Corporate Code of Ethics

OBJECTIVES

This Corporate Code of Ethics (hereinafter referred to as the “Code”) establishes a set of principles, rules, and values that govern the internal and external relations of Osiris Travel – Viagens e Turismo, Lda. and its subsidiaries (hereinafter jointly referred to as OSIRIS) and was created with the fundamental objective of sharing these principles, rules, and values, as well as promoting and encouraging their adoption.

SCOPE OF APPLICATION

The Code applies to all members of the corporate bodies, employees, and collaborators of OSIRIS, regardless of their contractual status (hereinafter referred to as Collaborators). It is also intended for third parties that contract with OSIRIS or act on its behalf, namely suppliers and partners.

PRINCIPLES

The corporate and professional behavior of the entities and stakeholders covered by this Code must respect the following principles:

Principle of legality – acting in strict compliance with the constitutional and legal framework in force in each of the locations where OSIRIS operates;
Principles of justice and impartiality – treating, in all cases, fairly and impartially all citizens and other entities and organizations with which they interact, prohibiting arbitrary practices or decisions and behaviors that result in illegitimate benefits or losses;
Principle of equality – acting in a way that does not benefit or harm any person, entity, or organization based on their ancestry, sex, race, language, political, ideological or religious convictions, economic situation or social condition, or any other factor that increases the likelihood of inequality of opportunity or treatment, ensuring that identical situations receive equal treatment;
Principle of proportionality – acting so that their conduct is appropriate and proportional to the objectives to be achieved and the tasks to be performed;
Principles of collaboration and good faith – collaborating with any persons, entities, or organizations with which they interact to achieve the most appropriate result for the fulfillment of their mission, and acting in a way that does not create unjustifiable obstacles or difficulties for those persons, entities, or organizations;
Principle of providing quality information – providing any information requested of them or that they must provide to the recipients of OSIRIS’s activity in the most complete, truthful, up-to-date, clear, objective, and rapid manner possible, always respecting the law and regulations in force;
Principle of loyalty – acting in a loyal, supportive, and cooperative manner, both among themselves and with the persons and entities, public and private, with which they interact in the context of OSIRIS’s activity;
Principle of integrity – guiding their conduct by criteria of personal and professional honesty, and not adopting any acts that may harm other Collaborators or the persons or entities with which they interact;
Principles of competence and responsibility – acting in a responsible and competent, dedicated, and critical manner, committing to professional development and the rigorous fulfillment of their mission;
Principle of courtesy – treating everyone they interact with in a cordial, respectful, and thoughtful manner, fostering a healthy work environment and a conciliatory and cooperative relationship with other persons and entities.

RELATIONS WITH AND BETWEEN COLLABORATORS

OSIRIS’s relationship with its Collaborators and between them will be based on compliance with the following commitments:

Respectful treatment and prohibition of discrimination: OSIRIS assumes the responsibility of maintaining a workplace free from all discrimination and any improper conduct of a personal nature; all Collaborators will be treated fairly and with respect by their hierarchical superiors and colleagues; any abusive, hostile, or offensive conduct, whether verbal or physical, will not be tolerated.
Equal opportunities: all Collaborators will enjoy equal opportunities for career development; OSIRIS commits to establishing an effective equal opportunity policy so that its Collaborators develop their professional activity based on merit; OSIRIS Collaborators will respect the equal opportunity policy in their professional sphere and support the personal and professional education of their colleagues.
Occupational health and safety: OSIRIS will provide its Collaborators with a safe and stable workplace and commits to permanently updating occupational risk prevention measures, as well as respecting the applicable regulations in all locations where it operates; all Collaborators must strictly comply with health and safety standards.
Respect for privacy and confidentiality of information: OSIRIS commits to requesting and using exclusively the data of Collaborators that are necessary for the efficient management of its business and those required by applicable regulations; Collaborators who, by reason of their function, have access to confidential information must respect the same principles and will be responsible for said information;
Promotion of personal and professional balance: OSIRIS will promote the balance between the personal and professional lives of its Collaborators; OSIRIS values and promotes benefits that imply the existence of a balance between the professional and personal responsibilities of the Collaborator.

COMMITMENTS TO THIRD PARTIES AND THE MARKET

OSIRIS and its Collaborators will base their relations with clients and suppliers, competitors and partners, investors, and all market agents on the following commitments:

Fair competition: OSIRIS prohibits any action that involves the exercise of illicit practices and unfair competition and commits to controlling and monitoring compliance with the competition laws applicable in the locations where it carries out its activities;
Quality: OSIRIS is committed to the perceived quality of its services among all those who interact with it; OSIRIS will always seek the best satisfaction of its clients’ expectations and will make an effort to anticipate knowledge of their activities and needs;
Confidentiality of information to third parties: OSIRIS will guarantee the confidentiality and privacy of third-party data to which it has access; OSIRIS commits to preserving the confidentiality of data it holds from third parties, except in legal, administrative, or judicial obligations that require delivering them to entities or persons or making them public; OSIRIS Collaborators, in the performance of their professional activity, will maintain the confidentiality of data, under the terms mentioned above, and will refrain from any inappropriate use of this information; whenever personal data is involved, OSIRIS and its Collaborators must fully comply with the applicable standards related to the protection of personal data;
Transparency, value creation, and Corporate Governance: OSIRIS assumes as a guiding principle of its corporate behavior towards all stakeholders and the market in general, the transmission of truthful, complete information that expresses a fair image of the company and its business activities and strategies; OSIRIS’s corporate action and strategic decisions are guided by the creation of value for its clients, suppliers, and partners, transparency in management, and the adoption of best corporate governance practices;
Protection of corporate assets: OSIRIS and its Collaborators will always seek the best protection of the assets and rights that constitute the heritage of the company and its partners, preserving the confidentiality of their information, which may only be used within the scope of the company’s activity; OSIRIS Collaborators are responsible for protecting the assets of the company and its partners and for preventing any loss, damage, theft, illegal or dishonest use of the same;
Use of information concerning OSIRIS: OSIRIS requires its Collaborators to make discrete and professional use of the company information to which they have access in the performance of their activity, as well as to limit its use to the company’s own activities.

GIFTS AND COMMERCIAL OFFERS

OSIRIS does not encourage the practice of giving or receiving gifts and commercial offers. Collaborators must not accept, for their own benefit, goods, services, or any advantages with an individual value exceeding €100 (including Christmas gifts) from clients, suppliers, service providers, partners, or any other individual or collective entity that has had, has, or intends to have business relations with OSIRIS. However, if its non-acceptance or return becomes unfeasible or inadvisable, the offer must be previously approved by OSIRIS Management, and it may be decided that it reverts to company property, in which case the Collaborator must deliver it to the person responsible for human resources. The value of offers is calculated in the total of all offers from the same person or entity during a calendar year.

The previous restriction does not apply to offers or payments for goods or services, such as travel, meals, accommodation, or shows, which are granted by third parties to the collaborator because of the exercise of their position, within the scope of their representation duties and in the interest of OSIRIS. The exceptions described above must be previously communicated to the hierarchical superior.

The offering of goods to any external entity, carried out by an OSIRIS collaborator, is only admissible provided that, cumulatively, it is made on behalf of the company, is related to its activity, and corresponds to the usual uses or practices of the sector, and must be previously approved by the respective hierarchical superior.

The offering or receipt, under any circumstances and regardless of value, of money, checks, and other goods subject to legal restrictions is prohibited.

CONFLICT OF INTEREST

Collaborators must maintain loyal behavior towards OSIRIS, avoiding any situation or activity that may lead to a conflict of interest or harm professional performance and refraining from intervening in decision-making processes that may result in a potential conflict of interest.

For the purposes of this Code, a conflict of interest exists whenever an OSIRIS collaborator has a personal or private interest in a certain matter that may influence, or appear to influence, the impartial and objective performance of their duties.

Personal or private interest is understood as any potential advantage for themselves, their spouse or person with whom they live in conditions analogous to those of spouses, relative or kin, as well as for their circle of friends and acquaintances.

OSIRIS Collaborators who, in the exercise of their duties, are faced with a situation likely to constitute a conflict of interest, must inform OSIRIS management of its existence and declare themselves impeded or request to be excused from performing the conflicting activity or task. If it is impossible to refrain from intervening in these situations, they may only intervene with prior written authorization from OSIRIS management.

OSIRIS Collaborators must also refrain from participating or exercising functions in entities or organizations in which the activity to be developed may conflict with the fulfillment of their duties at OSIRIS or whose purposes may be contrary to those of OSIRIS.