Integrity Policy of PERFORMANCE BY HM

Whereas:

• The definition of Integrity is broadly associated with concepts of honesty, transparency, awareness and responsibility, as well as consistent adherence to sound moral and ethical principles, but also to strict legal and regulatory compliance;

• The practice of illegal criminal or administrative offences, such as corruption and bribery, influence peddling, money laundering and financing of terrorism, discrimination, insider trading, anti-competitive practices, failure to respect privacy, the need to protect data and the requirements to safeguard the confidentiality of information, as well as failure to comply with environmental legislation and prevention and safety legislation, among others, may, in certain cases, jeopardise public peace, security and the well-being of citizens, as well as the stability of the markets, and may have implications at the (i) political level, to the extent that they undermine democracy and the rule of law; (ii) economic level, insofar as valuable resources necessary for the growth and development of society are diverted; (iii) social level, as they promote instability, insecurity and distrust among citizens; and (iv) environmental level, as they can promote the degradation of ecosystems and their sustainability;

• As such, there has been, both nationally and internationally, an integrated logic of prevention and fight against the practice of this type of illicit offences, based on a zero tolerance policy and translated into the adoption of increasingly rigorous and demanding legislation that promotes cooperation between private entities and public authorities;

• The evolution of the context of PERFORMANCE BY HM, both with regard to the activities developed and with regard to its legal and regulatory framework, highlighting in this regard the publication in Portugal of the General Regime for the Prevention of Corruption (Decree-Law no. 109-E/2021 of 9 December), and the evolution of the best international practices in matters of integrity, as well as the experience acquired in the application of the Integrity Policy of PERFORMANCE BY HM;

• The permanent need to align PERFORMANCE BY HM’s business operations with the best market practices and in strict compliance with the legislation and regulations applicable to its activities, namely with regard to preventing and combating the practice of illicit offences, in particular conducts associated with the practice of acts of corruption, bribery, money laundering and financing of terrorism.

1. OBJECTIVE

This policy aims to define the general principles of action and the duties of PERFORMANCE BY HM, its directors, employees and business partners, in order to prevent illicit conduct, in particular conduct associated with crimes of corruption, undue receipt of advantage, money laundering and financing of terrorism, practices restricting competition and non-compliance with data protection rules.

Additionally, it aims to contribute to the promotion of ethical and upright conduct in the development of PERFORMANCE BY HM business, ensuring compliance with the legislation and the principles and rules adopted.

2. SCOPE

This Policy is applicable to all PERFORMANCE BY HM, its directors, employees, service providers acting on its behalf or on its account and in its direct or indirect interest, regardless of the nature or form of their legal relationship with the respective entity.

This Policy does not seek to address the legal and regulatory specificities of all jurisdictions in which the company operates, but rather aims to establish a common commitment to ensure compliance with all applicable laws and principles that bind the company. PERFORMANCE BY HM may approve its own policies and procedures, in order to also ensure compliance with locally applicable legislation, and, in any case, full compliance with this Policy must be ensured.

Whenever the requirements of local legislation applicable to the entities / subsidiaries are less demanding than the provisions of this Policy and other related policies and procedures, these shall ensure alignment with the principles established in the company’s policies.

Local policies that adapt and develop the principles of this Policy to the specificities of the respective jurisdiction, or any exception to the application of this Policy by prohibition of local law, must be submitted for consultation and review by the Board of Directors of PERFORMANCE BY HM, and appropriate coordination shall be maintained so that such policies or procedures remain at all times consistent with the principles set out in this Policy and other related procedures.

The representatives of PERFORMANCE BY HM who are part of the management bodies are charged with adopting the measures and developing the acts necessary for the implementation of this Policy.

3. DESCRIPTION AND RESPONSIBILITIES
PERFORMANCE BY HM Commitments

PERFORMANCE BY HM undertakes to carry out its activity in strict compliance with the laws and regulations in force, together with the promotion of responsible action guided by the highest standards of ethics and integrity.

Compliance with national and international legislation, applicable to the PERFORMANCE BY HM entity, as well as with this Policy and the other policies, procedures and internal instruments of any kind approved and applicable, is mandatory under all circumstances, and the practice of any acts or omissions that constitute violation or non-compliance with such standards shall not be tolerated.

PERFORMANCE BY HM promotes acting not only in accordance with the law, but also in a free, honest, upright, professional and fair manner, and PERFORMANCE BY HM, its Employees and service providers acting on its behalf, are required to conduct themselves in accordance with this commitment.

PERFORMANCE BY HM therefore actively and expressly assumes a policy of zero tolerance policy with regard to any type of act that does not comply with the applicable legal and regulatory rules, also guaranteeing willingness to collaborate with the competent authorities, in order to detect, report and eliminate such behaviour.

In this context, PERFORMANCE BY HM implements adequate procedures to prevent and mitigate the risk of occurrence of illicit practices in all its activities, such as, for example, acts of corruption, prevarication, money laundering, or insider trading. Additionally, this entity adopts the necessary procedures to detect possible occurrences of this type and to report them to the competent authorities.

PERFORMANCE BY HM also undertakes to periodically review and adapt its internal procedures and mechanisms, and whenever they prove inadequate, to safeguard their alignment with legal requirements and best market practices.