Code of behaviour

VERSION 1.1. (2025) 

I. Introduction

The General Regime for the Prevention of Corruption (RGPC), which came into force on 8 June 2022, established the obligation for entities with 50 or more employees to adopt a compliance programme that includes at least a plan for the prevention of risks of corruption and related offences, a code of conduct, a training programme and a whistleblowing channel. 

The Holmes Place group is a group of commercial companies, some of which employ more than 50 workers and, as such, is subject to the RGPC, which is why, as a covered entity, it has adopted this Code of Ethics and Conduct with a view to preventing acts of corruption and related offences carried out against or through it.

In this sense, this Code of Ethics and Conduct seeks to fulfil the obligations laid down in the RGPC, as well as promoting a culture of integrity and transparency that Holmes Place values.

II. Objectives

The purpose of this Code of Ethics and Conduct is to promote, encourage and consolidate the adoption of a set of ethical principles defined in this Code and to consolidate the institutional image of Holmes Place, which must continue to be characterised by the highest rigour and ethics, within a framework of transparency and professionalism and always in strict compliance with the Law.

III. Object 

This Code of Ethics and Conduct establishes a set of principles, values and rules of conduct that are transversal to all of Holmes Place's activities, in terms of professional ethics and the prevention of Corruption and Related Offences, as provided for in the RGPC, and is complemented by the PPR and the Whistleblowing Policy, both of which are available online.

IV. Scope of application

The Code of Ethics and Conduct applies to all Holmes Place employees and other elements who, regardless of their legal or functional relationship, provide work or services to the company, and is a fundamental management tool that makes it possible to strengthen and consolidate the procedures and mechanisms for the prevention and detection of corruption and related offences.

Holmes Place ensures that this Code of Ethics and Conduct is known to all its Employees.

V. Values

Holmes Place guides the development of its activity by ethical values and behaviours which in themselves constitute a strong link between the Entity's Vision, Mission and Values.

Holmes Place's behaviour is based on ethics and honesty, and its relationships are built on trust.

VI. Standards of Conduct

The rules of conduct should be understood as regulating the general attitude of Holmes Place. employees towards each other and towards the outside world, in order to define standards of behaviour that comply with the strictest ethical principles.

Holmes Place. repudiates any practice of corruption, bribery or related offences, whether active or passive, and any other forms of undue influence or illicit conduct, imposing compliance with the principles of action and duties set out both in this Code of Ethics and Conduct, in the PPR and in the legal rules in force.

In this regard, all employees, service providers and members of the governing bodies of Holmes Place must comply with the applicable national and international standards for combating Corruption and Related Offences, and any behaviour that may constitute the commission of a crime of corruption or any related offence provided for by law, in all its active or passive forms, whether through acts or omissions, is expressly prohibited. 

Accordingly, and although it is not recognised as having any real practical applicability given the outcome of the risk analysis, it is expressly prohibited: 

1. Accepting any advantages or offers in return for preferential treatment from any third party in order to influence an action or decision;

2. Offer or accept, under any circumstances and regardless of value, cash, cheques or other assets subject to legal restrictions;

3. Influencing the decisions of business partners in any way that is illegal or appears to contravene applicable regulations;

4. Obtaining a benefit or advantage for the company, for the Employee or for third parties, through unethical practices or contrary to the duties of the position, namely through corrupt practices, undue receipt of an advantage or influence peddling.

With regard to Gifts and Commercial Offers, offers may only be made if they are in line with socially appropriate behaviour and conform to custom.

A benefit is considered socially acceptable if it is offered as a sign of politeness and good manners, in accordance with local uses and customs, insofar as this benefit is related to professional activity and has no intention or purpose of persuading or obtaining preferential treatment or an illegitimate advantage from the recipient or unduly influencing their behaviour.

Gifts and commercial offers may never be offered or promised to public officials (national, foreign or from international organisations), political office holders (national or foreign) or senior public office holders, nor to family members or friends of the people listed here.

All gifts made and received by Holmes Place. employees must be reported to and authorised by their immediate superior. 

Expenses incurred in this context must always be documented and presented to the superior of the employee who made them, in order to be approved. The gifts made must also be appropriate to the circumstances in which they are given, be offered in an open and transparent manner and in the name of Holmes Place. and not of a particular employee.

Holmes Place. employees must ensure that the offers they make are for legitimate business purposes, namely in order to:

1. informing about Holmes Place. activities, products and services;

2. For marketing purposes to clients and potential clients (for example, with low-value products);

3. To improve or maintain the image or good name of Holmes Place;

4. Small gifts during festive seasons.

In case of doubt, employees must consult their superiors in writing.

In all contacts with the outside world, Holmes Place employees must act in accordance with the principle of independence, namely by not requesting or receiving instructions from any entity, organisation or person outside Holmes Place.  

Respect for this principle implies refusing offers, payments or other benefits which, due to their cost, repeated or exclusive nature, could lead those involved or third parties to assume that the duties of impartiality and independence have been compromised.

Holmes Place. employees, in their conduct, proceed according to criteria of reasonableness and prudence, and must report through the Whistleblowing Channel, available on the Holmes Place... website, or, depending on the nature of the matter involved, to other competent bodies, namely the Public Prosecutor's Office, the Court of Auditors, the General Inspectorate of Finance - Audit Authority, the European Anti-Fraud Office (OLAF) or the European Public Prosecutor's Office, in accordance with their respective powers, whenever they become aware of or have reasonable suspicions of the occurrence of corruption or related offences. 

In accordance with Law no. 93/2021, of 20 December, the completeness, integrity and preservation of complaints, the confidentiality of the identity or anonymity of the complainants and the confidentiality of third parties mentioned in the complaint are guaranteed, and access to unauthorised persons is prevented.  

Holmes Place employees who report or prevent illegal activities from taking place may not be penalised in any way. 

It is the responsibility of the Compliance Officer to receive any reports that are made and to carry out the necessary investigations to ascertain their veracity and reliability and to gather evidence with a view to formalising a complaint to the relevant authorities.  

With regard to these matters and the aforementioned communication procedure, it is important to bear in mind the adoption of the PPR, which is also publicised on the Holmes Place website.

All Holmes Place employees, especially those with access to personal data or involved in the processing of personal data, must comply with the legal provisions on the protection of personal data.

Holmes Place. employees must scrupulously comply with the law in general and all applicable internal rules and regulations. 

Relationships between Holmes Place employees must be based on trust, honesty and mutual respect, with no offensive attitudes or behaviour permitted. 

All employees must contribute to the creation and maintenance of good general working conditions.

Holmes Place employees who exercise management, coordination and responsibility functions in the different Teams must guide and instruct the members of their teams in a clear and comprehensible manner, and set them challenging but achievable objectives and tasks, maintaining a permanent and loyal relationship with them.  

Holmes Place employees must respect their hierarchical superiors and zealously strive to achieve the objectives and fulfil the tasks that these superiors, within the scope of their respective mission, set for them, showing willingness to accept suggestions for change and using the powers they are given in a non-abusive way, aimed at achieving Holmes Place's objectives and not at obtaining personal advantages. 

All Holmes Place employees, regardless of their legal relationship with Holmes Place, must be responsible for the correct and efficient use of equipment and facilities, adopting all appropriate and justified measures to rationalise the costs and expenses inherent in their operation, ensuring the protection and general good state of repair of Holmes Place equipment.

Holmes Place. employees must achieve their professional goals on their own merits and not use their position in the organisation as a means of future career progression. 

Holmes Place employees must not carry out any endeavours on behalf of the Entity that may violate the general law and regulations applicable to the Entity's activities. 

In relations with external entities, Holmes Place employees must adopt a conduct of impartiality and fairness based on mutual trust, demonstrating high standards of professionalism, respect and politeness, assuming a behaviour based on loyalty to Holmes Place, always putting all their efforts into safeguarding its credibility, good image and prestige.

Their behaviour must also be based on availability, efficiency, correctness and courtesy, providing any information or other clarification of justified interest that is requested.

With regard to contracts, Holmes Place employees must ensure that the terms of the contracts are honoured.

Holmes Place. employees must achieve their professional goals on their own merits and not use their position in the organisation as a means of future career progression. 

Holmes Place employees must not carry out any endeavours on behalf of the Entity that may violate the general law and regulations applicable to the Entity's activities. 

In relations with external entities, Holmes Place employees must adopt a conduct of impartiality and fairness based on mutual trust, demonstrating high standards of professionalism, respect and politeness, assuming a behaviour based on loyalty to Holmes Place, always putting all their efforts into safeguarding its credibility, good image and prestige.

Their behaviour must also be based on availability, efficiency, correctness and courtesy, providing any information or other clarification of justified interest that is requested.

With regard to contracts, Holmes Place employees must ensure that the terms of the contracts are honoured.

V. Responsible person

The compliance officer, appointed by the Holmes Place Board of Directors, ensures the execution and monitors the application of the respective compliance programme, without prejudice to the powers legally conferred on other company bodies or employees.

The compliance officer carries out his/her duties with independence and decision-making autonomy, and has access to internal information and the technical and human resources necessary to carry out his/her duties.

The compliance officer must provide all necessary clarification on the anti-corruption policy and will promote audits to assess compliance with it.

VI . Non-compliance

Failure by any employee to comply with the rules contained in this Code of Ethics and Conduct and/or the PPR will be considered a serious offence and, depending on the offender's degree of guilt and the seriousness of the offence, may give rise to the application of the following disciplinary sanctions:

a. Unrecorded reprimand;

b. Recorded reprimand;

c. Financial penalty;

d. Loss of holiday days;

e. Suspension from work with loss of pay;

f. Dismissal with just cause.

Non-compliance with the rules set out in this Code of Ethics and Conduct by Partners and other third parties is grounds for penalties and/or termination of the contract that is appropriate and proportional to the offence.

Failure to comply with the rules of the Policy may also lead to administrative or civil liability for the offenders and, depending on the seriousness of the offence and the culpability of the offender, criminal sanctions.

The offences of Corruption and Related Offences referred to in this Policy are punishable, depending on their legal framework, by fines and imprisonment.

The Compliance Officer must draw up a report for each offence committed, which identifies the rules violated, the sanction applied and the measures adopted or to be adopted by Holmes Place within the scope of its internal control system for the Prevention of Corruption and Related Offences.

VII. Clarification of doubts 

Whenever any employee has any doubts about the application and/or interpretation of this Code of Ethics and Conduct, they should send them to the Compliance Officer who will analyse them and issue a clarification opinion if necessary.  

VIII. Publicity 

The Holmes Place Code of Ethics and Conduct may be consulted at any time by any interested party.  

The Interim and Annual Evaluation Reports, when drawn up, are duly published on the website.  

After each review, if there are any changes, however minimal, they will be publicised as described above.  

For all intents and purposes, publicising these documents is the responsibility of the Compliance Officer appointed by Holmes Place.

This Code of Ethics and Conduct is publicised, in its most up-to-date version, to all Holmes Place employees, either by handing them a copy when they sign their employment contract, or by posting it on the company's notice boards, and, as mentioned above, it is available for consultation on the official website.