work organization and in the employment contract;
b) the legitimate exercise of hierarchical or disciplinary power (e.g. performance appraisal, disciplinary procedure, etc.);
c) pressure arising from the normal performance of duties.

Harassment at work

Unwanted and repeated behavior, particularly that based on discrimination, with the aim or effect of disturbing or embarrassing the person concerned, affecting their dignity, or creating an intimidating, hostile, degrading, humiliating or destabilizing environment.

Among others, the following are considered to be forms of harassment at work:
- Discrimination;
Use of and access to electronic media;
- Access to employment, work or vocational training.

Sexual harassment

Harassment is sexual when such unwanted verbal or physical behavior is sexual in nature.

Among others, the following are considered forms of sexual harassment:
- Sexual innuendo;
- Jokes and/or comments about your appearance that have offended you;
- Jokes and/or offensive comments about your body;
- Sexually offensive jokes and/or comments;
- Unwanted sexual attention;
- Invitations to unwanted meetings;
- Explicit and unwanted proposals of a sexual nature;
- Unwanted sexual propositions via email, SMS or through websites and social networks;
- Offensive phone calls, letters, SMS, emails or images of a sexual nature;
- Insinuating looks;
- Intrusive and offensive questions about private life;
- Physical contact and sexual assault; Unwanted physical contact (touching, moving, grabbing, groping, kissing or trying to kiss);
- Sexual assault or attempted sexual assault;
- Grooming;
- Requests for sexual favors linked to promises of employment or improved working conditions.

Moral Harassment

Bullying is moral harassment when it consists of verbal attacks with offensive or humiliating content, physical attacks or very subtle acts, which may include physical and/or psychological violence, aimed at lowering the victim's self-esteem and ultimately causing them to quit their job.

Among others, the following are considered to be forms of bullying:
- Social isolation;
- Promoting isolation or lack of contact with colleagues;
- Promoting isolation or lack of contact with managers. Code of Good Conduct for Preventing and Combating Harassment at Work;
- Professional harassment;
- Setting goals that are impossible to achieve;
- Systematic devaluation of work;
- Inadequate duties.
- Intimidation;
- Systematic threats of dismissal;
- Being the target of stressful situations with the aim of provoking lack of control;
- Personal humiliation;
- Suffering humiliation due to physical, psychological or other characteristics.

Prevention

It is our duty to reject any behavior that denotes a lack of respect, bearing in mind that harassment is determined by how others perceive our actions, regardless of our original intentions.

POWERSHIELD is committed to:
- Encourage good relationships in the workplace, promoting a climate of tolerance for diversity and respect for difference, managing conflicts appropriately;
- Disclose the gift internally to all employees, holders of management positions and the Board of Directors;
- Promote training and awareness-raising actions on the topics of preventing and combating harassment at work;
- Providing support to Employees who are victims of harassment at work;
- To flag, monitor and forward all situations that indicate the practice of harassment, particularly through the Occupational Medicine service;
- Respond to questions and suggestions related to harassment at work;
- Dealing with reports of harassment at work and initiating disciplinary proceedings whenever the legal requirements for this purpose are met;


Investigation and Resolution Procedures

The investigation and resolution process is conducted by the Compliance Officer with external legal support, guaranteeing impartiality, equality and transparency in all procedures for all those involved (complainant, accused and witnesses).

They should preferably use the "Integrity and Compliance Channel", which can be accessed via POWERSHIELD's online page.

Whenever it becomes aware of alleged situations of harassment, POWERSHIELD will initiate a prior investigation procedure or any other procedure it deems appropriate, within the time limits and in accordance with the terms set out in the Labor Code, and, in this context, it must carry out all the investigative steps necessary to ascertain the truth.

Confidentiality is guaranteed with regard to complainants, witnesses and the complaint, until such time as a statement of fault is issued.

All the people involved in the investigation process for alleged harassment will act in strict compliance with the principle of equality and the duties of secrecy and confidentiality, and are obliged not to disclose any information they have access to within the scope of the process, in relation to any of the people involved (complainant, accused and witnesses).


Sanctions

Workers involved in prohibited behavior, as well as those who report it in bad faith, are subject to disciplinary action, including dismissal without compensation.

Harassment entitles the victim to compensation for pecuniary and non-pecuniary damage, in accordance with the provisions of the Labor Code on compensation for discriminatory acts.

Harassment also constitutes a very serious offense, as provided for in the Labor Code, without prejudice to any criminal liability provided for under the law, and may give rise to the respective procedures to be instituted by the competent authorities.


CONFIDENTIALITY AND GUARANTEES

Within the scope of reports made, POWERSHIELD guarantees:

- Respect for the Principles of Confidentiality, Non-Retaliation and Data Protection and Information Security;
- Sending information to the complainant about the status of the process;
- That the complainant and the witnesses indicated by him/her cannot be subject to disciplinary sanctions, unless they act with intent, based on statements or facts contained in the records of proceedings, judicial or administrative offense, triggered by harassment until a final decision, final and unappealable, without prejudice to the exercise of the right to adversarial proceedings;
- The reasons for the decision to archive the procedure.

The Code of Ethics is managed by the Security Department, which is responsible for communicating it, updating and enforcement.

As a result of its activity and its particular position in the national private security system, PowerShield system, PowerShield sees itself as a company with particular responsibilities in social terms. PowerShield PowerShield employees must be fully aware of this fact, and aware of the possible possible impacts that their professional actions or omissions may have at a social level.

Ethical problems, for the most part, are not themselves, but arise in front of them, forcing them to deal with them.

The general lines of this Code make it possible to assess a large number of situations, but they don't necessarily detail all the problems that can arise on a daily basis, not necessarily detail all the problems that may arise on a day-to-day basis. As a result, doubts may arise about the correct course of action. In these cases, you should immediately immediately and formally.

Licenses no. 216 A,B and C

In the event of a dispute, the consumer can turn to a Alternative Dispute Resolution: CACCL - Lisbon, Tel.: 218 807 030.
More information on the Consumer Portal www.consumidor.pt

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