ANA

Ethics and Conduct

Introduction Ethics and Vigilance Committee Guides and Documents Reporting Infractions

In a company like ANA, long-term success is based on relationships of trust, with clients, with shareholders, with employees, with suppliers and business partners and with the community in which the company operates and that it has an impact on.

Trust – which presupposes living by the same rules and principles of conduct – grows stronger when these rules and principles are known and shared transparently. This is why ANA adopted a Code of Ethics, which was in force until 2013, when the Company became part of the VINCI Group. From then on, it adopted the principles established for the entire group as an extension of its own convictions.

The company’s all-round performance commitments are outlined in the VINCI Manifesto, which sets out the following values shared by all employees:

1. Together! Design and build
2. Together! Comply with ethical principles
3. Together! Accelerate the environmental transition
4. Together! Engage in civic projects
5. Together! Strive for zero accidents
6. Together! Foster equality and diversity
7. Together! Promote sustainable careers
8. Together! Share the benefits of our performance

Thus, and in compliance with DL No. 109-E/2021, of 9 December, ANA implemented the Programme for Integrity, Transparency and Compliance with the General Framework for the Prevention of Corruption (GFPC), with the aim of reinforcing prevention of and protection against corruption. To this end, it is provided with internal control mechanisms and corruption prevention measures that transparently assure the effectiveness and efficiency of processes and operations:

For clarification of the Programme for Integrity, Transparency and Compliance with the General Framework for the Prevention of Corruption (GFPC), the following e-mail address of the Ethics and Vigilance Committee shall be used exclusively etica.vigilancia@ana.pt

With the aim of assuring the implementation, monitoring and continuous improvement of the Programme for Integrity, Transparency and Compliance with the General Framework for the Prevention of Corruption (GFPC), an Ethics and Vigilance Committee has been set up, with the following members:

a) Helena Girão (Responsible for Regulatory Compliance and Responsible for the Plan for the Prevention of Corruption Risks and Related Infractions);
b) Raphaël Pourny;
c) Rui Morgado;
d) Madalena Miranda.

Any communications addressed to the Ethics and Vigilance Committee regarding possible violations of the rules on which the principles of Business Ethics are based, particularly respect for the law, respect for people and the fight against corruption, must be made exclusively via ANA’s Reporting Channel.

The mandate of the Ethics and Vigilance Committee is for three years from the date of their appointment by ANA’s Executive Committee.

The values we embrace and that are reflected in the Programme for Integrity, Transparency and Compliance with the General Framework for the Prevention of Corruption (GFPC) are defined in the following documents:

The Anti-Corruption Policy affirms ANA’s commitment to the prevention of corruption.

The Privacy Policy affirms ANA’s commitment to personal data privacy and protection.

The Code of Ethics and Conduct, which lays down all the principles of business ethics that apply in all circumstances; is a direct extension of Commitment no. 2 of the Manifesto.

The Annex to the Charter of Ethics and Conduct incorporates the specificities and the national reality at ANA.

The Anti-Corruption Code of Conduct, which details the rules concerning the prevention of all acts of corruption, notably identifying risks in business processes and defining conduct to be avoided.

The Guide on Human Rights: is also an extension of the Manifesto. It reiterates the risks identified and their implications and presents a common set of guidelines on how to handle issues concerning human rights. These guidelines are based on the principles of the Universal Declaration of Human Rights, on the eight fundamental Conventions of the International Labour Organisation and on the OECD Guidelines for multinational enterprises. This Guide includes an Annex with the internal implementation procedures.

The Declaration on Essential and Fundamental Actions Concerning Occupational Health and Safety reflects a shared determination to achieve the “zero accidents” objective. The declaration is the fruit of constructive and regular social dialogue. As part of a continuous improvement policy, it affirms that progress can only be made with all employees and their representatives through the promotion of our safety culture. Is an extension of Commitment no. 5 of the Manifesto.

The Environmental Guidelines, which are an extension of Commitment no. 3 of the Manifesto, provide a framework designed to minimise the risks and impact of our activities on the environment, to continuously improve and to adapt our actions to protect the environment.

Also in this scope, based on rules aiming among other principles the respect for the law, the right to competition, the fight against corruption and the prevention of conflicts of interest, ANA has developed a risk assessment system, included in the Plan for the Prevention of Corruption Risks and Related Infractions; (PPR), in line with the methodology of the VINCI Group.

This plan is reviewed at least every 3 years and its implementation is monitored and reflected in the Annual Assessment Report.

Apart from strict compliance with the law and regulations in force, ANA is governed by the principles of professional ethics, which should, in all circumstances and in all places, inspire the conduct of its employees. This is therefore considered a distinctive factor in reinforcing the confidence of all its stakeholders.

With the introduction of this Reporting Channel, we aim to allow both employees and third parties to report any situations that violate the rules that the principles of Corporate Ethics are based on, in particular: respect for the law, respect for people and fighting against corruption.

This channel allows anonymous reports to be received and is implemented according to the requirements of Law No. 93/2021, of 20 December, which establishes the general framework for the protection of whistleblowers, and ANA assures the same level of protection in all of the areas reported, particularly assuring non-retaliation against the whistleblowers.

Complaints are excluded from the scope of this reporting channel. There is a specific channel for Suggestions and Complaints, which can be accessed via the internet page of each airport, in the “Tell us” section.

When you submit a report, don't forget to save the password automatically created by the system so that you can access and follow up on it (if you lose or forget your password, it cannot be recovered or reset, so you will no longer be able to access your complaint).

To subsequently send and receive communications about your report, you must access it by selecting "Follow up on existing report" and entering your password.

You can access the Reporting Channel and our FAQs here.

ANA

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