Code of Ethics & Conduct

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1. Preamble

This Code of Ethics and Conduct sets out the principles and rules of conduct that guide the activity of Império Global Telecomunicações Unipessoal, Lda. It applies to all employees, as well as to partners, suppliers and other third parties acting in the name of or on behalf of the company.

2. Values

Our conduct rests on three values:

• Commitment — we deliver on what we promise, with responsibility and rigour.
• Trust — we build solid relationships through transparency and quality.
• Innovation — we continuously evolve towards more efficient, future-ready solutions.

3. Principles of conduct

• Integrity and honesty — we act truthfully and consistently between what we say and do.
• Technical rigour and safety — we comply with technical and workplace safety standards, protecting people and infrastructure.
• Respect in the workplace — we adopt zero tolerance of harassment and discrimination.
• Confidentiality and data protection — we process personal data in accordance with the GDPR.
• Prevention of conflicts of interest — we declare and avoid situations that pit personal interests against those of the company or clients.
• Fair competition — we compete on technical merit, respecting competition law.
• Anti-corruption and anti-bribery — we neither offer nor accept undue advantages of any kind.
• Environmental sustainability — we minimise the environmental impact of our operations.

4. Relationship with clients and partners

We conduct our relationships with operators, contractors and public entities with transparency, fulfilling contractual commitments and protecting the confidentiality of the information we access. We reject any practice that compromises impartiality in the award or execution of work.

5. Relationship with employees

We promote safe working conditions, professional development through training and merit-based recognition. We reject any form of discrimination based on origin, gender, age, beliefs or any other personal characteristic.

6. Compliance and reporting of irregularities

Breaches of this Code may be reported, in confidence, through our Whistleblowing Channel, under Law 93/2021. The company guarantees the protection of whistleblowers against retaliation.

7. Approval and review

This Code was approved by the Management of Império Global. It will be reviewed periodically, within a maximum of 12 months, or whenever justified by legal or organisational changes.