holos@holos.pt+351 21 043 86 86

1. POLICY STATEMENT
All Donations and Sponsorship provided by the Company must be compatible with our business activities and reflect our commitment to operating in an ethical manner.  Donations and Sponsorship will not be given to organisations that the Company is in legal or financial conflict with or which connects the Company to any political party or group.

2. DEFINITIONS
“Company”: All subsidiaries and affiliated companies.
“Donation”: A Donation is a voluntary contribution in the form of monetary or non-monetary gifts to a fund or cause for which no return service or payment is expected or made.  Contributions to industry associations or fees for memberships in organisations that serve business interests are not necessarily considered Donations.
“Employee”: For the purposes of this policy this includes all individuals working at all levels and grades, including senior managers, officers, directors, employees (whether permanent, fixed-term or temporary), consultants, contractors, trainees, seconded staff, home-workers, casual workers and agency staff, volunteers, interns, agents, sponsors, or any other person associated with us, or any of our subsidiaries or joint ventures or their employees, wherever they are located.
“Sponsorship”: Sponsorship is about partnering with external organisations to deliver mutual benefits through an exchange of monies, products, services, content or other intellectual property.
“Third Party”: Any individual or organisation you come into contact with during the course of your work for us.  This includes actual and potential customers, suppliers, business contacts, Intermediaries, government and public bodies, including their advisors, representatives and officials, politicians and political parties.

3. SCOPE
This policy applies to all Employees and Third Parties of the Company in all countries or territories and shall be communicated to them at the outset of our business relationship and as appropriate thereafter.

4. WHAT DOES THIS MEAN?
4.1 Charitable donations by the Company may only be made where: • the donation is made in compliance with applicable laws; • the donation is not made to secure an improper business advantage; and • the donation is made to a properly established charity and there is a valid charitable purpose for the donation.

4.2 Promotional expenditure should seek to improve the image of the Company as a commercial organisation, to better present its products or services or establish cordial relations.  The provision of promotional items such as T-shirts, calendars, pens and other such similar items of modest value is permissible.  Any other promotional expenditure (including Sponsorship) must be reasonable and proportionate and the prior approval from the duly authorised Executive of the Company must be obtained.
4.3 No offers of Sponsorship shall be provided without the prior written consent of the duly authorised Executive of Company and any use of the Company trademarks must be referred for approval.
4.4 No Employee in or relating to the course of his/her employment, shall make any payment or other contribution to any political party, political office holder or candidate.
4.5 Donations or Sponsorship must not be made or offered in conjunction with, as part of or in relation to any bid, tender, contract renewal or prospective business relationship.
4.6 The Company will not enter into any charitable Donation or Sponsorship agreement with an organisation as a means of gaining favourable terms from that organisation or its affiliates/connected parties in any other business agreements.

5. YOUR RESPONSIBILITIES
5.1 Ensure any Donation or Sponsorship is compatible with the Company’s values and ethical policies such as the Anti-Bribery & Corruption policy.
5.2 All Donations and Sponsorship must be approved by your manager and reported to the Board of Directors.  A record of all Donations and Sponsorships should be maintained for audit purposes.
5.3 Any Employee who breaches this policy will face disciplinary action, which could result in dismissal for gross misconduct.
5.4 All Employees have the responsibility to read, understand and comply with this policy. You should at all times, avoid any activity that might lead to, or suggest, a breach of this policy.
5.5 This policy should be read in conjunction with the Company’s Code of Conduct.
5.6 Employees are encouraged to raise concerns about any instance, or suspicion, of malpractice at the earliest possible stage through their line manager and or Ethics & Compliance Helpline (ethicsandcompliance@holos.pt).

6. GOVERNANCE
The board of directors has overall responsibility for ensuring this policy complies with our legal and ethical obligations, and that all those under our control comply with it.

7. MONITORING AND REVIEW
7.1 The Company will establish and put in place appropriate performance measures and reporting systems to monitor performance against metrics and compliance with the relevant policies, procedures and controls.
7.2 The Board of Directors will monitor the effectiveness and review the implementation of this policy, regularly considering its suitability, adequacy and effectiveness.  Any improvements identified will be made as soon as possible.
7.3 Internal control systems and procedures will be subject to regular audits to provide assurance that they are effective.