Donation and sponsorship policy

Policy statement

Such contributions will not support organisations with which the company has a legal or financial conflict, nor those that would connect the company to political parties or groups.

Definitions

• Company: all subsidiaries and affiliated companies.
• Donation: a voluntary contribution, in the form of a monetary or non-monetary gift, to a fund or cause for which no return service or payment is expected or made.
• Employee: all personnel levels, including permanent and temporary staff, consultants, contractors, volunteers, interns and agents across all locations.
• Sponsorship: partnering with external organisations to deliver mutual benefits through an exchange of money, products, services, content or other intellectual property.
• Third party: any individual or organisation contacted during business operations, including customers, suppliers, government bodies and politicians.

Scope

This policy applies to all employees and third parties, across all countries and territories.

What does this mean?

• Charitable donations may only proceed when made lawfully, without securing an improper advantage, and directed to properly established charities with a valid charitable purpose.
• Promotional expenditure should improve the company's image or present its products and services appropriately. Promotional items such as T-shirts, calendars and pens of modest value are permissible; other promotional activities require authorisation from duly authorised company executives.
• Sponsorship offers all require prior written executive consent, and trademark usage requires separate approval.
• Political restrictions: no employee, in or relating to the course of their employment, shall make any payment or other contribution to any political party, office holder or candidate.
• Bid-related restrictions: donations or sponsorships cannot accompany bids, tenders, contract renewals or prospective business relationships.
• Affiliate transactions: the company prohibits charitable arrangements designed to gain favourable terms from recipient organisations or their affiliates in separate business agreements.

Your responsibilities

Employees must ensure that donations and sponsorships align with the company's values and ethical policies. All such contributions require manager approval and board reporting, with records maintained for audit purposes. Breaches may result in disciplinary action, including dismissal for gross misconduct. Concerns should be raised through a manager or the Ethics & Compliance Helpline atethicsandcompliance@holos.pt.

Governance

The board of directors retains overall responsibility for compliance with this policy and for ensuring adherence throughout the organisation.

Monitoring and review

The company establishes performance measures and reporting systems to monitor compliance. The board regularly reviews the policy's effectiveness and suitability, and the internal control systems are subject to regular audits.