CODE OF ETHICS

The rules in the Code of Ethics aim to guarantee that the professional conduct of all those working for ESPHERA CAPITAL, SGPS, SA, is of the highest moral standard and complies fully with the company culture and values,  and with any other legal provisions and regulations that should be observed.
All workers must, in the scope of their responsibilities and duties, observe the principles and values established in this Code, both in internal and external relations.

Compliance with the law
ESPHERA CAPITAL, SGPS, SA and all of its workers undertake to comply with and ensure that others comply with the legal precepts and regulations applicable to their activity. Notwithstanding the sanctions provided for by Law, any worker may be subject to disciplinary measures should s/he fail to meet the obligations arising from her/his employment relationship.

Loyalty, transparency, honesty
ESPHERA CAPITAL, SGPS, SA and its entire workforce must always act with rigour, veracity and transparency in all procedures and in compliance with contractual obligations.
ESPHERA CAPITAL, SGPS, SA and its entire workforce accept that they must explain and make explicit their decisions and professional behaviour with total transparency, whenever properly requested to so do.
Workers shall always behave with loyalty to the principles and interests of ESPHERA CAPITAL, SGPS, SA, and must denounce any situations that might put the image or prestige of the Company at risk.
Workers must guarantee the confidentiality of company matters and those of its clients and suppliers, with the information to which they have access being used only in the company’s interests, or when expressly authorised for the given purpose.
ESPHERA CAPITAL, SGPS, SA will not sustain a relationship with suppliers who are not in agreement with the spirit of this Code of Ethics, and will not cease to monitor the ethical conduct of its suppliers and adopt immediate and exacting measures where a supplier’s ethical conduct is found to contravene the principles established herein.

Integrity and rigour
All and any forms of corrupt practices or bribery are forbidden, both active and passive, through actions or omissions, or via the creation and maintenance of illicit and irregular situations.
ESPHERA CAPITAL, SGPS, SA and its workers shall not, on behalf of the Company, make any monetary contributions in an attempt to bribe or influence anyone.
ESPHERA CAPITAL, SGPS, SA and its workers shall refuse any offers that might be considered or interpreted as an attempt to influence the company or the worker. If in doubt, the worker must inform his/her superiors of the situation.
Workers may not personally benefit from any business advantages in a relationship established with third parties in the company’s name.
Workers shall undertake not to perform any outside professional activity that might interfere with their duties or with the company activities.
Workers shall always act in such a way as to avoid any situation likely to cause a conflict of interest with the company, and any situations that might generate conflicts of interest between personal interests and the duty of loyalty to the company must immediately be communicated to the management.
Workers must respect and protect company property, and neither misuse nor allow others to misuse services and/or premises and equipment.
Workers have a duty to adopt appropriate measures to minimise costs, avoid waste and make the use of available resources more efficient.

Diligence, efficiency and responsibility
All workers of ESPHERA CAPITAL, SGPS, SA must fulfil the tasks and duties assigned to them with zeal,  efficiency and professionalism,  doing their utmost to comply with the standards of quality and safety that the company adopts and always striving for excellence in performance.
In performing their duties, the workers of ESPHERA CAPITAL, SGPS, SA must act with a high sense of responsibility and cooperation, facilitating a good environment, team spirit and personal approach, fostering cooperation and the sharing of knowledge and information.
The workers of ESPHERA CAPITAL, SGPS, SA must observe and see that others observe timely and rigorous compliance with legal or regulatory procedures, adopt an attitude of innovation and ongoing improvement, be imaginative and proactive, take responsibility for meeting the objectives established, share information and knowledge and show ability to adapt to new situations.  
Workers must seek to develop and update their skills and knowledge, on an ongoing basis, and take full advantage of the training provided by the company.
Each manager is responsible for the workers under him/her, and must always be accessible, define clear, realistic and ambitious objectives, comply with the management and control tasks, lead on a basis of trust and give workers the maximum responsibility and freedom of action, while still having the final responsibility, even where tasks have been delegated.

Work environment, equal opportunities and professional development
ESPHERA CAPITAL, SGPS, SA gives prominence to assuring the safety, health and well-being of its workers. All workers must be conversant with, comply with and see that others comply with occupational health and safety standards and report any non-conformities detected in this area.
In working relationships, workers should observe the principles of loyalty, integrity, cooperation, respect for superiors, cordiality and good manners.
ESPHERA CAPITAL, SGPS, SA promotes respect for personal dignity, privacy and the individual rights of all, and will not allow any form of moral or psychological pressure, guaranteeing equal opportunities for all of its workers, forbidding discriminatory practices and any differences in treatment on the basis of race, gender, social class, disability, religious beliefs, sexual orientation, nationality, political choices, trade union involvement or party membership.
ESPHERA CAPITAL, SGPS, SA shall invest in the professional development of its workers, implementing ongoing training programmes to foster staff progression, improve qualifications, enhance skills and knowledge and encourage talents.
ESPHERA CAPITAL, SGPS, SA shall respect the right of all workers to form and join syndicates of their choice and to bargain collectively.

Dissemination and disciplinary action
ESPHERA CAPITAL, SGPS, SA shall guarantee that the Code of Ethics is made available to all workers, together with a channel to monitor its application, clarify issues and resolve any doubts.
Non-compliance with the rules and principles of this Code of Ethics shall constitute a serious breach, susceptible to disciplinary action or other actions where appropriate.