Within the scope of its activity, We Are META, Lda. (META), its employees and holders of management positions and corporate bodies must be guided, among others, by the principles of diligence and transparency, legality, non-discrimination and good faith, and in compliance with a zero tolerance policy with practices of moral or sexual harassment, in order to grown and maintain the credibility and prestige of the organization, granting everyone increased responsibility with regard to their own conducts.

Now, therefore, considering:

• Undesirable behaviour which affects the dignity of women and men at work on the part of managers, members of management, employees with duties of responsibility/coordination and any other employee;
• Such behaviour may be explicitly or implicitly used as the basis for decisions affecting the employee’s access to professional training, continued employment and any other work-related decisions;
• Such behaviour is likely to create an intimidating, hostile or humiliating atmosphere for the targeted person;
• The purpose for preventing harassment at work and, if it occurs, the need to ensure the application of appropriate measures to punish and prevent its recurrence;
• The provisions of article 127(1)(k) of the Portuguese Labor Code, particularly, those that state that the employer must “adopt codes of good conduct for preventing and combating harassment at work, whenever the company has seven or more employees”;
• META’s public commitment to upholding the values of non-discrimination and combating harassment in the workplace.

This Code of Good Conduct for Preventing and Combating Discrimination and Harassment at Work (henceforth the “Code”) is hereby entered into, and will be used and considered the privileged instrument in resolving ethical issues, ensuring META’s compliance with the legal practices to which it is obligated.

 1. This Code establishes a set of principles, guidelines and procedures that must be observed in the performance of META’s activities and serves as regulatory instrument and expression of a policy to disclose, identify, combat and punish situations and behaviours that may represents harassment in the workplace.

2. This Code applies to all META’s employees, holders of management positions and corporate bodies, regardless of their employment relationship, as well as to all collaborators without an employment relationship with META.

1. META’s holds a policy to condemn and not condone to any form of harassment, and to prohibit acts of harassment inside or outside the workplace for work-related reasons, including discriminatory behaviour toward others or third parties based on race, gender, age, disability, sexual orientation, opinions, political ideology or religion.

2. In the performance of their duties, functions and responsibilities, all META’s employees and collaborators must act in compliance with the principles of non-discrimination and combating harassment in the workplace, and all relationships must be based on loyalty, integrity and mutual respect.

3. All those covered by this Code must, in their interpersonal conduct, promote a respectful and healthy working relationship, adopting in particular the following practices.

a) Foster respect, availability to others, sharing of information, and team spirit;

b) Act with courtesy, common sense and self-control when dealing with all situations that arise in a professional context;

4. All reports of situations that may constitute harassment will be treated seriously, confidentially, promptly and with urgent proceedings.

5. Those involved in harassment investigations shall be treated equally, regardless of career, category, organizational unit, and hierarchical position within META’s organizational structure.

6. Those involved in harassment investigations shall be treated equally, regardless of career, category, organizational unit, and hierarchical position within META’s organizational structure.

7. This Code applies to all relationships established within the scope of META’s activity, whether these take place during or outsider working hours, in its offices or other locations, in person or through information and communication Technologies.

1. “Harassment” means the practice of undesirable behaviour, namely any behaviour based on discriminatory factors, whether in job access procedures or during the performance of the job itself, with the purpose or effect of disturbing or embarrassing a person, affecting their dignity, or creating an intimidating, hostile, degrading, humiliating or destabilizing atmosphere.

2. “Moral harassment” means any unwanted behaviour perceived as abusive, practiced persistently and repeatedly, that may take form of verbal or non-verbal attacks with offensive or humiliating contents, or any act that may including psychological or physical violence, with the purpose or effect referred to in the previous number.

3. “Sexual harassment” means any unwanted behaviour of sexual nature, whether verbal, non-verbal or physical, with the purpose or effect referred to in number 1 of this article.

4. “Unwanted behaviour” means any gesture, word, or act, including sexual invitations, messages, unsolicited phone calls and attempts at physical contacts.

5. “Labor dispute” means any behaviour or attitude that, regardless of the discomfort it may cause or the infraction it may represent (disciplinary, criminal or labor), is practiced without the intention or effect of affecting the dignity of a person or creating an intimidating, hostile, degrading or humiliating atmosphere.

1. Harassment may be considered:

• Vertical downward, when perpetrated by a superior against a subordinate;
• Vertical upward, when perpetrated by a subordinate against a superior;
• Horizontal, when perpetrated between employees at the same level;
• Other, when perpetrated by or against third parties.

2. Victim means any person referred to within the scope of this Code, regardless of their hierarchical relationship with the harasser, as well as third parties who are the recipients of an act of harassment.

1. Any person who considers having been a victim of harassment at work can report such situation in writing to their immediate superior, the next highest supervisor, or directly to META’s Management.

2. The aforementioned report may also be sent to the following email address: whistleblowing@wearemeta.io

3. Reports may also be filed through the Working Conditions Authority’s (Portuguese Autoridade para as Condições no Trabalho) dedicated channels.

4. Any person that becomes aware of acts that may be considered workplace harassment has a duty to report such acts to any higher supervisor, directly to META’s Management, or through the email address mentioned in number 2 of this article.

5. All reports must contain a description of the facts that may be considered workplace harassment, including circumstances, time and place, victim’s and perpetrator’s identities, as well as any evidence available.

6. Verbal reports or complaints shall always be written as soon as possible.

7. When it is concluded that the report is unfounded or intentionally filed with the purpose of harming a person, contains false statements or defamatory material, particularly when the report itself constitutes harassment, META will initiate the appropriate disciplinary procedures, without prejudice to any imposing legal procedures.

1. After investigating the reported facts, META will open a disciplinary proceeding, in accordance with the Portuguese Labor Code, whenever it concludes that the reported situation involves acts or behaviours that are considered harassment in the workplace.

2. Harassment in the workplace is also a very serious offense as provided for in article 29 (5) of the Portuguese Labor Code, without prejudice to any criminal liability provided for by law, at may originate the corresponding procedures by the competent authorities.

3. The confirmation of a harassment in the workplace act grants the victim the right to compensation for material and moral damages, in accordance with the provisions of Article 28 of the Portuguese Labor Code.

4. When acts or behaviours that may be considered harassment in the workplace are perpetrated by providers or suppliers of goods or services, or employees of companies providing or supplying goods or services, META shall initiate an investigation process aimed at determining the facts, and the contracts may be terminated on the basis of just cause for breach of the non-tolerance for harassment commitment assumed by META.

1. A specific protection regime for victims, whistleblowers and witnesses is granted in procedures related to harassment in the workplace situations, and their confidentiality must be ensured until the accusation is filed.

2. META’s employees and managers may not disclose or make public information regarding harassment in the workplace procedures obtained in the performance of their duties or by virtue of such duties, even after termination, unless such information has already been authorized or made public, in accordance with the law.

3. All procedures initiated after a report of a harassment in the workplace situation must be promptly concluded.

4. Whistleblowers and witnesses, whether or not named by the victim, cannot be subject to disciplinary action unless they act intentionally, based on statements or facts contained in records of judicial or administrative procedures involving harassment in the workplace until a final, unappealable decision is made, without prejudice to the exercise of the right of to be heard.

5. Retaliation against victims, whistleblowers or witnesses constitutes a serious violation of this Code and will be subject to disciplinary actions.

1. This Code will be made public via institutional email and will be available on META’s intranet and website

2. This Code must be disclosed to those who begin their duties at META.

3. This Code will be reviewed whenever necessary.

4. This Code shall come into effect upon approval on the date of its publication.

This Code is written in Portuguese and English and, in case of any discrepancy or conflict, the Portuguese version shall prevail over the English version.