1. SCOPE OF APPLICATION

This Code of Conduct (CC) establishes guidelines on professional ethics for all employees of RSM & Associados - Sroc, Lda. (RSM).
The term “Employees” is understood in a broad sense, that is, all those who carry out professional activities for RSM or under its supervision, regardless of the legal and/or contractual relationship that exists between the parties.
The CC contains the ethical conventions and standards to which RSM employees are obliged in their relationships with third parties and arising from the activity carried out, without prejudice to the provisions of the "Código de Ética e Deontologia Profissional dos Revisores Oficiais e Contas” (Regulamento n.º 551/2011 publicado no Diário da República, 2.ª série, n.º 198 em 14 de outubro de 2011).
This CC also applies to employees with a contractual relationship with companies that are or will be part of the RSM “Network” concept.
To the extent applicable, the rules of conduct contained in this code are extended to RSM partners.

2. PRINCIPLES AND STANDARDS

2.1. General Principles of Operation

The actions of employees must be guided by loyalty to RSM and its partners. It must be honest, independent, impartial, discreet and not serve personal interests, as well as avoid situations capable of generating conflicts of interest.

Employees must commit to safeguarding RSM's credibility and good image in all situations and guaranteeing/promoting its prestige. Employees must carry out the duties assigned to them at RSM with care, efficiency and to the best of their ability.

2.2. Equal Treatment / Non-Discrimination

RSM employees are not permitted to accept any form of individual discrimination that is incompatible with the dignity of the human person, particularly due to race, sex, age, physical disability, political and/or other opinions or religious convictions. Personal conduct adopted at RSM must demonstrate sensitivity and mutual respect, and employees must refrain from any comments and/or behavior considered offensive by another person.

2.3. Loyalty and Cooperation

RSM employees must behave in loyalty, especially when carrying out the tasks entrusted to them and respecting orders/instructions from management/partners, as well as defined hierarchical channels.
Employees must base their conduct on transparency and openness in personal dealings with partners and colleagues, in particular keeping the work team aware of matters that concern them and listening to their respective contributions.
Lack of loyalty is considered to be failure to communicate, to management, partners and colleagues, information that may affect the normal progress of work, obtaining personal advantages, providing false, inaccurate, exaggerated information, refusing to collaborate and demonstration of an obstructive attitude.

2.4. Independence

Employees must perform the functions entrusted to them with absolute professional independence, free from any pressure, especially that resulting from personal interests or those of third parties, which translate, directly or indirectly, into a decrease in their freedom and ability to formulate or allow RSM partners to form a fair and impartial opinion on the matters under consideration.

2.5. Confidentiality and Professional Secrecy

Confidentiality and professional secrecy constitute a fundamental principle on which the activity of legal audit/audit is based.
All RSM employees, even after terminating their employment relationship, are subject to professional secrecy and cannot discuss or transmit confidential information about RSM or its clients, without arising from the normal and necessary exercise of their functions or resulting from the relationship with the partners responsible for the work.
Employees are directly responsible for the information entrusted to them and must ensure its safeguarding and archiving in a timely manner, as defined internally.
When an RSM employee terminates his employment relationship, all documentation and all electronic information (files and/or other) that he maintains in his possession must be returned to the Company.

2.6. Illegitimate Offers

RSM employees may not request, receive or accept any benefits, offers or other rewards from third parties that exceed a merely symbolic value, as a courtesy, and that may indicate less clear intentions on the part of the offerors.

All situations that configure the practices mentioned above must be communicated to RSM management.

2.7. Safeguarding RSM Assets

Employees must ensure the protection and conservation of RSM assets, which are intended to achieve the company's objectives. RSM resources, notably equipment and facilities, must not, as a rule, be used by employees for personal purposes, and any exceptions must be expressly authorized by management and be restricted to economically irrelevant and ethically unreprehensible situations that derive from common practices developed outside of working hours.

2.8. Employee Attitude towards Recruitment Processes

Whenever RSM employees are involved in recruitment processes with a view to eventual employment, they must behave with integrity and discretion, refraining from any initiative that could be considered ethically reprehensible in light of the general principles of action referred to in item 2.1 of this CC .

2.9. Exercise of Activities External to RSM

Employees may not carry out paid or unpaid activities outside of working hours, nor perform duties as members of corporate bodies of any entity, without obtaining prior authorization from RSM management.
Activities related to artistic and literary creation and the holding of conferences, lectures and short-term training are not subject to obtaining prior authorization.
In any case, the exercise of activities or performance of functions cannot negatively interfere with the obligations assumed with RSM nor generate conflicts of interest, particularly with clients, or entities that have been clients in the recent past, of RSM.

2.10. Issues not covered by this CC

All questions not covered by this CCC or that cannot be answered by the “Code of Ethics and Professional Deontology of Official Auditors and Accountants”, mentioned in the point referring to “Scope of Application” must be submitted to RSM management.

3. FINAL PROVISIONS

3.1. The importance of this CC for RSM

Although we understand that the principles and rules invoked throughout this CC have always been part of RSM's culture and values, we consider it essential to systematize the aforementioned principles and rules into a Code of Conduct, which must be observed, lived and guaranteed by all RSM employees.
Employees who perform coordination functions at RSM have the special responsibility and obligation to act exemplarily in relation to the rules and principles enshrined in this CC.

3.2. Entry into Force / Disclosure

The RSM Code of Conduct comes into force on January 1, 2019.