ACA pursues a model of ethics and conduct based on fundamental values, which reflect a common purpose that cuts across the organisational design. Ethical values are foundational, mobilising leadership and guiding governance choices, while at the same time steering the behaviour of all those who are part of the organisation and those who engage with it — the stakeholders.
Compliance is grounded in a dynamic process of ethical construction, creating mechanisms to ensure conformity with internal standards, laws and regulations, while also fostering knowledge by clarifying expected behaviours for everyone.
Code of Ethics and
Conduct
As an essential reference in our actions, ACA’s Code of Ethics and Conduct assigns to everyone the important role of making it a driver of ethical construction, framing behaviours and providing guidance and inspiration in the face of challenges and demanding expectations faced by organisations. It therefore seeks to serve as a guide for conduct regarding how to act within the organisation, in business and in society.
Accordingly, all employees and managers, regardless of their functional level, must comply with the provisions of this Code, under penalty of being subject to disciplinary action, in accordance with the legal and regulatory terms applicable to the offences committed. Third parties who engage with the Group’s companies within its value chain, to whom the Code applies, must also comply with it, under penalty of being subject to measures or sanctions contractually established.
Whistleblowing
Channel
The existence of a channel for reporting irregularities is one of the best international practices for promoting transparency, fairness and responsible conduct across all types of organisations, whether public or private, with or without profit-making objectives.
ACA provides all its companies with access to this communication channel, which not only fulfils the stated purpose but also meets the requirements of the General Regime for the Prevention of Corruption (Regime Geral de Prevenção da Corrupção — RGPC). It should also be noted that, with regard to the protection of whistleblowers and in coordination with the RGPC, ACA applies the General Regime for the Protection of Whistleblowers (Regime Geral de Proteção de Denunciantes de Infrações — RGPDI), Law No. 93/2021, which transposed Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019.
Corruption and Related
Offences Risk Prevention Plan
On 9 December 2021, Decree-Law No. 109-E/2021 was published, approving the General Regime for the Prevention of Corruption (Regime Geral de Prevenção da Corrupção — RGPC). This regime stemmed from the National Anti-Corruption Strategy 2020–2024, previously approved on 18 March 2021.
For the first time in Portugal, both public and private entities with more than 50 employees were required to adopt compliance programmes, which, among other instruments provided for, include the obligation to establish a Corruption and Related Offences Risk Prevention Plan (CRORPP).