COMPLIANCE 

 

Corporate Compliance Program

On May 17 2018, the ProCME Group approved a Corporate Compliance Program. This Program aims to promote a true culture of business ethics and reaffirms the Group's culture of respect for law.

We have taken an active role in the fight against crime in business activities and, for this reason, specific technical, organizational and personnel management measures have been adopted, as well as monitoring and control measures and a proper sanctions regime to avoid any kind of infringements or actions.

 
In this context, and to fulfill this objective, the following documents were published internally:
ACS Code of Conduct (pdf)
 
ACS Industrial General Protocols

Framework Protocol

Normative Conformity Protocol

Allegedly Irregular Facts Reporting Protocol

Protocol of Activation of the Procedure of Corporate Defense

Training Protocol

Protocol on the Corporate Compliance Officer

Internal Scheme Instructions
 
ProCME Group Crime Prevention Plan and related annexes

Corporate Compliance Policy (pdf)


Information Security Management Procedure

Anti-Corruption Regulation

Regulations on Combating Money Laundering and Financing of Terrorism

Protocol on the Protection of Industrial and Intellectual Property Rights

Protocol for the Treatment of Confidential Information

Global Policy on the Protection of Personal Data

Protocol on Environmental Protection

 

The Corporate Compliance Program includes and applies good practices for the prevention of criminal risks and promotion of ethical behavior in business, in line with the requirements of the Penal Code. Any person who has knowledge or a well-founded suspicion of any type of infraction or illicit action may report the same, to the following e-mail address canal.denuncia@grupo-procme.com or to the following address: Internal Compliance Corporate Compliance Officer, Group ProCME, Rua Rui Teles Palhinha, 4, 2740-278 Oeiras.

The above mentioned channels can also be used to clarify any doubt regarding the Corporate Compliance Program.

In addition to the general complaint channels, the ProCME Group provides all its professionals with a specific and independent channel through which an infraction or irregularity related to possible suspicious transactions or violations of policies and procedures may be reported anonymously and internal controls on money laundering and terrorist financing. For this purpose, a form has been created in the Business gateway through which it is possible to report anonymously.