This Code of Conduct aims, on the one hand, to increase awareness and understanding among all human resources of Américo Coelho Relvas, Sucrs., S.A. and provide a guiding framework of action that allows, on the one hand, to identify, prevent, and manage workplace harassment issues, and on the other hand, to respond to Article 127(1)(k) of the Labor Code.


General principles of conduct 

Employees of Américo Coelho Relvas, Sucrs, S.A., internally or in external representation, should act in accordance with the ethical principles and values associated with Américo Coelho Relvas, Sucrs, S.A., adopting behaviors based on responsibility, rigor, and strict respect for the dignity and rights of individuals.

Américo Coelho Relvas, Sucrs, S.A., encourages respect and cooperation among all employees in a respectful and dignified work environment, rejecting any practices of harassment.

Workplace harassment. 

According to Article 29 of the Labor Code:

“Harassment shall be understood as unwanted behavior, particularly based on a discriminatory factor, practiced during access to employment or in employment itself, work or vocational training, with the objective or effect of disturbing or constraining the person, affecting their dignity, or creating an intimidating, hostile, degrading, humiliating, or destabilizing environment.

Sexual harassment shall be understood as unwanted behavior of a sexual nature, whether verbal, non-verbal, or physical, with the objective or effect referred to in the preceding paragraph.” 

Harassment is an expression of unacceptable behavior by one or more individuals and can take various forms, some of which are more easily identifiable than others.

Harassment occurs when one or more workers are repeatedly and deliberately intimidated, threatened, and/or humiliated in work-related circumstances.

Harassment can be carried out by any individual, with the purpose or effect of violating a worker’s dignity, affecting their health, and/or creating an intimidating, hostile, degrading, humiliating, or destabilizing work environment.

Workplace harassment includes, but is not limited to, the following vectors:

  • Degrading, offensive, insulting, intimidating, embarrassing, or humiliating behavior;
  • Targeting an individual with irritating differential treatment;
  • Impeding performance/job sabotage;
  • Spreading rumors, including negative blogs or cyberbullying;
  • Inappropriate sexual touching, advances, suggestions, or requests;
  • Displaying or circulating offensive images or materials in electronic or printed format that are known or should be recognized as offensive.

On the other hand, workplace harassment does not represent nor intend to prevent employers from disciplining or managing their employees.

Therefore, workplace harassment does not include, in particular:

  • Exercise of managerial authority;
  • Performance management;
  • Pressure resulting from the exercise of duties;
  • Exercise of disciplinary power;
  • Operational requirements or decisions;
  • A disagreement or misunderstanding;
  • Work-related changes (e.g., change of location, coworkers, or occupational work);
  • Positive reinforcement.

Procedure in case of harassment allegation 

In the event of a potential harassment situation, the following should be considered:

  • The interest of all parties in acting with the necessary discretion to protect the dignity and privacy of each individual;
  • Non-disclosure of any information to other parties not involved in the incident;
  • Complaints should be promptly investigated and addressed;
  • All involved parties should be impartially heard and benefit from equitable treatment;
  • Complaints should be supported by detailed information;
  • False accusations will not be tolerated, and the authors may be subject to disciplinary proceedings; and
  • If harassment is proven, appropriate measures will be taken against the perpetrator(s), including possible disciplinary sanctions such as dismissal.

Formal procedure

In the case of a harassment allegation, which must be reduced to writing, a disciplinary procedure is initiated following the procedure described in the Labor Code, culminating in the application of the appropriate disciplinary sanction for the case.

The complainant of harassment situations and the witnesses indicated by them cannot be subject to disciplinary sanctions, unless they act with intent, based on statements or facts contained in the records of the process, judicial or administrative, triggered by harassment until the final decision becomes res judicata, without prejudice to the exercise of the right to adversarial proceedings.

Rio Meão, September 28, 2017

José Coelho Ferreira

Chairman of the Board of Directors