Compliance Program

The Compliance Program at Devoteam Portugal entities – BOLDINT, S.A. and EDOTOUTFIT, LDA. – is a comprehensive set of policies, procedures, and practices designed to ensure that both the company and its employees operate in full compliance with legal, ethical, and regulatory standards. The program is specifically aimed at preventing and addressing issues such as corruption, conflicts of interest, discrimination, harassment, and other unethical behaviors within the organization. It serves as an essential tool for managing risks, ensuring legal compliance, and fostering a strong ethical corporate culture. Each of these entities has a tailored approach to compliance, aligned with the overarching Devoteam Group's Code of Conduct and Anti-Corruption Charter.

The Compliance Program is essential for promoting a culture of integrity, transparency, and accountability at Devoteam Portugal entities  – BOLDINT, S.A. and EDOTOUTFIT, LDA. It helps ensure that each company adheres to legal and regulatory requirements, maintains high ethical standards, and minimizes the risks associated with unethical behavior, fraud, corruption, and legal violations. By promoting compliance, the program safeguards the companies’ reputation, enhances trust with clients and stakeholders, and ensures that we operate within the bounds of the law.

The Compliance Director and the Compliance Team are responsible for the overall implementation and enforcement of the Compliance Program at Devoteam Portugal entities. Additionally, all employees have a role to play by understanding, adhering to, and upholding the policies and standards set forth in the program. Leadership at all levels of the organizations is responsible for setting the tone and ensuring that compliance is integrated into day-to-day business activities.

The key components of the Compliance Program at Devoteam Portugal entities include:

• Code of Conduct: Establishes ethical guidelines and behavioral expectations for all employees and stakeholders.

• Anti-Corruption and Conflict of Interest Policies: Defines preventive measures to avoid corruption and manage potential conflicts of interest.

• Corruption Risk Prevention Plan: Identifies and mitigates risks associated with corruption, fraud, and unethical practices.

• Internal and External Whistleblowing Channel: A secure and confidential platform for employees and third parties to report unethical behavior or violations.

• Integrity Training and Communication Program: Educates employees on compliance matters and ethical conduct to ensure awareness and engagement with the program.

These components work together to ensure that compliance is a key focus in everything we do at Devoteam Portugal, and are fully aligned with the Devoteam Group's Code of Conduct and Anti-Corruption Charter, ensuring a unified and cohesive approach to ethical governance and compliance across all Devoteam operations.

You can report unethical behavior or any suspected violations through the Devoteam Portugal entities' dedicated Whistleblowing Channels. Each entity, BOLDINT, S.A. and EDOTOUTFIT, LDA., has its own confidential and secure platform where employees, suppliers, clients, and other stakeholders can anonymously report concerns regarding unethical conduct, fraud, corruption, or policy violations.

• 🔊BOLDINT, S.A. Speak-Up Line or by e-mail to pt.speakup.line.bold@devoteam.com 

• 🔊EDOTOUTFIT, LDA. Speak-Up Line or by e-mail to pt.speakup.line.outfit@devoteam.com 

The Whistleblowing Channel provides further details on how to submit a report, and additional information can be found on each entity’s Compliance Program page in this intranet section. All reports are handled impartially and confidentially. 

Each report will be investigated in accordance with the company's policies, ensuring that proper action is taken where necessary.

Please note that Whistleblowing reports related to corruption, fraud, or other serious misconduct may lead to criminal or disciplinary liability.

Yes, the Devoteam Portugal Entities "Speak-Up Line" allows you to report concerns anonymously. The channel is designed to protect the identity of the whistleblower, ensuring confidentiality. Reports can be made without revealing personal information, and all individuals are protected from retaliation under the General Regime for the Protection of Whistleblowers (RGPDI).

Once a report is submitted, it will be reviewed by each Devoteam Portugal entity designated Compliance Officer and Compliance Team and investigated in accordance with each Devoteam Portugal entity's policies and procedures. All reports are handled confidentially, and the investigation will be conducted impartially. If necessary, corrective actions or disciplinary measures will be taken. The whistleblower will be informed of the outcome of the investigation, as appropriate.

Once a report is submitted, it will be reviewed by each Devoteam Portugal entity designated Compliance Officer and Compliance Team and investigated in accordance with each Devoteam Portugal entity's policies and procedures. All reports are handled confidentially, and the investigation will be conducted impartially. If necessary, corrective actions or disciplinary measures will be taken. The whistleblower will be informed of the outcome of the investigation, as appropriate, unless they have chosen anonymity, in which case their identity will remain protected.

Yes, employees who report concerns in good faith are protected by law under the General Regime for the Protection of Whistleblowers (RGPDI). Retaliation against whistleblowers, such as threats, discrimination, harassment, or any form of retaliation, is strictly prohibited. Any form of retaliation will be subject to disciplinary action. We are committed to creating an environment where employees can report concerns without fear of repercussions.

You should report the following types of issues:

• Ethical Misconduct & Unethical Treatment: 

  • Ethical misconduct or inappropriate behavior

  • Discrimination

  • Harassment (including sexual harassment)

  • Retaliation against whistleblowers

  • Workplace violence/threats

  • Substance abuse

• Legal & Regulatory Violations:

  • Violations of legal or regulatory requirements

  • Fraud

  • Fraudulent insurance claims

  • Insider trading

  • Improper loans to executives

  • Kickbacks

  • Unauthorized discounts

• Company Policy & Internal Compliance Issues:

  • Breaches of Devoteam Portugal entities' or the Devoteam Group's internal policies

  • Accounting/audit irregularities

  • Falsification of company records

  • Conflicts of interest

  • Policy issues

• Employee & Customer Relations:

  • Employee relations issues

  • Customer relations issues

  • Wage/hour issues

• Safety & Product Concerns:

  • Safety issues and sanitation

  • Product quality concerns

  • Release of proprietary information

• Asset & Financial Misuse:

  • Theft of cash

  • Theft of time

  • Theft or misuse of company assets/services

Day-to-day management or operational issues should be addressed through the appropriate channels, such as Human Resources or People Managers.

The Compliance Program is regularly reviewed and updated to reflect changes in legal requirements, industry best practices, and internal business needs. We also adapt to emerging trends or issues in corporate governance and compliance. Employees are encouraged to stay informed about updates and changes by regularly consulting the program and the resources available on the Compliance section of Devoteam Portugal Intranet.

Yes, Devoteam Portugal entities offer an Integrity Training and Communication Program to ensure that all employees understand their obligations under the Compliance Program. This training covers key topics such as the Code of Conduct, anti-corruption policies, how to use the Whistleblowing Channel, and the proper steps to take when reporting violations. Training is mandatory for all employees, and periodic refresher courses are provided to ensure ongoing awareness and engagement. [check "Training & Awareness > Mandatory Training Schedule" page].

To learn more about the specific compliance programs for each entity within Devoteam Portugal - BOLDINT, S.A. and EDOTOUTFIT, LDA. - please visit the dedicated pages for each entity’s program on the Compliance Intranet. Each entity has a tailored compliance program that aligns with the overarching policies and principles of Devoteam Portugal entities.

• BOLDINT, S.A. Compliance Program

• EDOTOUTFIT, LDA. Compliance Program