Anti-Corruption Policy

 

1. Purpose

The purpose of this policy is to establish the principles and responsibilities to prevent, detect, and respond to bribery and corruption in all business operations of Fernanda e Capelo, Lda.

2. Scope

This policy applies to all employees, management, directors, suppliers, contractors, and third parties acting on behalf of the company.

3. Policy Statement

Fernanda e Capelo, Lda., adopts a zero-tolerance approach to bribery and corruption. We are committed to acting professionally, fairly, and with integrity in all our business dealings and relationships.

4. Definitions

Bribery: Offering, giving, receiving, or soliciting something of value to influence a decision.
Corruption: Abuse of entrusted power for private gain.

5. Prohibited Practices

- Offering or accepting bribes, gifts, or hospitality that could influence decisions.
- Making facilitation payments.
- Engaging in kickbacks or commissions intended to secure improper advantage.

6. Gifts and Hospitality

Gifts or hospitality must be reasonable, infrequent, and not intended to gain any business advantage. All such activities must be declared and approved according to internal guidelines.

7. Reporting and Whistleblowing

Employees are encouraged to report any suspicions or incidents of bribery or corruption. Reports can be made anonymously via our internal ethics channel at: ethics@fcapelo.com

8. Training and Communication

All employees will receive regular training on this policy. The policy will be available on the company’s intranet and shared with relevant third parties.

9. Monitoring and Review

Compliance with this policy will be monitored regularly. The policy will be reviewed annually and updated as necessary.

10. Approval

Approved by: Paulo Capelo
Date: 01/04/2025