Code of Conduct

Code of Conduct

1. Introduction

Advanced Resources carries out its activities based on the trust that clients place in the services provided to them.

This trust is founded on the experience, technical expertise and professionalism of our teams.

The company delivers services to the highest quality standards, complying with applicable legal and regulatory requirements and the specific requirements of each client.

This Code of Conduct defines the principles and rules of behaviour applicable to all employees, partners and suppliers, and is mandatory in the exercise of any professional activity carried out on behalf of the company.

2. Scope of Application

This code applies to all Advanced Resources employees, regardless of their type of employment contract, as well as to partners, suppliers, subcontractors and any third parties acting on behalf of the company or in the provision of services to its clients.

It also incorporates the conduct requirements set by the company's main partners.

3. Fundamental Principles of Ethics and Conduct

3.1 Respect for Human Rights

Advanced Resources recognises the United Nations Universal Declaration of Human Rights and expects all employees to conduct themselves with respect for human dignity, without distinction of race, sex, nationality, ethnicity, language, religion or any other condition.

No form of discrimination is tolerated in professional relationships, whether based on colour, sex, religion, origin, social class, political beliefs, language, sexual orientation, age or physical disability.

3.2 Confidentiality and Professional Secrecy

All employees are subject to a duty of professional secrecy regarding company and client information, and must adopt a discreet and reserved attitude towards facts and data they become aware of in the exercise of their duties. They must also comply with confidentiality obligations arising from written agreements or applicable legislation.

3.3 Environmental Protection

Advanced Resources promotes the continuous improvement of its environmental performance, raising employee awareness of responsible conduct and compliance with all applicable legal requirements. When on partner premises, all those involved in delivering our services must ensure responsible and safe environmental behaviour.

3.4 Safety, Health and Wellbeing at Work

Advanced Resources ensures a safe and healthy working environment, in accordance with applicable national and international legislation. When on partner or client premises, employees must comply with all applicable safety rules. The following are prohibited:

  • Consuming, possessing, distributing or selling alcohol or drugs (except prescribed medication) on partner premises or during service delivery;
  • Engaging in any form of verbal or physical violence in the workplace;
  • Accessing partner premises under the influence of substances.

Accidents, incidents or hazardous material spills on partner premises must be reported immediately to the local safety officer. Employees who transport or handle hazardous materials are responsible for ensuring their correct containment and for notifying the safety representative (HSS) of any problem, accident or spill occurring during transport or near partner premises.

3.5 Sustainability

Advanced Resources operates in a responsible and sustainable manner, guiding its conduct by the principles of social, environmental and economic responsibility.

3.6 Client Relations

Client satisfaction is the company's primary commitment. All employees must respect client requirements and rights and actively seek solutions that serve their interests.

3.7 Professional Conduct

Advanced Resources invests in the development of its employees through technical training and ethical conduct awareness. Employees are expected to pursue continuous improvement, contributing to a positive working environment and to the company's objectives.

4. Anti-Corruption and Bribery

Advanced Resources does not tolerate corruption or bribery under any circumstances.

It is prohibited to offer, promise, accept or solicit any undue advantage — in cash or in kind — to influence decisions or obtain benefits.

This rule applies to all relationships with clients, suppliers, public entities and other partners.

4.1 Gifts, Hospitality and Entertainment

Gifts, hospitality and entertainment are only acceptable when, simultaneously:

  • They are consistent with normal business practices and the company's ethical standards;
  • They are not intended to influence a business decision or obtain any advantage;
  • They are not given with the expectation of reciprocity;
  • They are transparent and duly recorded;
  • They do not violate any applicable law, regulation or policy;
  • Would not damage the partner's reputation if made public.

All hospitality expenses must be supported by documentation. Cash payments or equivalents (vouchers, gift cards) to public officials, as well as gifts to members of their families, are prohibited.

4.2 Facilitation Payments

Facilitation payments are prohibited — that is, payments to public officials intended to expedite routine procedures such as obtaining services or customs clearance. If an employee is confronted with such a demand, they must refuse, request formal justification and report the incident to the compliance officer.

4.3 Sponsorships and Charitable Contributions

Any sponsorship or donation requires prior management approval and must be formalised in writing, with invoice issuance and adequate documentary record. Contributions intended to influence tenders or decisions, or those occurring immediately before or after contractual negotiations, are not permitted.

5. Money Laundering

Advanced Resources complies with applicable legislation on combating money laundering and operates only with entities that carry out legitimate activities and hold funds of lawful origin. Any attempt to convert illegally obtained funds into apparently legitimate assets is not tolerated.

6. Sanctions and International Trade Regulation

Advanced Resources complies with applicable laws and regulations on exports, imports, transit and international sanctions in all countries where it operates, systematically screening parties involved in commercial transactions against applicable sanctions and embargo lists.

The company obtains all necessary licences and authorisations before importing, exporting or re-exporting goods or services. Where applicable, a record of the licence or exemption used in each transaction must be maintained so that it can be presented to the competent authorities whenever requested. Each employee involved in international transactions is responsible for knowing and complying with applicable regulatory obligations. Any suspected non-compliance must be reported immediately to the competent authorities and the affected partner.

7. Cybersecurity and System Protection

Advanced Resources maintains up-to-date controls and protection measures to ensure the confidentiality, integrity and availability of the information it processes, including partner and client information, preventing and mitigating cybersecurity threats.

Any security incident with potential impact on partner systems or data must be reported immediately. Employees may not access, use or disclose partner systems or information without express authorisation.

8. Fair Competition and Antitrust

Advanced Resources competes fairly and ethically, complying with the competition laws of the markets in which it operates. The following are prohibited:

  • Price-fixing agreements with competitors;
  • Participation in bid-rigging schemes;
  • Market or customer sharing with competitors;
  • Sharing commercially sensitive information with competitors;
  • Abuse of a dominant position.

In the context of trade or sector associations, employees must exercise caution and avoid any exchange of information that could constitute a violation of competition laws.

9. Conflicts of Interest

A conflict of interest exists when a personal or professional relationship or activity compromises, or may compromise, an employee's ability to make impartial decisions in the exercise of their duties or to act in the interests of the company and its partners.

Employees must avoid situations of real or potential conflict of interest in any business relationship. Whenever such a situation exists or may exist, it must be declared immediately to management. Examples include:

  • Providing consultancy to competitors while employed by Advanced Resources;
  • Creating a company that supplies goods or services to Advanced Resources;
  • Approving donations to organisations in which the employee has personal involvement;
  • Favouring a supplier with whom a close personal relationship is maintained in selection processes.

Failure to declare a conflict of interest may be interpreted as an attempt to improperly influence decision-making processes and may result in the termination of the employment or commercial relationship.

10. Fraud and Accuracy of Information

Advanced Resources does not tolerate fraud and maintains internal controls to prevent and detect it. Whenever a fraud situation involving partners is identified, the company notifies them immediately and cooperates with the competent authorities.

All accounting and financial reporting must comply with applicable standards. Specifically:

  • Payments to third parties are made exclusively by bank transfer, based on invoices issued under written agreements;
  • No transaction may be intentionally misclassified in relation to accounts, departments or accounting periods;
  • No information may be concealed from internal, external or independent auditors.

11. Personal Data Protection

Advanced Resources processes personal data in accordance with applicable legislation, including the General Data Protection Regulation (GDPR). Personal data means any information relating to an identified or identifiable person, such as name, address, telephone number or email address. Processing means any operation performed on personal data, including collection, recording, storage or disclosure.

Personal data of employees, clients, partners and third parties is not shared without authorisation. Each employee is responsible for keeping the information they access secure and for using it only for the purposes for which it was collected.

12. Business Partner Management and Due Diligence

Before entering into commercial relationships, Advanced Resources assesses the legitimacy, integrity and compliance history of partners and suppliers. This assessment includes:

  • Verification of the entity's legitimacy and qualifications;
  • Background checks for corruption, fraud or criminal conduct;
  • Identification of shareholders, beneficial owners and management bodies;
  • Assessment of links to clients or public officials that may represent a corruption risk.

Relationships with third parties are monitored on an ongoing basis, and contracts include anti-corruption clauses. Advanced Resources is responsible for the acts of its subcontractors and agents acting on its behalf.

13. Responsible Taxation

Advanced Resources complies with applicable tax legislation in all countries where it operates, does not use tax haven structures to minimise taxes, and discloses all necessary information to the authorities. In cases where the law allows for alternative interpretations, the company adopts prudent and well-founded positions.

14. Social Media

Employees must refrain from posting on social media or other digital channels any content — text, image, video or audio — that is false, inappropriate or harmful to the reputation of the company, its partners or clients. Non-compliance with this rule may result in the immediate removal of the content and may have disciplinary consequences.

15. Whistleblowing Channel

Advanced Resources provides internal mechanisms that allow any employee to report, confidentially and without fear of retaliation, suspected violations of the law, improper conduct or breaches of this code. This includes, in particular, any suspicion of illegal or improper payments — whether the offering, acceptance or solicitation — regardless of whether they are made by employees, partners or third parties acting on behalf of the company.

No employee will be subject to disciplinary measures for reporting, in good faith, suspected misconduct. When a report is received, the company investigates immediately, implements the necessary corrective actions and, where applicable, reviews its processes to prevent recurrence. All reports and measures taken are duly documented.

16. Training and Communication

Advanced Resources ensures that all employees are aware of this code and its requirements. To this end, it conducts periodic training sessions — in person or in e-learning format — tailored to the risk level of each role, maintaining a record with the details of each session and its participants.

Management regularly communicates with employees on the importance of complying with this code, promoting an ethical culture throughout the organisation.

17. Monitoring, Auditing and Continuous Improvement

Advanced Resources conducts regular assessments of compliance risks and monitors the effectiveness of implemented controls. Internal audits, carried out on a risk basis, verify compliance with this code and with partner requirements, with results reported to management at least once a year. The company designates a compliance officer with direct access to senior management, whose responsibility is to oversee the implementation of this code, guide employees on compliance matters, and escalate any relevant issues whenever necessary.

The compliance management system is reviewed annually by management, which analyses the status of previous actions, legislative changes, reported incidents, audit results and improvement opportunities. The company is committed to the continuous improvement of its processes and behaviours.

18. Consequences of Non-Compliance

Non-compliance with this code may have serious disciplinary consequences, including termination of the employment contract or commercial relationship. Depending on the nature of the infringement, civil or criminal liability may also arise under applicable legislation.

Any conduct contrary to this code must be reported immediately through the whistleblowing channel. Advanced Resources cooperates fully with the authorities in investigations related to serious infringements, particularly in matters of corruption, fraud or international sanctions.

19. Conclusion

Advanced Resources is committed to the continuous improvement of its processes, services and behaviours, in order to maintain the trust of clients and partners and to ensure the quality of its delivery. This commitment is exercised in a sustainable manner, with attention to the social, ethical and environmental dimensions.

This code enters into force on the date of its approval by management and supersedes all previous versions. All employees, partners and suppliers are responsible for knowing, understanding and complying with it.