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Anti-Corruption Policy

CONCEITO performs its activity in accordance with high standards of professional responsibility and ethics, governed by the principles of integrity, transparency, honesty, loyalty, accuracy, and good faith.


CONCEITO has adopted a regulatory compliance programme with a view to preventing, detecting, and punishing acts of corruption and related offences undertaken against or through the Company, in compliance with Decree-Law No. 109-E/2021, of 9 December (‘General Regime for the Prevention of Corruption’ or ‘RGPC’).


This policy establishes all the principles, values, and operating guidelines applicable to all its activities with regard to professional ethics and the prevention of corruption and related offences, as provided for in the RGPC, which must be read together with the Code of Conduct and Ethics, included in the Rules of Procedure of CONCEITO, and the Confidential Reporting Procedure (Whistleblowing).

This Anti-Corruption Policy is intended for all CONCEITO Employees and has the following objectives:


  • Describing the rules of conduct required of CONCEITO employees

  • Preventing the risks of fraud, corruption, and related offences 

  • Implementing a channel through which any irregularities at CONCEITO may be reported 

  • Documenting the actions to be taken in case of awareness of irregularities

  • Training CONCEITO employees on the subject

CONCEITO provides annual in-house training on this Policy’s content to its staff to ensure their awareness and understanding of all the rules and procedures within the scope of the prevention of corruption and related offences.

The Compliance Officer is appointed by the Board of Directors of CONCEITO and performs their duties with independence, having access to internal information and the technical and human resources necessary for performing those duties.

The Compliance Officer must provide all the necessary explanations on the application of the Anti-Corruption Policy and shall promote regular internal audits with a view to assessing compliance with it.

1. Rules of conduct and action

CONCEITO rejects any practice of corruption, bribery, or related offences, either actively or passively, and other forms of undue influence or illicit conduct, imposing strict compliance with these principles in all its internal and external relationships, both with private and public entities.

All employees must comply with the applicable regulations on anti-corruption and related offences, and any behaviour that may constitute the practice of the crime of corruption or any related offence provided by law is expressly forbidden.

For the purposes of this Policy, only gifts that fall within the scope of socially appropriate conduct and conform to custom and usage may be offered. A benefit is considered socially acceptable if it is offered as a sign of politeness and good manners, in accordance with local customs and practice, to the extent that such benefit is related to the recipient’s professional activity. It is not intended or designed to persuade or obtain preferential treatment, an illegitimate advantage from the recipient, or to influence their behaviour unduly.

2. Political Contributions

It is absolutely forbidden to make political donations or contributions, in cash or in kind, under any circumstances, on behalf of and/or in the name of CONCEITO or in a manner that appears to be made on behalf of or in the name of any company in the CONCEITO Group to political parties, candidates for political office or organisations or individuals associated with those whose mission is essentially political.

3. Contracting with Third Partie

Intending to ensure that third parties contracted by CONCEITO abide by this Policy and the existing legislation on the prevention of corruption and related offences, CONCEITO has defined a set of principles and rules that, without prejudice to the application of legal standards or any other applicable internal regulations, must be observed in procurement processes:

  • Contracting with third parties presupposes a legitimate need for the goods or services to be acquired

  • The choice of potential suppliers is based on objective, transparent, and impartial criteria

  • The contracted third parties must be considered appropriate from the perspective of the degree of exposure to the risk of corruption

  • The conditions accepted by CONCEITO (including price and payment conditions) shall be in line with market practices (unless otherwise justified by a legitimate reason)

  • The contracted third parties agree to comply with CONCEITO’s Anti-Corruption Policy.

4. Provision of Services to Customers

In the relationship of CONCEITO and its employees with its Clients within the scope of the services provided to them, a policy of total transparency exists, and the Clients are formally informed of the set of principles and rules defined by CONCEITO concerning the prevention of corruption and related offences.

By signing the respective service provision contracts, the Clients expressly declare that they are aware of and agree with CONCEITO’s internal policy on this matter.

5. Non-compliance

Failure to comply with the rules contained in this Policy by any employee shall be considered a serious offence, which, depending on the degree of culpability of the offender and the seriousness of the offence, may give rise to the application of the following disciplinary sanctions, applied with or without disclosure within the company:

  • Reprimand – verbal 

  • Reprimand – on record

  • Penalty payment

  • Loss of holidays

  • Suspension from work with loss of pay and seniority

  • Dismissal for just cause

Failure by Partners and other third parties to comply with the rules contained in this Policy will result in the application of penalties and/or termination of the contract as appropriate and proportional to the infringement.

Non-compliance with the rules of this Policy may also lead to the administrative or civil liability of the offenders and, depending on the seriousness of the offence and the offender’s culpability, give rise to criminal sanctions.

The Compliance Officer must write a report for each infraction committed, detailing the identification of the rules violated, the sanction applied, and the measures adopted or to be adopted by CONCEITO within the scope of its internal control system.

6. Internal Confidential Reporting Channel

CONCEITO has an Internal Whistleblowing Channel through the platform Lefebvre-Centinela and follows up on any allegations of acts of corruption and related offences in accordance with the provisions of the legislation that transposes Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of EU law.

The receipt and forwarding of complaints follow the procedure applicable to complaints set out in the Confidential Reporting Procedure (Whistleblowing).

7. Conflict of Interests

To maintain their objectivity, independence of judgement and conduct in carrying out their responsibilities on behalf of CONCEITO, all employees must complete a conflict of interest questionnaire on an annual basis.

January 2024

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