CODE OF CONDUCT – CORRUPTION AND RELATED OFFENCES
Code of Conduct
Following the approval of the 2020-2024 National Anti-Corruption Strategy, Decree-Law No. 109-E/2021 of December 9th established the National Anti-Corruption Mechanism (hereinafter referred to as “MENAC”) and the General Regime for the Prevention of Corruption (hereinafter referred to as “RGPC”).
Therefore, and in compliance with Decree-Law No. 109-E/2021 of December 9th, A. Sampaio adopted a Regulatory Compliance Program (hereinafter referred to as “PCN”), the scope of which aims to prevent, detect, and sanction acts of corruption and related offences committed against or through A. Sampaio.
Under said legislation, and incorporated into the PCN, the Code of Conduct – Corruption and Related Offences was developed. It includes a set of values that govern A. Sampaio’s activities and a set of ethical and deontological rules that apply to members of the Company’s Governing Bodies and all Employees and Interns (hereinafter referred to as “Employees”) in their relationships with each other and with Customers, Suppliers, and other Stakeholders. This Code aims to prevent, detect, and sanction acts of corruption and related offences.
The following Code of Conduct is reviewed every three years, or whenever justified, particularly taking into account the assessment of A. Sampaio’s risk of exposure to corruption crimes and related offences or significant changes to A. Sampaio’s organisational or corporate structure or functional content. Furthermore, this Code of Conduct is communicated both internally and externally (via the website) and submitted to the MENAC electronic platform within 10 days of its implementation and/or any subsequent revisions.
We have always based our decisions on the values we value most—Dedication to Work, Trust, Transparency, and Social Responsibility—combined with our focus on Technology, Innovation, Know-How, Flexibility, and Sustainability. The blend of all these factors distinctively marks the essence of our business model and A. Sampaio’s path in the national and international textile industry.
At A. Sampaio, we pride ourselves on building relationships based on Trust and Transparency. These relationships underpin our company’s and all our partners’ success in an economy that is increasingly moving towards a circular model. We create value while respecting the ecosystem and everyone’s future.
The rules contained in this Code must be understood, accepted, and practised by all A. Sampaio Employees, regardless of their hierarchical position or specific roles and responsibilities.
- Bribery or Corruption – A. Sampaio does not tolerate any practice of corruption or bribery, whether active or passive, or other forms of undue influence or illicit conduct, particularly through the undue offer or acceptance of compensation or benefits, regardless of their value, intended to influence the behavior of others to obtain advantages for the Employee or the company.
- Related Offences – A. Sampaio also does not tolerate any practice that may constitute the crimes of embezzlement, economic participation in business, bribery, abuse of power, malfeasance, influence peddling, money laundering, or fraud in obtaining or diverting subsidies, grants, or credit.
Therefore, A. Sampaio Employees must act by the following Standards of Conduct outlined in the Code of Conduct – Corruption and Related Offences.
Employees who fail to comply with this Code may be subject to disciplinary action, including corresponding administrative and criminal consequences, under applicable law.
Therefore, any situation that violates the values and rules outlined in this Code will result in disciplinary proceedings being initiated, as provided for in the Labour Code.
Consequently, the following sanctions may be applied, provided they are deemed proportionate to the severity of the violation and the culpability of the offender, without prejudice to any other sanctions provided for in collective bargaining agreements:
- Reprimand.
- Recorded reprimand.
- Financial penalty.
- Loss of vacation days.
- Suspension from work with loss of pay and seniority.
- Dismissal without severance pay or compensation.
Additional information available in the Code of Conduct – Corruption and Related Offences.