INTRODUCTION
WHAT IS OUR CODE OF CONDUCT?
Our Code of Conduct regulates and promotes the fundamental aspects of ethical behavior that the LMSI Board of Directors believes should be adopted across all our businesses and activities.
WHY IMPLEMENT A CODE OF CONDUCT?
To ensure that business ethics and integrity are evident in our relationships with employees, clients, suppliers, partners, and society, as well as in the way we operate in different markets.
WHO DOES OUR CODE OF CONDUCT APPLY TO?
Our Code of Conduct must be adhered to by all employees, service providers, and anyone representing LMSI in their interactions with clients, suppliers, partners, and any other entities with professional relationships with the company.
All employees and members of the company’s governing bodies are responsible for complying with and enforcing the provisions of this Code. Area managers have the additional responsibility of promoting and ensuring compliance within their respective teams.
Any doubts regarding the Code of Conduct or how to handle situations not explicitly addressed in the Code should be clarified with the Human Resources Department.
HOW TO IMPLEMENT OUR ETHICAL PRINCIPLES?
INTEGRITY IN RELATIONSHIPS
PROPER CONDUCT
CONFIDENTIALITY
Ensure the confidentiality of all information related to LMSI clients and suppliers, limiting its use to agreed-upon and legally permitted purposes.
Protect contractual and transactional documents related to client and supplier negotiations.
Comply with legal requirements regarding data protection.
TRANSPARENCY
Provide timely, accurate, and clear information about our operations.
Act professionally and responsibly to ensure the proper functioning of LMSI processes and information systems.
Promote competition among a diverse range of goods and services providers that meet LMSI’s requirements and standards.
Respect different cultures and business practices.
RECRUITMENT AND SELECTION
Treat each individual fairly and recruit, select, train, and remunerate based on merit, experience, and other professional criteria.
We are committed to ensuring that the human resources, talents, and skills available within the community are considered when employment opportunities arise, selecting the most suitable candidate for the position based on their qualifications and experience.
PROFESSIONAL TRAINING
Provide the most appropriate training to all employees.
Encourage employees to identify their own training needs.
Identify training needs for LMSI employees.
WORKPLACE SAFETY AND HEALTH
Offer all employees a pleasant working environment that is safe and free from work-related risks.
At LMSI, the protection of lives, people, and property is a priority. We provide the necessary resources and adopt industry-leading practices in occupational health and safety (OHS).
MANAGEMENT STYLE
Promote team spirit as a way to create value.
Encourage individual creativity.
Foster responsible decision-making while accepting the possibility of mistakes.
Promote a meritocratic culture.
PERSONAL AND PROFESSIONAL DEVELOPMENT
View the personal and professional development of all employees as a key objective for LMSI.
Conduct periodic evaluation processes that are objective and rigorous.
POLITICAL NEUTRALITY
Conduct business activities without engaging in, interfering with, conditioning, or influencing the diversity of political views within the various communities where LMSI operates.
Maintain independence from political authorities and political parties while fostering good professional relationships with local and national political entities.
RESPECT FOR THE ENVIRONMENT
Implement an environmental policy based on sustainable development and respect for the environment.
Promote and encourage the adoption of good environmental practices.
FIGHT AGAINST BRIBERY AND CORRUPTION
It is strictly prohibited to offer or accept any type of reward or benefit with the intent to influence someone’s behavior to gain commercial advantages.
CONSISTENT EXTERNAL COMMUNICATION
Adhere to established guidelines whenever participating in activities (e.g., interviews, communications, publication of articles) involving the dissemination of information related to LMSI.
Communicate information clearly and accurately, including any descriptions of our products and services.
ENGAGEMENT AND COMMITMENT TO THE COMMUNITY
Actively participate in community events or collaborate with the community, strengthening and implementing our Corporate Social Responsibility Policy.
Protect the reputation and brand of LMSI by avoiding any actions that could harm them.
Ensure transparency in all our operations and activities.
Present data, results, and records accurately.
Use LMSI assets and resources appropriately.
PERSONAL INTEGRITY
PROPER CONDUCT
Stay well-informed at all times.
Adopt a transparent attitude and attempt to anticipate situations that may result in conflicts of interest (e.g., between an employee and the company). If such a situation arises, the respective Team Leader must be informed immediately.
Ensure that all information and documentation is archived promptly and properly, and that reports are prepared according to agreed standards of accuracy and detail.
Respect the dignity of every individual.
IMPROPER CONDUCT
CONDUCT UNDER PRESSURE
LMSI’s ethical principles must always be respected, regardless of any internal or external pressures.
TERMINATION OF EMPLOYMENT WITH LMSI
Do not use any information obtained during your employment with LMSI.
All work developed for LMSI, including products, services, and related materials, remains the property of the company after the termination of the employment relationship.
ACCEPTANCE OF GIFTS AND OTHER BENEFITS
Do not accept any personal or economic benefits valued individually at more than €100 (including Christmas gifts) from any client, supplier, service provider, or any other individual or entity that has or intends to establish a commercial relationship with LMSI.
It is prohibited to request gifts from suppliers, clients, or third parties with whom LMSI has, or is in the process of establishing, commercial relationships.
It is prohibited to accept or offer, under any circumstances and regardless of their value: money, personal checks, or any other goods subject to legal restrictions.
All gifts valued over €100 that, for any reason, cannot be refused will become the property of LMSI. These items must be delivered to the Human Resources Department, which will donate them.
Any questions related to the above points should be directed to the Board of Directors through the Business Manager | Operations Manager.
POLITICAL ACTIVITY
Do not use work time, equipment, or the name of LMSI for activities related to political parties.
MARKET INTEGRITY
PROPER CONDUCT
FREE COMPETITION
Act ethically in all the countries where we operate, complying with the rules and laws that promote and protect free competition, and encourage the same behavior in these markets.
Provide market information transparently.
IMPROPER CONDUCT
CONFLICTS OF INTEREST
Employees must report in writing to LMSI, through their Team Leaders, any situations where a conflict of interest exists or may exist.
PRIVILEGED INFORMATION
Protect and control the use of all non-public information that, if made public, could harm LMSI’s activities.
FINANCIAL INTEGRITY
PROPER CONDUCT
Maintain and provide complete and accurate data, records, and reports.
Protect LMSI’s assets.
Implement security procedures.
Maintain professional confidentiality.
IMPROPER CONDUCT
Any abusive use of privileged or confidential information.
HUMAN AND LABOR RIGHTS
At LMSI, any form of harassment is strictly prohibited, especially moral and sexual harassment, involving any verbal or physical conduct that humiliates, coerces, threatens employees of the company, suppliers, or partners, or creates a hostile work environment that unjustifiably interferes with individual performance or affects working conditions.
LMSI does not practice or support any form of discrimination, based on criteria such as race, gender, disability, sexual orientation, political or ideological beliefs, religion, education, marital status, or any other factor. All employees adhere to the company’s ethical and deontological principles, and their behavior is guided by tolerance, respect, and courtesy.
At LMSI, all employees are treated with fairness, respect, and dignity.
LMSI conducts its activities in accordance with principles of fairness, impartiality, and neutrality, prohibiting arbitrary practices, decisions, or behaviors that lead to illegitimate benefits or harm, consistent with our sense of fairness and equal opportunities. Employees, in their dealings with third parties, must act without favoritism or prejudice, ensuring that identical situations are treated equally.
Merit is rewarded at LMSI, not race, color, nationality, religion, sex, age, sexual orientation, gender identity, marital status, disability, or any other factor.
Employees are free to associate with any class entity, such as trade unions or other legitimate negotiation bodies. LMSI does not discriminate against workers due to their union memberships or union activities and strictly prohibits discrimination by other company employees.
Any form of protectionism or privilege in the relationship between leaders and subordinates is unacceptable. Employee privacy and confidentiality are respected by all. LMSI has a Data Protection Policy implemented, as outlined in the employment contracts of all employees.
At LMSI Child labor is strictly prohibited. Only employees over 18 years of age and who have completed the compulsory education are admitted. No minors, regardless of the tasks assigned, are allowed. We do not support the use of child labor by our suppliers or subcontractors. Forced labor is not tolerated under any circumstances, including corporal punishment, physical or mental coercion, verbal abuse, withholding of documents, or requiring the payment of fees to use work instruments. No employee is forced to work at LMSI, and employees are free to resign in full compliance with labor laws established in the Labor Code. Employees are not required to make any financial deposit to use uniforms or other work-related equipment. It is the responsibility of LMSI to supply all necessary work equipment to employees.
LMSI only works with recognized recruitment agencies. All recruitment processes are paid for by the company to the recruitment agency. Candidates are not required to pay any fee to the recruitment agency, and they are informed of this. Should a payment be demanded and the company becomes aware of it, LMSI will immediately cease cooperation with that agency and report it to the Ministry of Labor. LMSI does not support the use of forced labor by its suppliers or subcontractors.
Employees are required to report any violations of the above-mentioned standards. LMSI is committed not to retaliate against anyone who reports harassment, breaches of conduct, or cooperates in the investigation of such reports.
At LMSI, communication with employees is informal and open. This approach is considered essential to maintaining an effective professional relationship.
COMPLIANCE CHECKLIST
Before making a decision or following a directive, ask yourself the following questions:
- Is my action in line with the spirit and legal aspects of the LMSI policy?
- Is my conduct consistent with LMSI’s ethical and professional standards?
- Does my decision reflect the “right attitude”?
- Is my decision based on a responsible and sensible professional opinion?
- Would I feel comfortable explaining my decision, even if it were in public?
WERE TO GET HELPH
If you have any doubts or questions, you can seek clarification from your Team Leader or the Human Resources Department.
Final Note:
Any situation not covered by this Code that may also violate its principles should be disclosed and reported to your Team Leader, who will forward the matter to the LMSI Human Resources Department for review and assessment.
OUR COMMITMENT
LMSI is committed to supervising the effective implementation and application of the principles outlined in this Code of Conduct, as well as reviewing and updating its content and formulating additional guidelines based on the results achieved and the experience gained.
Lisbon, 19 October 2022
CEO,
Pedro Malheiro