Compliance Program

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EPOS has implemented a compliance management program, or compliance management, whose compliance is mandatory for all employees.

The compliance program establishes a set of measures and procedures based on the Compliance Policy, the Code of Ethics and Conduct and the Mission and Values of the Teixeira Duarte Group in order to ensure with greater effectiveness and evidence of compliance with the law and internal rules, contributing to a climate of integrity and ethical culture in the development of the Company’s activities.

The compliance system provides for risk assessment processes and financial and non-financial internal control procedures.

Combating corruption and bribery, money laundering and terrorist financing.

The compliance system also ensures the implementation and evaluation of the effectiveness of the Code of Ethics and Conduct, according to which employees must act in order to assess and avoid possible situations of conflict of interest, as well as prevent any corrupt behavior, in active or passive form, including payments or facilitation receipts, or the creation, maintenance or promise of irregular situations or favor.

They are obligated to report any actions that constitute misconduct, including those that constitute possible illegal or unlawful practices in financial and accounting matters, fraud, corruption and money laundering, as well as any actions related, directly or indirectly, to terrorist entities or that may target or support terrorism practices.

They are also responsible for promoting that the indirect addressees of the Code also do so.

Employees must guide their actions in order to actively combat any money laundering attempts, refusing to participate in any act that can be considered as such, under the legal and regulatory rules in force, as well as in any attempt, complicity, facilitation or advice to its practice.

Likewise, they must act in such a way as to prevent the company’s activity from in any way providing, collecting or holding funds or assets that may be used for the financing and support of criminal activities, including terrorists.

EPOS - Empresa Portuguesa de Obras Subterrâneas, S.A.

Relationship with the Competition

Competition is a natural and healthy consequence of the market that promotes excellence and efficiency of companies. In this sense, Employees must adopt a position of truth and commitment towards the Company’s and the Group’s competitors, always in accordance with the applicable law and internal rules.

Employees must therefore assume – and promote that the recipients of this Code also assume – the commitment to scrupulously respect market and competition rules, acting truthfully in a serious and loyal manner, avoiding restrictive practices or abuses of dominant position, and must ensure that the company relates to competing entities in a healthy manner, in good faith and promoting mutual respect.