Code of Conduct

​​1. Diligence
The employees shall carry out their functions with the due degree of care, efficiency, responsibility and strictness of demands, and in strict observance of legal, regulatory and internal standards and laws in effect, thereby ensuring that all clients, suppliers, authorities, and any other parties with whom they have a business relationship, receive a duly diligent treatment. Employees shall abstain from any kind of conduct, whether on the job or outside, that could have a negative effect upon their performance, or other collaborators, or which could, in any way, jeopardise or harm the legitimate interests of the Fidelidade Group.
 
2. Loyalty
The employees shall use their respective internal status, as also the funding placed at their disposal, at the service of the Group, and never for self-benefit or in favour of third parties. Employees are also required to maintaian a legal and ethically correct standard of behaviour, under any circumstances whatsoever. In interpersonal relationships, the employees shall, between themselves, observe principles such as cooperation, politeness and respect, while observing cordiality, respect and professionalism in their mutual relationships.
 
3. Protection of Resources
The employees shall always seek to protect, as also to prudently and efficiently use, all resources placed at their disposal, whether they material assets, like equipment and IT materials, or confidential information and passwords. The employees shall always, by all means at their disposal, avoid and discourage any situation which could lead to possible loss or siphoning off of funds, materials, equipment, or any other kinds of assets, and inform any such situations to their line managers. Any employees who are aware of, or suspect that there has been, any practice of irregularities that could put the good reputation of the Fidelidade Group on the line, including cases of fraud, corruption or other practices harmful to the interests of the companies within the Group, shall immediately inform the situation, through all methods and forms as internally defined, being assured of  the respective confidentiality and protection of identity, and also being guaranteed that there shall be no retaliation against the person who made the communication in good faith and in non-anonymous fashion.
 
4. Trust
The employees shall always honour any commitments of the Group before third parties. Employees shall abstain from any type of conduct that could affect trust in the Group companies, or which could put at risk their compliance with the commitments as validly entered into with third parties. 

5. Transparency
Employees shall always adopt, whatever the circumstances, including mutual relationships, a personal and professional posture based on honesty and truth. The employees must also keep note of all records, transactions and support information in perfectly organised condition, and accessible to authorised personnel. The employees must also avoid situations of omission, or which could be interpreted in a negative light, in all relationships with clients and suppliers, especially for sale, post-sales, marketing and advertising. The employees shall provide the clients with accurate and comprehensive information about the products commercialised.

6. Fairness and Impartiality
The employees shall treat all clients, suppliers, work colleagues, and anyone else with whom they maintain a professional relationship, in a fair and correct manner, including competitors, with whom they must uphold cordiality in their relationships, promoting mutual respect.

7. Secrecy
Even when they leave the Fidelidade Group, employees shall maintain strict and utter confidentiality of all knowledge they may have acquired through exercising their posts, and may not disclose any information or data about the life of the Group Companies, or of their clients, shareholders, employees and suppliers, except in the cases as established by law, or when prior authorisation has been granted by the administrative entity. The employees must also comply with, and make sure others comply with, rules governing information security and circulation control.

8. Receptivity
 
9. Public Declarations
The employees may only make public declarations that could involve the Fidelidade Group or any of its constituent companies when prior authorisation has been obtained from the administration body. Declarations made to social communication media may only be made through the channels as internally chosen. It is therefore forbidden for anyone outside this group to provide any information, and to confirm or deny any news with regard to the Group or its companies.

10. Privileged Information 
Unless and until prior written authorisation has been obtained from the administration entity, employees may not, in any way, disclose privileged information about the Fidelidade Group or any of its companies. Employees may not, under any circumstances, disclose information that could lead to commitment or harm to the interests of the Group or its companies, albeit potentially.
 
11. Conflict of Interests
Employees shall not intervene with the appreciation, decision or implementation of operations or processes in which they, or any other people to whom they are attached by family ties or any other kind of affinity, or any companies where one of such people is directly or indirectly in charge, have any direct or indirect interest.  Employees shall also inform their superiors about all situations that could breed conflict between their interests and those of the Group. The acceptance of gifts is forbidden for all employees of the Fidelidade Group, and for this reason they must abstain from receiving any offers from third parties that could harm or otherwise jeopardise their impartiality, even if in only an apparent way, as also the reputation of the Group and the companies that are part thereof. Similarly, employees must not breed, in clients, suppliers, mediators or any other representatives, expectations of undue favours in their relationships with the Fidelidade Group.

12. Individual Solvency