Corporate Compliance Programme
On May 17th, 2018, ProCME Group approved a Corporate Compliance Programme, aiming to promote a true ethical business culture and reaffirm the Group's respect for Law.
In March 2020, AENOR Spain certified CME under the number ASO-2020/0020, as recognition and proof of compliance of its management system with the standard ISO 37001:2017.
We have adopted an active role in fighting corporate crime, and therefore specific technical, organisational and personnel management measures have been taken, as well as monitoring and control measures and an appropriate sanction regime to prevent any kind of offences or illicit actions.
In order to fulfil this goal, the following documents have been internally published: ACS Code of Conduct (pdf).
ACS Industrial Protocols
- Framework Protocol.
- Regulatory Compliance Protocol.
- Allegedly Irregular Facts Reporting Protocol.
- Corporate Defence Procedure Activation Protocol.
- Training Protocol.
- Corporate Compliance Officer Protocol.
- Essential Policy Protocol.
- Forbidden Conduct and Expected Behavior Standards Catalogue.
- ACS Code of Conduct for Business Partners (pdf)..
- Compliance Protocol on Competition Law.
ProCME Group Crime Prevention Plan and its annexes:
- Corporate Compliance and Anti-Bribery Policy (pdf).
- Information Security Management Policy.
- Professional Courtesies Policy.
- Anti-corruption policy.
- Anti-Money Laundering and Terrorist Financing Policy.
- Industrial and Intellectual Property Rights Protection Policy.
- Confidential Information Policy.
- Global Policy on Personal Data Protection.
- Environment Protection Policy.
- Prevention, Detection and Action against Labour Harassment Policy.
Important Notes:
The Corporate Compliance Programme comprises and applies good practices for the prevention of criminal risks and the promotion of ethical behaviour in business, aligned with the Criminal Code requirements. Anyone aware of or suspecting a well-founded infraction, or illicit action, may report it to the e-mail canal.denuncia@grupo-procme.com or to the following address: Responsável Cumprimento Corporativo, Grupo ProCME, Rua Rui Teles Palhinha, 4, 2740-278 Oeiras, Portugal.
The above-mentioned channels can also be used to clear up any doubts regarding the Corporate Compliance Programme.
Apart from these general reporting channels, ProCME Group provides all its professionals with a specific and independent channel, through which any breaches or irregularities related to possible suspicious operations, policies violations, procedures and internally defined controls on the prevention of money laundering and terrorist financing, can be reported anonymously. For this purpose, an online form has been created on the portal through which it is possible to submit anonymous complaints.