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)
Framework Protocol of the Corporate Compliance Program
Regulatory Compliance Protocol
Protocol for Reporting Suspected Irregular Activities
Corporate Defence Procedure Activation Protocol
Protocol on Training of Professionals in Regulatory Compliance Issues
Protocol on the profile, expertise and organizational location of the Corporate Compliance Officer and the Corporate Compliance Delegate
Protocol for Core Policies
Catalogue of Forbidden Conducts and Expected Behaviours
Code of Conduct for Business Partners
Protocol for Compliance with Competition Standards
Criminal and Anti-Brybery Policy
Policy on IT Conduct
Policy on Business Courtesies
Policy on Prevention of Money Laundering and the Financing of Terrorism
Policy on Intellectual and Industrial Property Rights
Confidential Information Processing Policy
Environmental Protection Policy
Policy on Prevention, Detection and Intervention against Workplace Mobbing
Personal Data Protection Policy
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 firstname.lastname@example.org 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.