Effective January 1, 2025

• Organization: CODEMAKER Unip. Lda.
• Address: Av. Visconde Barreiros, 358, 4th Floor, Right Wing, 4470-151 Maia, Portugal

1. Introduction

This Code of Ethics and Conduct establishes the ethical principles, values, and standards of behavior that guide the actions of all employees, managers, service providers, partners, and other representatives of Codemaker Unip, Lda.

The purpose of this policy is to ensure that all our actions are guided by integrity, accountability, respect, and professionalism, thereby fostering a healthy, transparent, and ethical organizational culture.

2. Scope of Application

This code applies to:

• employees (permanent and temporary);
• members of the administration and management;
• interns and consultants;
• partners, suppliers, and service providers acting on behalf of the company.

3. Ethical Principles

1. Integrity: acting with honesty, consistency, and transparency in all situations.
2. Respect for people: valuing diversity, promoting equality, and combating all forms of discrimination or harassment.
3. Responsibility: to fulfill the commitments made to customers, colleagues, partners, and society.
4. Professionalism: acting with competence, dedication, and technical rigor, while adhering to professional standards.
5. Transparency: ensuring clear, honest, and objective communication.
6. Confidentiality: protecting the information of the company, its customers, and its partners.
7. Compliance: Comply with applicable national laws and regulations, including the GDPR, labor laws, and contractual obligations.

4. Expected Conduct

4.1. In the workplace

• To promote collaboration, mutual trust, and team spirit;
• treat everyone with respect, courtesy, and impartiality;
• prevent and report discriminatory, abusive, or unethical behavior;
• ensure a safe, inclusive, and productive work environment.

4.2. Relationships with Customers and Partners

• Act with integrity, loyalty, and professionalism;
• meet agreed-upon deadlines, commitments, and quality standards;
• maintain clear and responsible communication;
• comply with clients' policies and standards.

4.3. Use of Company Resources

• Use the company's equipment, systems, and information responsibly;
• prevent the misuse or personal use of the organization's resources;
• protect the company's physical and digital assets from loss, damage, or misuse.

4.4. Conflict of Interest

• Avoid situations in which personal interests might interfere with professional decisions;
• report any potential conflict to your supervisor;
• act impartially and objectively in all decision-making processes.

4.5. Corruption and Bribery

• Any form of corruption, bribery, improper payment, or dishonest practice, whether direct or indirect, is strictly prohibited;
• All business relationships must comply with the principles of legality and professional ethics.

4.6. Data Protection and Privacy

• Strictly comply with the GDPR and all other applicable regulations;
• ensure the proper and secure handling of personal and confidential data;
• Use sensitive information only for authorized and lawful purposes.

5. Social and Environmental Responsibility

Codemaker Unip. Lda. promotes sustainable, mindful, and responsible practices toward the environment and the community. All employees must:

• minimize waste and the environmental impact of its activities;
• support initiatives related to inclusion, social responsibility, and citizenship;
• to act ethically even outside the workplace, as representatives of the organization.

6. Complaints and Ethics Channel

Everyone has a duty to report situations that violate this code. The company has a confidential, impartial, and secure reporting channel that ensures the whistleblower is protected against any form of retaliation.

Ethics Channel: info@codemaker.pt

7. Consequences of Noncompliance

Violation of the principles or rules set forth in this code may result in disciplinary action, in accordance with applicable labor laws and the company’s internal regulations, including a warning, suspension, or, in serious cases, termination.

8. Review and Dissemination

This code will be reviewed periodically to ensure it remains up to date with legal, technological, and organizational developments. It is available to all employees and is an integral part of Codemaker Unip, Lda.’s culture.