The Code of Ethics and Conduct outlined herein establishes a comprehensive framework of principles, rules, and values that govern ethical standards and professional behavior. It serves as a guiding document for all employees of Frutas Patricia Pilar, SA, outlining their responsibilities in professional relationships with colleagues and third parties.

The primary objectives of this Code are as follows:

1. Sharing Guiding Principles: The Code aims to communicate the fundamental principles that shape the operations of Frutas Patricia Pilar, SA. It seeks to provide a clear understanding of the ethical and deontological rules that should govern the behavior of all employees and management. Furthermore, it aims to encourage the adoption of these principles and rules by our partners.


2. Promoting Adoption of Ethical Standards: The Code strives to promote and encourage the adoption of the prescribed principles of action and behavioral rules outlined within its contents. These guidelines are especially relevant in fostering a culture that upholds the company's core values in all employee-to-employee and employee-to-partner interactions.


3. Strengthening Institutional Image: By adhering to this Code, Frutas Patricia Pilar, SA endeavors to bolster its institutional image. The ethical conduct of employees and management, as outlined in the Code, enhances the organization's reputation, instilling confidence in stakeholders and the wider community.


4. Commitment to Universal Declaration of Human Rights: This Code signifies the company's unwavering commitment to upholding and promoting the principles enshrined in the Universal Declaration of Human Rights. It serves as a pledge to respect and safeguard the rights and dignity of all individuals, both within and outside the organization.

In the exercise of their duties, all employees of Frutas Patricia Pilar, SA are expected to uphold and adhere to high standards of professional ethics. They must avoid situations that may give rise to conflicts of interest and ensure strict compliance with the following principles:

Objectivity: It is essential for employees to act impartially and fairly in all their interactions with individuals involved in their professional activities.

Confidentiality: Employees must maintain strict confidentiality and discretion regarding any facts or information they become privy to during the course of their duties.

Independence: Employees are required to maintain independence and treat all entities and individuals they interact with in a fair and unbiased manner, irrespective of their relationships established through their job responsibilities.

Integrity: Employees should consistently demonstrate honesty and personal loyalty in their conduct to ensure the accuracy and reliability of the work they carry out.

Competence: All employees should present themselves as dedicated professionals committed to fulfilling their assigned tasks. They are expected to apply their skills and knowledge with technical precision in their daily activities.

Proportionality: Employees must align their actions and decisions with the objectives of their role, ensuring that their procedures are suitable and proportionate to the nature and goals of their activities.

Rigor: It is crucial for employees to carry out their daily tasks with the utmost accuracy and attention to detail, maintaining a high level of precision in their work.

In the exercise of their duties, all employees of Frutas Patricia Pilar, SA. must follow the following guidelines:

Safeguard Impartiality: Employees should ensure that their professional relationships and actions remain impartial, free from any bias or favoritism.

Prevent Conflicts of Interest: Employees must actively avoid situations that may create conflicts of interest. They should be aware of and adhere to the legal rules, regulations, and policies regarding incompatibilities and impediments that apply to partners. Specifically:

1. Technical Work with Relatives: When working with relatives, it is important to ensure that personal relationships do not negatively impact the professional environment or the way tasks are carried out.


2. Resolving Conflicts of Interest: In cases where conflicts of interest arise between the interests of the company and personal interests, employees should prioritize and resolve such conflicts in a manner that aligns with the best interests of the company, unless there are specific legal or contractual reasons to handle the situation differently.


3. Fair and Equal Treatment: Employees must act in a manner that does not privilege, benefit, harm, deny rights, or exempt any individual or group based on factors such as ancestry, race, sex, territory of origin, language, religion, political and/or ideological beliefs, education, economic situation, or social condition.

Any employee who becomes aware of potential conflicts of interest should promptly communicate the matter to the Administration. The purpose of such communication is to address and resolve conflicts in a fair and equitable manner, ensuring that all parties involved are considered appropriately.

Employees of Frutas Patricia Pilar, SA are required to maintain strict confidentiality regarding all information they come across in the course of their duties. This includes:

Professional Secrecy: Employees must uphold professional secrecy, ensuring that all information they become aware of during their work remains confidential and is not disclosed to unauthorized individuals.

Preserving Confidentiality: Employees should exercise discretion and caution when handling sensitive information. They must refrain from altering or manipulating such information in any way that could compromise its integrity or confidentiality.

Non-Disclosure: Employees are prohibited from disclosing confidential information to external parties or individuals who do not have the necessary authorization to access such information.

By adhering to these guidelines, employees demonstrate their commitment to maintaining the confidentiality of sensitive information and protecting the interests of Frutas Patricia Pilar, SA.

To uphold the principle of independence, employees of Frutas Patricia Pilar, SA must:

Ensure Impartiality: Employees should act in a manner that upholds impartiality in their dealings with partners and individuals. They must not allow personal interests or external pressures to influence their decisions or actions.

Maintain Technical and Professional Autonomy: Employees are expected to exercise technical and professional autonomy while adhering to the operating rules and guidelines set forth by Frutas Patricia Pilar, SA. They should carry out their responsibilities without undue influence or interference.

By adhering to these principles, employees demonstrate their commitment to acting independently, without bias or external influences, in order to safeguard the integrity and objectives of Frutas Patricia Pilar, SA.

Employees of Frutas Patricia Pilar, SA are expected to uphold the highest standards of integrity and honesty. This includes:

Honesty, Diligence, and Responsibility: Employees should carry out their assigned tasks with honesty, demonstrating diligence and a sense of responsibility in their work. They should act in a manner that reflects the values and professionalism of the organization.

Rejection of Illegal Practices: Employees must refrain from engaging in any form of illegal practices that could discredit their own role or the reputation of the organization. They should adhere to all applicable laws, regulations, and ethical standards in their actions.

Promotion of Respectful and Safe Work Environment: Employees are responsible for promoting a work environment that is respectful, inclusive, and free from any form of discrimination or harassment. They should treat all colleagues and individuals with respect and dignity, fostering a safe and welcoming atmosphere for everyone.

Reporting Violations: Employees have a responsibility to report any behavior that violates the Code of Ethics and Conduct. The organization guarantees confidentiality and legal protection to those who report such violations, in accordance with its own regulations. Additionally, individuals who report violations will be treated fairly and without retaliation.

By adhering to these principles of integrity and honesty, employees contribute to a positive and ethical work culture, ensuring the well-being of all individuals within Frutas Patricia Pilar, SA and upholding the organization's values.

In order to uphold the principle of competence, employees of Frutas Patricia Pilar, SA must:

Skill Development: Employees are expected to actively develop their skills and knowledge, taking responsibility for their professional growth. They should strive for continuous improvement in both their technical expertise and the quality of services they provide.

Adherence to Standards and Rules: Employees should be familiar with and adhere to the required competence standards and performance rules that have been established for their specific roles. This includes consistently applying the principles, rules of conduct, and best practices relevant to their professional activities.

Commitment to Service Quality: Employees are encouraged to adopt an attitude that prioritizes the quality of service. This involves actively embracing and adapting to changes, remaining flexible in response to evolving circumstances, and continuously seeking ways to enhance the quality of their work.

By demonstrating competence in their respective roles, employees contribute to the overall effectiveness and success of Frutas Patricia Pilar, SA. Their commitment to skill development, adherence to standards, and dedication to service quality ensures the organization remains competitive and capable of delivering value to its stakeholders.

The principle of proportionality guides employees of Frutas Patricia Pilar, SA to:

Equal Treatment: Employees should ensure equal treatment to situations that are proven to be equal. This means that similar situations should be treated in a consistent and fair manner, without any unjustified distinctions or biases.

Differentiated Treatment: Conversely, employees should also exercise differentiated treatment when faced with different situations. They should consider the specific circumstances and characteristics of each situation to determine the appropriate course of action. This may involve tailoring responses or solutions to suit the unique needs or requirements of the situation at hand.

By adhering to the principle of proportionality, employees contribute to fairness, justice, and consistency in their decision-making and actions within Frutas Patricia Pilar, SA. This approach helps to ensure that appropriate and equitable responses are applied to various situations that arise in the organization.

To ensure ethical and professional conduct in relationships with external parties, Frutas Patricia Pilar, SA establishes the following rules for its employees:

• Availability and Responsiveness: Employees should demonstrate availability and promptly respond to customer inquiries or requests. They should address customer needs efficiently and with a high level of quality.


• Courtesy and Respect: Employees should interact with customers in a courteous and respectful manner, treating them with politeness and consideration. They should strive to provide clear and understandable information that meets the customer's requirements.

Relationships with suppliers should be conducted in a transparent and ethical manner, with strict adherence to agreed-upon conditions. Key considerations include:

• Transparency and Integrity: Employees should maintain transparency in their dealings with suppliers and honor the terms and conditions agreed upon in contracts or agreements. They should avoid engaging in any practices that could compromise the integrity of the relationship.


• Abstaining from Abusive Use of Information: Employees must refrain from any abusive use of information they have access to within the scope of their duties. This includes avoiding the unauthorized disclosure or misuse of sensitive information that could adversely affect the relationship with suppliers or compromise the company's interests.

By adhering to these conduct rules, employees of Frutas Patricia Pilar, SA uphold the principles of fairness, transparency, and professionalism in their interactions with customers and suppliers. These guidelines foster strong and mutually beneficial relationships, based on trust, respect, and adherence to ethical standards.

These 9 points are based on the Basic Code of the Ethical Trading Initiative (ETI), ensuring the fulfillment of all labor practices.

1. EMPLOYMENT IS FREELY CHOSEN

1.1. Forced Labor and Involuntary Work: Frutas Patricia Pilar, SA strictly prohibits the use of forced, slave labor, or any form of involuntary prison work.

1.2. Deposits and Identification Documents: Employees will not be required to leave "deposits" or submit their identification documents with the employer as a condition of employment. Employees have the right to retain their personal identification documents, and they may terminate their employment after providing reasonable notice.

2. FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING ARE RESPECTED

2.1. Right to Join Associations: All employees, without any form of discrimination, have the right to join or form labor associations, participate in collective bargaining, and exercise their rights collectively.

2.2. Support for Associations: Frutas Patricia Pilar, SA maintains an open attitude towards labor association activities and supports the organization and functioning of such associations.

2.3. Non-Discrimination: Employee representatives engaging in labor association activities are protected from discrimination. They are allowed to carry out their representation activities in the workplace without prejudice or negative consequences.

2.4. Alternative Means of Association and Bargaining: In situations where legal restrictions impede freedom of association and collective bargaining, Frutas Patricia Pilar, SA will actively facilitate and support the development of alternative means for employees to freely associate and engage in independent bargaining.

3. WORKING CONDITIONS ARE SAFE AND HYGIENIC

3.1. Safe and Hygienic Working Environment: Frutas Patricia Pilar, SA is committed to providing a safe and hygienic working environment. This includes identifying and addressing any specific risks associated with the company's activities. Reasonable measures will be taken to prevent accidents and health issues arising from the work environment.

3.2. Health and Safety Training: Employees will receive regular and documented health and safety training. New or relocated employees will also undergo appropriate training to ensure their awareness of safety protocols and practices.

3.3. Basic Facilities: Employees will have access to clean toilets, drinking water, and, if necessary, clean facilities for food storage.

3.4. Adequate Housing (if applicable): If housing is provided, it must meet cleanliness and safety standards and fulfill the basic needs of employees.

3.5. Appointment of Health and Safety Executive: Frutas Patricia Pilar, SA will designate a senior executive responsible for health and safety matters within the organization.

4. CHILD LABOR IS PROHIBITED

4.1. Prohibition of Child Labor: Frutas Patricia Pilar, SA strictly prohibits the hiring of child labor in any form.

4.2. Support for Education: The company will develop or participate in policies and programs aimed at assisting children engaged in child labor to leave the workforce. These initiatives will provide opportunities for children to access and receive quality education until they reach adulthood. The definition of "child" and "child labor" is outlined in the relevant appendices.

4.3. Protection of Minors: Children and young people under the age of 18 will not be employed for night work or in hazardous conditions.

4.4. Compliance with International Standards: Frutas Patricia Pilar, SA ensures that policies and procedures related to child labor align with the standards set by the International Labor Organization (ILO).

5. WAGES MUST BE DIGNIFIED

5.1. Fair Remuneration: Wages and benefits provided to employees must meet the standards established by national laws or industry-specific regulations. The higher of the two prevailing standards should be applied. Wages should be sufficient to meet employees' basic needs and provide disposable income.

5.2. Transparent Payment Information: Prior to commencing work, employees should receive clear and understandable written information about payment conditions. Additionally, employees should receive detailed wage statements each time they are paid.

5.3. Salary Reduction Restrictions: Salary reductions as disciplinary measures or in violation of applicable legislation require the employee's consent. All disciplinary measures must be documented.

6. WORKING HOURS MUST NOT BE EXCESSIVE

6.1. Compliance with Working Hour Laws: Working hours should adhere to national laws, collective agreements, and clauses 6.2 to 6.6 outlined below. The provision that best protects employee rights should be applied. Clauses 6.2 to 6.6 are based on international labor standards.

6.2. Maximum Weekly Hours: Working hours, including overtime, should not exceed 48 hours per week.

6.3. Voluntary Overtime: Overtime work should be voluntary and used responsibly. Factors such as the extent, frequency, and working hours of each employee and the workforce as a whole should be considered. Overtime should not replace regular hires and should be compensated at a higher rate, preferably at least 125% of the regular wage.

6.4. Limit on Total Working Hours: The total number of working hours should not exceed 60 hours every 7 days, except as provided in clause 6.5.

6.5. Exceptions to Working Hours: Working hours may exceed 60 hours in a 7-day period only in exceptional situations, subject to the following conditions:

• Permitted by national legislation.
• Permitted by collective agreements negotiated freely between employee organizations representing a significant portion of the workforce.
• Appropriate measures are in place to protect the health and safety of employees.
• The employer can demonstrate the existence of exceptional conditions, such as production peaks, accidents, or emergencies.

6.6. Rest Days: Employees should have at least one day off every 7 days. If permitted by applicable legislation, employees may have 2 days off every 14 days.

* Progressive reduction of normal working hours, without reducing employee wages, is recommended as appropriate, aiming for a standard of 40 hours per week.

7. DISCRIMINATION IS PROHIBITED

7.1. Non-Discrimination: Frutas Patricia Pilar, SA prohibits discrimination in hiring, remuneration, access to training, promotion, dismissal, or retirement based on race, social class, origin, religion, age, disability, sex, marital status, sexual orientation, union membership, or political affiliation.

8. WORK SHOULD BE PROVIDED REGULARLY

8.1. Regular Employment: Frutas Patricia Pilar, SA strives to establish working relationships that are recognized and defined in accordance with national laws and customs to the greatest extent possible.

8.2. Avoiding Circumvention of Obligations: Labor obligations cannot be evaded through employment contracts, outsourcing, homework, intern programs that lack a genuine intention to provide skills or permanent employment, or excessive use of temporary work contracts.

9. INHUMANE OR SEVERE TREATMENT IS PROHIBITED

9.1. Prohibition of Abuse: Physical or disciplinary abuse, threats of physical abuse, sexual harassment, or any form of harassment, verbal abuse, or other types of intimidation are strictly prohibited.

By adhering to these standards, Frutas Patricia Pilar, SA ensures a respectful, ethical, and safe work environment for all employees, fostering sustainable and responsible practices within the organization.

Frutas Patricia Pilar, SA. is committed to identifying and minimizing the environmental impacts and associated risks resulting from its operations. The company aims to implement appropriate environmental measures to promote environmental performance, prevent pollution, and protect the environment. This commitment is reflected in the following actions:

1. Environmental Impact Assessment: The company conducts regular assessments to identify and evaluate the environmental aspects associated with its activities. This allows for the implementation of measures to mitigate or eliminate adverse environmental impacts.
2. Rationalization of Energy Consumption: Frutas Patricia Pilar, SA. emphasizes the rational use of energy resources. As part of this effort, the company has implemented the use of photovoltaic panels to generate renewable energy and reduce its carbon footprint.
3. Water Consumption Management: The company actively seeks to rationalize water consumption by implementing efficient water management practices. These practices aim to minimize waste and promote responsible water use throughout the organization.
4. Proper Waste Treatment: Frutas Patricia Pilar, SA. is committed to proper waste treatment and disposal. The company follows best practices in waste management to minimize environmental harm, reduce waste generation, and promote recycling and reuse whenever possible.
5. Employee Awareness and Environmental Education: Frutas Patricia Pilar, SA. recognizes the importance of fostering environmental awareness among all employees. The company promotes environmental education initiatives to increase employee understanding of environmental issues and their role in implementing sustainable practices.
6. Compliance with Legal Environmental Requirements: The company ensures compliance with all relevant environmental laws, regulations, and standards. Frutas Patricia Pilar, SA. is committed to meeting or exceeding these requirements to protect the environment and contribute to environmental sustainability.

Through these measures, Frutas Patricia Pilar, SA. aims to integrate environmental considerations into its business practices, reduce its ecological footprint, and contribute to the preservation and protection of the environment.

The Code of Ethics and Conduct of Frutas Patricia Pilar, SA is widely disseminated through various channels to ensure accessibility and promote understanding. The dissemination methods include:

• Company Website: The Code is published on the company's official website at www.patriciapilar.pt for easy access to all employees and stakeholders.
• Internal Means: The Code is also shared through internal communication channels, such as the company network, to reach all employees and ensure they have access to the information.
• Paper Format: A printed version of the Code is made available so that everyone, including employees without online access, can consult and refer to it easily.

To address any doubts related to the interpretation or application of the Code, Frutas Patricia Pilar, SA provides the following communication channels:

• Email: Employees can reach out to the designated email address, sugestoes@patriciapilar.pt, to report any questions or seek clarification on the Code.
• Suggestion/Complaint Box: The company has installed a suggestion/complaint box at the reception area. Employees can use the form I045_Report Situações to submit their queries, suggestions, or complaints regarding the Code of Ethics and Conduct.

By providing multiple avenues for communication, Frutas Patricia Pilar, SA encourages open dialogue and ensures that any concerns or inquiries related to the Code can be addressed promptly and effectively.

Frutas Patricia Pilar, SA (GPP) acknowledges the importance of an internal whistleblowing channel and provides the following details for reporting any concerns or misconduct:

Reporting Channels - Reports can be made through the following channels:
E-mail: denuncias@patriciapilar.pt
Phone: 261 982 465

Mail: Rua Poço de Arroz, Nº2, Casal da Lapa, 2560-030 A-dos-Cunhados

Reporting Options: Reports can be submitted in writing or verbally. Whistleblowers have the choice to remain anonymous or provide their identification when making a report.

Responsible Individuals: The receipt and processing of reports are exclusively handled by the Human Resources Director of the Patricia Pilar Group, SA (Sarah Bernardes | 910 934 459). In the absence of the HR Director, the Financial Director of the Patricia Pilar Group, SA (Brigite Jorge | 910 950 703) assumes responsibility.

Processing Rules: The processing of received reports adheres to the following rules:

• Exhaustiveness, Integrity, and Conservation: Reports are treated with thoroughness, ensuring all necessary details are captured accurately and preserved for further investigation.
• Confidentiality: The identity of whistleblowers is kept confidential, and their anonymity is respected. The identity of any third parties mentioned in the report is also treated with confidentiality.
• Unauthorized Access Prevention: Measures are in place to prevent unauthorized access to the reports.
• Whistleblower Notification: Whistleblowers will be notified within the legally established deadlines regarding the status and progress of their report.
• Code of Conduct Manual: The Code of Conduct Manual, specifically addressing the New Whistleblower Protection Regime, is available on the document board displayed at the main reception.

Frutas Patricia Pilar, SA is committed to ensuring a secure and confidential whistleblowing process, enabling employees to report any concerns or potential misconduct without fear of reprisal.