Code of Ethics and Conduct

1. Introduction

This document is the property of GRACENTUR – GRANDE CENTRO TURÍSTICO, LDA. This document may not be reproduced in whole or in part, computer processed or transmitted in any form by electronic, mechanical, photocopying, recording or any other means. Likewise, it cannot be loaned or assigned any form of use without prior written permission from the entities holding the intellectual property rights. Failure to comply with the limitations identified here by any person who has access to the documentation will be subject to sanctions provided for in applicable legislation.

2. Code of Ethics and Conduct:

All professionals at GRACENTUR – GRANDE CENTRO TURÍSTICO, LDA (hereinafter referred to as HCM), have an unshakable commitment to the honor, nobility and dignity of the profession, always acting with technical independence, decorum, loyalty and good faith. HCM's commitment to ethics and integrity in the provision of services led us to draw up our own document, which aims to govern the relationship between the members of our team, not only with each other, but also when dealing with clients, public authorities, suppliers, competitors and society in general. The procedures, rules and ethical standards set out in the Code of Conduct will be adopted by all HCM employees, without distinction. Adherence to and strict compliance with its terms are essential requirements for maintaining the relationship with our HCM, and any changes or additions to the Code will be immediately communicated and made available to all employees. Violation of the terms of the Code implies disciplinary action, which may even result in the termination of the contract with the employee. All violations or suspicions must be immediately reported to the Human Resources Director. HCM will preserve confidentiality regarding the communication of violations or suspicions and prohibits any type of retaliation against employees who report them in good faith. Requests for clarification regarding the content of the Code, or its application, must be requested from our Human Resources Department.

2.1 What is the Code of Conduct?

The HCM Code of Conduct aims to establish fundamental ethical principles and guidelines to be adopted by all employees, in their internal and external relationships, in everything related to HCM activities. This Code establishes values ​​of integrity and ethical conduct for the best daily development at HCM. All employees are expected to conduct themselves with integrity, compatible with the company's values, acting fairly in fighting, setting an example and preventing unethical acts from being committed or repeated around them in the work environment. The Code certainly does not exhaustively detail the countless situations that may arise on a daily basis; However, the search for an ethical stance must be constant.

2.2 Scope of the Code of Conduct

The Code of Conduct applies to all HCM employees, without distinction, including partners, associates, interns, temporary workers, external consultants, fixed-term workers or service providers, clients, suppliers, respecting and not overlapping in any conflict with the specific terms and conditions of each of the forms of employment with HCM, such as service provision contracts, internship contracts, among others. Compliance with these standards highlights our excellence as an ethical institution and confirms our professional commitment, in addition to contributing to the good image of HCM.

2.3 Consequence of violating the Code of Conduct

Adherence to and strict observance of the terms of the Code of Conduct are essential requirements for maintaining the relationship with HCM. Failure to comply with the Code or any applicable policies and procedures, when found by internal or external investigation, will result in the adoption of disciplinary measures, such as a warning, suspension or even termination of the contract maintained with HCM. Failure to comply with the Code that, directly or indirectly, causes damage to HCM constitutes grounds for proposing civil legal action against the non-compliant party, aiming to repair the damage caused to HCM through civil liability and criminal action.

2.4 Questions regarding the Code of Conduct

Each HCM Employee is responsible for their behavior and actions. Whenever you deem it necessary, you should seek guidance regarding the interpretation or application of the rules set out in this Code. Any questions regarding this Code or other HCM policies and procedures should be clarified directly with HCM management.

2.5 Obligation to report violations of the Code of Conduct

All HCM employees, interns and temporary workers have the obligation to immediately report any well-founded suspicion or actual violation of this Code of Conduct or any law or regulation in force by other employees; as well as having the obligation to immediately report any conduct that is offensive, illegal or that violates the basic principles of this Code, on the part of customers, suppliers or any individuals that HCM hires. Confidentiality must be preserved regarding the communication of violations or suspicions mentioned above. HCM prohibits any type of retaliation against Employees who report it in good faith. The above communications must be directed exclusively to the person responsible for complying with the Code, who is Dr. Jorge Nunes, Director of Human Resources, verbal or written communication via the following email address:denuncia.int@cascaismirage.com

3. Framework, awareness and commitment to comply with the Code of Ethics and Conduct:

HCM aims to establish itself in the market as an honest and upstanding company in the conduct of its activities, and this position is only possible with the professional conduct of its employees. Relationships in the workplace must be guided by courtesy, honesty, integrity and, above all, mutual respect, regardless of the role or position held. Teamwork must be stimulated through mutual cooperation, taking into account individual characteristics. The democratic stance in the face of divergence and diversity must be seen as healthy and beneficial while creating opportunities for development and evolution. It is important to recognize individual and team talents, providing equal access to existing professional development opportunities, according to the characteristics, skills and contributions of each person. This code is subject to periodic reviews, at most every 3 years, in order to ensure its continuous improvement and compliance with legal and regulatory standards in HCM's sector of activity.

3.1 General Framework: Scope of application

This Code of Ethics and Conduct covers all HCM employees, whether they are members of the administration, workers with an open-ended or fixed-term contract, service providers, attorneys or agents, interns, temporary workers, suppliers, customers, all of whom must be committed to its values ​​and objectives. This Code applies to all employees, regardless of their contractual relationship and the hierarchical position they occupy. Suppliers, in particular, must also subscribe to this Code. This code applies regardless of ethical standards to which any employee is subject specifically depending on their own sector of activity. Each HCM employee and supplier will be asked to sign a declaration acknowledging the code and committing to comply with it and/or sending it via email with a read receipt.  To customers, the Hotel asks all customers to conduct themselves with respect for others, not promoting noise in rooms, corridors and other public areas. All types of violent or inappropriate behavior will be reported to the police authorities. Respect space schedules. “For the protection of everyone, the Hotel is under closed circuit television surveillance, with images being recorded. Decree-law 35/2004 of 21 February, article 13 number 3.                                                                                                    The Hotel has a Complaints Book, located at the Hotel Reception.

3.2 Mission

HCM aims to be a reference in the hotel industry in Portugal, providing excellent service to customers and ensuring commitment to employees, customers, suppliers and other stakeholders. It aims to combine the well-being of those who work there with the well-being of the community in general, and its customers in particular. HCM, when providing services in the hotel sector, is recognized in the hotel sector as a company with a recognized reputation at national and international level.

3.3 Behavioral Values

HCM's conduct is governed by the legislation applicable to our sector of activity: hospitality, tourism and leisure. HCM's standard of behavior is governed by the highest values, such as ambition, integrity, honesty, commitment, excellence, trust, cohesion and team spirit. HCM always acts with unwavering respect for people's rights, which translates into an excellent work environment based on 5 principles: Satisfaction, Customer, Proximity, Commitment, Dynamism and Growth. 

It is mandatory for any guest, whether national or foreign, to present valid identification documents at the time of "Check-in" to stay at the Hotel. Decree-Law No. 98/2021 of November 16th.

The Hotel reserves the right to prevent customers, suppliers or others from staying in the unit, in cases where they show signs of behavior. It is expressly prohibited to touch the decorative pieces present throughout the Hotel, including inside the rooms.  We ask customers accompanied by children to ensure that they do not cause disturbances that bother other customers: It is expressly prohibited for unaccompanied children to be present in the Hotel in general and in particular in the rooms, elevators, swimming pools and "Kids Place".

The Hotel asks all customers to behave respectfully towards others, not promoting noise in rooms, corridors and other public areas. All types of violent or inappropriate behavior will be reported to the police authorities. 

"For everyone's protection, the Hotel is under closed circuit television surveillance, and images are being recorded." Decree-Law 35/2004 of 21 February, article 13, number 3

It is not permitted to walk bare-chested or unclad between corridors, elevators, Looby, Reception, Restaurants and Bar. It is only permitted to walk barefoot in the pool area. 

3.4 Objectives

HCM bases its activity and business relationships on professionalism, integrity, commitment and dedication. HCM intends to be recognized for the maximum quality of the service provided, developing its strategic objectives with an attitude of total responsibility and respect for ethics. The ultimate objective of this Code is to compile the rules that should guide the behavior of all those who collaborate with HCM and to affirm and make known HCM's values.

3.5 Principles

HCM employees are subject to the principles of legality, good faith and transparency, responsibility and efficiency, equality and non-discrimination, loyalty and confidentiality. o Legality All HCM employees must respect and ensure scrupulous compliance with the legal and regulatory standards applicable to the activity of HCM and the employee. o Good faith and transparency All HCM employees must base their conduct (internal and external) on high moral standards, always providing truthful information. 

- Responsibility and efficiency

All HCM employees must carry out the tasks assigned to them with zeal and professionalism, always having as their scope the objectives outlined by HCM

- Equality and Non-Discrimination

None of HCM's employees should adopt any type of discriminatory behavior, in particular, based on ancestry, sex, race, language, territory of origin, religion, political or ideological beliefs, education, economic situation, social status or sexual orientation. The recruitment, selection, performance evaluation, remuneration and professional progression policies of employees are based on the merit of each one, and everyone will have equal opportunities to develop their career.

- Loyalty

All employees must make a serious effort to safeguard HCM's credibility, prestige and image, refraining from making derogatory comments among themselves or third parties.

- Confidentiality

All HCM employees must maintain absolute secrecy and reserve in relation to third parties all information they become aware of in the course of performing their duties, even after they have ceased.

3.6 Internal and external relations

Relations between employees

With respect for the HCM hierarchical structure that can be consulted in the organization chart, [which constitutes Annex I of this code], employees must act daily with team spirit, sharing knowledge and information, striving to increase productivity and maintain a healthy and trusting climate, treating each other with cordiality and correctness.

- Relationships with third parties and Relationships with customers:

All HCM employees must act effectively and professionally and provide quality services that increase HCM's image and reputation among its customers, strengthening relationships with them.

- Relationships with suppliers and service providers:

Suppliers and service providers are selected by HCM independently and objectively, depending on market offers, basing the choice on objective cost and quality criteria. All commercial relationships established with suppliers or service providers will be reduced to a written contract, in strict compliance with applicable legislation.

- Relations with the media:

Any statements to the media must be preceded by prior written authorization from the administration/management and management for that purpose. Such statements must respect the truth and be limited to facts, without issuing any considerations or opinions.

- Social media:

Employees cannot use social media to denigrate or expose situations or people inherent to HCM. This premise covers written information and unauthorized use of photographs or videos.

- Relations with public authorities:

HCM provides all legal information about you that prevents public authorities from requesting it, with complete transparency and truth.

3.7 Safety and hygiene at work

HCM provides a healthy and safe working environment for its employees, to whom it provides full protection, complying with legal standards regarding safety and hygiene at work. HCM employees are obliged to keep their workplaces clean and orderly, not only in their offices, but also at their desks. Drug use is not permitted on HCM facilities. The use of alcohol is not permitted on HCM facilities, except at events previously authorized by HCM. Any and all conditions dangerous to health or safety must be reported.

3.8 Use of work instruments

HCM employees are obliged to use, diligently and efficiently, the work tools made available to them by HCM, protecting and preserving them. The use of the working tools provided for private purposes is not permitted. The use of equipment such as laptops or other devices outside HCM facilities must be preceded by respective authorization.

3.9 Training

HCM promotes continuous training for its employees, as a way of enhancing their skills, performance and motivation. Employees must also strive to update their knowledge and skills. All employees receive initial internal training when they begin their duties and all employees are provided with the necessary training to monitor changes that are to be implemented.

3.10 Meritocracy

Both the recruitment policy, the evaluation policy and consequent updating of remuneration and the professional progression of employees are based on the merit of the candidate/employee.

3.11 Conflict of interest

There is a conflict of interest when the personal interest of an employee interferes with the interest of the company. All HCM employees must always act in its interests and act in a way to avoid a collision of interests. In case of doubt, the employee must request clarification from his/her superior and refrain from any practice.

3.12 Gifts, hospitality and invitations

It is mandatory for all HCM employees to communicate offers from suppliers and/or customers in cash or in kind above €50.00 to the person responsible for the Conduct Manual. Any doubts must be raised internally by the employee to his/her superior.

3.13 Corruption and Related Offenses

HCM repudiates any practice of corruption, bribery or related infraction, actively or passively, and other forms of undue influence or illicit conduct, imposing strict compliance with these principles in all its internal and external relations, whether with private entities, public entities and individuals. All Employees must comply with applicable national and international standards to combat corruption and related offenses, with any and all behaviors that may constitute the commission of the crime of corruption or any related offense provided for in the current criminal code law being prohibited. HCM has developed and implemented a plan to prevent the risks of corruption and related infractions, delivered as part of the training to all Employees, which can be consulted at www.cascaismirage.com. Attached to this document for information is the table of the corruption risk prevention plan and related infractions with a summary of the situations, measures and sanctions.

3.14 Confidentiality

Confidential information is all non-public information, written or oral, disclosed by HCM to the employee, directly or indirectly, through any means of communication or observation, which, if disclosed, could be used by competitors for their own benefit and harm HCM or its customers. Confidential information includes business secrets, customer data and information, databases, customer and supplier lists, costs, service prices, information on IT support, business strategies. Therefore, all HCM employees who are aware of this type of information must maintain their confidentiality, unless they obtain prior and express authorization from HCM. In case of doubt about the type of information held or about a possible lapse in the disclosure of confidential information, the employee must immediately communicate what happened to their superior.

3.15 Non-compete

HCM employees must remain loyal to HCM, always looking out for its interests in relationships with third parties, while maintaining the employment or commercial relationship with HCM and even after its termination. HCM employees must therefore refrain from any type of practice or activity that, in any way, may compete directly or indirectly with those pursued by HCM.

3.16 Equality and prohibition of harassment

Harassment constitutes any unwanted behavior that may disturb or embarrass a specific person, affecting their dignity or creating a hostile, intimidating, degrading or humiliating environment. It is considered a discriminatory practice to privilege, benefit, harm, deprive of any right or exempt from any duty based on, in particular, ancestry, age, sex, sexual orientation, gender identity, marital status, family situation, economic situation, education, origin or social condition, genetic heritage, reduced work capacity, disability, chronic illness, nationality, ethnic origin or race, territory of origin, language, religion, political or ideological beliefs and trade union membership. Any and all conduct that substantiates any of the concepts mentioned above, therefore negatively affecting the dignity of any HCM employee, is prohibited.

3.17 Data protection

HCM, due to legal and contractual obligations, processes the personal data of employees, only as necessary for the purposes inherent to the contractually established relationship, whether established with workers or service providers. HCM fully complies with current EU and national legislation relating to data protection and specific to its field of activity, also applicable to data protection. HCM has developed and implemented a data protection manual that can be consulted at www.cascaismirage.com.

3.18 Supervisory body

The following is the responsibility of the supervisory body:

Ensure the dissemination of this code of conduct;

Analyze and issue opinions on violations of this code;

Ensure the existence of internal mechanisms for reporting infractions, in accordance with applicable legislation;

Clarify any doubts that this code raises.

The supervisory body is: the Human Resources Department.

3.19 Non-compliance and disciplinary action

In the event of violation of the provisions contained in this code of conduct by HCM Employees, they are subject to the exercise of its disciplinary power, under the terms set out in the Labor Code. Substantiated complaints must be sent to the Human Resources Department, via the following email address: denuncia.int@cascaismirage.com, which must follow up accordingly. In case of violation of the provisions contained in this Code of Conduct by attorneys, service providers, suppliers, agents or third parties, the sanctions provided for in this code will be applied to them as well as those provided for in the contractual instruments established with each one, and the established commercial relationship will also be reassessed, case by case. Reports of infractions must be made in writing to the supervisory body. Violations of this code may also be punished criminally and civilly, if there is a basis.

3.20 Entry into force and disclosure

This code comes into force on the day of admission for new employees and on the date of communication of changes for other employees. HCM intends to consolidate the application of the principles established in this code and the behaviors provided for in it, and therefore promotes its dissemination both internally, through emails and the intranet, and externally, through the website.

4. Document ownership and approval

The Data Protection Officer is the owner of this document and is responsible for ensuring that this notice is reviewed in accordance with the requirements set out for this purpose in the General Data Protection Regulation. The latest version of this document is published and available for consultation by all interested parties. This notice was approved by the Data Protection Officer in May 2018 and this controlled copy was issued.

Review and insertion of anti-corruption code 12/02/2025

5. Associated Risk Applicable Sanctions Offers - Employees or managers who receive bribes or personal benefits from suppliers in exchange for contracts or preferential treatment. Application of disciplinary process with a view to dismissal for just cause Inflated prices - Suppliers inflating prices, with employees colluding for personal gain. Application of disciplinary proceedings with a view to dismissal for just cause

Favoritisation - Awarding contracts to friends, family or preferred suppliers without following fair procedures. Application of disciplinary proceedings with a view to dismissal for just cause

Embezzlement - Misappropriation of funds by employees who manage cash transactions, income or expenses. Application of disciplinary proceedings with a view to dismissal for just cause

False Invoicing - Creating false invoices to divert hotel funds to personal accounts. Application of disciplinary proceedings with a view to dismissal for just cause

Unrecorded Payments - Personnel who do not record income or divert funds from cash payments. Application of disciplinary proceedings with a view to dismissal for just cause

Nepotism – Hiring or promoting individuals based on personal relationships rather than qualifications. Application of disciplinary proceedings with a view to dismissal for just cause

Bribery in Recruitment – Candidates paying bribes to secure employment or favorable positions. Application of disciplinary process with a view to dismissal for just cause Ghost employees - listing false employees on the payroll and embezzling their salaries. Application of disciplinary proceedings with a view to dismissal for just cause

Bribes for Services - Guests or third parties offering bribes for preferential treatment, such as room upgrades or better reservations. Application of disciplinary proceedings with a view to dismissal for just cause

Misuse of Guest Information -Selling or exploiting guests' personal information for financial gain. Application of disciplinary proceedings with a view to dismissal for just cause and criminal complaints in official entities.

Extortion - Employees soliciting bribes from guests to resolve disputes or provide basic services. Application of disciplinary proceedings with a view to dismissal for just cause and criminal complaints in official entities.

Bribes to authorities – Paying officials to bypass inspections, acquire licenses, or avoid penalties for noncompliance. Application of disciplinary proceedings with a view to dismissal for just cause and criminal complaints in official entities.

Manipulation of Inspections - Offering gifts or incentives to influence the outcome of health, safety or regulatory inspections. Application of disciplinary proceedings with a view to dismissal for just cause

Unauthorized Discounts or Overbilling - Employees providing unauthorized discounts for personal tuition or overbilling and pocketing the difference. Application of disciplinary proceedings with a view to dismissal for just cause

Inflated costs for event services - Collusion with suppliers or event organizers to inflate hotel service fees. Application of disciplinary proceedings with a view to dismissal for just cause

Collusion with Travel Agents or Tour Operators - Offering undisclosed commissions or bribes to agents in exchange for directing guests to the hotel. Application of disciplinary proceedings with a view to dismissal for just cause

Inflated maintenance costs - Personnel colluding with contractors for inflated service fees or unnecessary repairs. Application of disciplinary proceedings with a view to dismissal for just cause

Misappropriation of property - Theft or misuse of hotel equipment, supplies or facilities for personal benefit. Application of disciplinary proceedings with a view to dismissal for just cause

Fraudulent promotions - Collaborate with external agencies to create false marketing campaigns and embezzle funds. Application of disciplinary proceedings with a view to dismissal for just cause Offers for

Advertising Contracts - Receiving bribes or gifts in exchange for awarding contracts to specific advertising companies Application of disciplinary proceedings with a view to dismissal for just cause

Data manipulation - Altering financial or operational data to hide corrupt practices. Application of disciplinary proceedings with a view to dismissal for just cause

Unauthorized Access - Exploit hotel management software to divert funds or manipulate reservations for personal gain. Application of disciplinary proceedings with a view to dismissal for just cause 

Selling Sensitive Data – Employees selling confidential guest information or hotel trade secrets. Application of disciplinary proceedings with a view to dismissal for just cause

Unauthorized agreements - Signing agreements with unverified suppliers in exchange for bribes. Application of disciplinary proceedings with a view to dismissal for just cause

Undisclosed Relationships - Employees or managers who work with or favor companies owned by family or friends. Application of disciplinary proceedings with a view to dismissal for just cause

Self-Dealing - Employees who direct hotel resources to benefit their business or private investments. Application of disciplinary proceedings with a view to dismissal for just cause

February 2025