Corruption Prevention Policy

We believe that principles and behaviour embody the values and establish the guide for the organisation’s actions, strengthening its reason for existing. We believe that the way we work, how we develop and relate to each other dictates who we are and the Culture lived in an organisation.

In line with these ideals, and in compliance with Decree-Law 109E/2021, of 9 December (“Regime Geral de Prevenção da Corrupção” or “RGPC”), iBET has drawn up a programme of regulatory compliance aimed at preventing, detecting and penalising acts of Corruption and Related Infringements, carried out against or through it, which consists of the following elements:

1. A Policy for the Prevention of Corruption and Related infractions (“Anti-Corruption Policy” or “Policy”);
2. A code of conduct (“iBET’s Code of Ethics and Conduct”)
3. A whistleblowing channel and respective Whistleblowing Regulations
4. A training programme.

1.1 This Policy establishes the set of principles, values and rules of action, transversal to all its activities, in matters of professional ethics and prevention of Corruption and Related Infractions, as set forth in the RGPC, which should be read together with the iBET Code of Ethics and Conduct and the Whistleblowing Regulations, both available at www.ibet.pt.

1.2 For the purpose of this Policy, the following terms and expressions shall have the meaning indicated below, when they start with a capital letter, in the singular or plural:

• iBET’s Code of Ethics and Conduct: a set of principles that govern the activity of iBET and a set of rules of an ethical and deontological nature to be observed by the members of the governing bodies and all employees in their relations with customers, suppliers and other stakeholders. It is also aimed at third parties contracted by or acting on behalf of iBET in cases where it may be held responsible for their actions.
• Employees: all employees of iBET, regardless of the nature of their contractual relationship, including its governing bodies.
• Corruption and Related Infractions: corresponds to the crimes of corruption, receiving and offering an undue advantage, embezzlement, economic participation in business, extortion, abuse of power, prevarication, influence peddling, money laundering or fraud in obtaining or diverting a subsidy, grant or credit, as set out in the Penal Code, approved as an annex to Decree-Law No. 48/95, of 15 March 1995. No. 48/95, of 15 March, as amended, Law No. 34/87, of 16 July, as amended, the Military Code of Justice, approved annexed to Law No. 100/2003, of 15 November, Law No. 50/2007, of 31 August, as amended, Law No. 20/2008, of 21 April, as amended, and Decree-Law No. 28/84, of 20 January, as amended. The version thereof in force at any given moment is also included, as well as other diplomas that in the future may regulate matters that, due to their nature, should be considered included herein.
• Partners: the agents, external auditors, clients, suppliers and other people that provide services to iBET, in any capacity, on a permanent or occasional basis.
• Conflict of interest: any situation in which employees’ personal interests are potentially contrary to iBET’s interests.

1.3 This policy covers the practices that, under the terms of the law, concern private entities and all employees, as well as, with the respective adaptations, all those who represent iBET and all its partners.

2.1 The Regulatory Compliance Officer (“RCN”), appointed by iBET’s Executive Committee, shall monitor and control the execution of the Regulatory Compliance Programme, without prejudice to the powers legally conferred to other iBET bodies or Employees.

2.2 The RCN shall exercise its functions with independence and decision-making autonomy, having access to internal information and to technical and human resources necessary for the exercise of its functions.

2.3 The RCN shall provide all necessary clarifications on the application of the Anti-corruption Policy and shall promote regular internal audits to assess compliance with it.

3.1 iBET repudiates any practice of corruption, bribery or related infractions, whether active or passive, and other forms of undue influence or illicit conduct, imposing strict compliance with these principles in all its internal and external relations, whether with private or public entities.

3.2 All employees shall comply with applicable national and international rules against corruption and related infractions, and any behaviour which may constitute a crime of corruption or any related infractions under the law is expressly forbidden.  In particular, it is expressly forbidden for all employees to

• Accept any advantages or gifts in exchange for preferential treatment from any third party, to influence an action or decision.
• To offer or accept, under any circumstances and regardless of value, cash, cheques, or other legally restricted goods.
• Influence the decisions of business partners in any way that is illegal or appears to contravene applicable regulations.
• Obtain any benefit or advantage for the company, for the Employee or for third parties, through unethical practices or contrary to the duties of the position, namely through corrupt practices, undue receipt of advantage or influence peddling.
• iBET’s employees may not do business on their own account or in competition with it, in which case there will be a Conflict of Interest, and they may not obtain personal benefits, advantages or favors by virtue of the position held or duties performed.

3.3 In the course of IBET’s activities, there may be frequent interactions with public and administrative officials, government agents and other public bodies, and such interactions must be guided by the utmost rectitude, transparency and strict compliance with all legal rules and applicable ethical duties, as well as with the provisions of this Policy.

3.4 For the purposes of this Policy, and without prejudice to the provisions of the Code of Ethics and Conduct with regard to Gifts and Commercial Offers, only offers that conform to socially appropriate conduct and to customary practices may be made. A benefit is considered socially acceptable if it is offered as a sign of politeness and good manners, in accordance with local custom and practice, to the extent that such benefit is related to professional activity and is not intended or intended to persuade or obtain preferential treatment or an illegitimate advantage from the recipient or to improperly influence his or her behavior.

It is absolutely prohibited to make political donations or contributions, in cash or in kind, under any circumstances, on behalf of and/or in the name of iBET or in a manner that appears to be made on its behalf or in its name, to political parties, candidates for political office or organizations or individuals to those members whose mission is essentially political.

To ensure that third parties contracted by iBET comply with this Policy and the existing legislation on the prevention of corruption and related infractions, iBET has defined a set of principles and rules that, without prejudice to the application of legal standards or any other applicable internal rules, must be observed in the contracting processes, namely:

5.1 The contracting of third parties occurs based on a legitimate need for the goods or services to be acquired.

5.2 The choice of potential suppliers is based on objective, clear and impartial criteria, and made public in a transparent way.

5.3 The choice of potential suppliers is preceded by an analysis of the level of exposure to the risk of corruption

5.4 The conditions accepted by iBET (including price and payment conditions) are in line with market practices (unless justified by a legitimate reason).

5.5 The contracted third parties accept IBET’s Anti-Corruption Policy.

6.1 Failure to comply with the rules set out in this Policy by any Employee will be considered a serious offence, which, depending on the degree of fault of the offender and the seriousness of the offence, may lead to the application of the following disciplinary sanctions

• Unrecorded reprimand.
• Registered reprimand.
• Financial penalty.
• Suspension from work with loss of pay and seniority.
• Dismissal with just cause.

6.2 Failure to comply with the rules set out in this policy by partners and other third parties may constitute grounds for the application of penalties and/or termination of the contract, in an appropriate and proportional manner.

6.3 Failure to comply with the rules of the policy may also lead to administrative or civil liability of offenders, and also, depending on the seriousness of the offence and the culpability of the offender, give rise to sanctions under Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law.

6.4 The crimes of Corruption and Related Infractions referred to in this Policy are punishable, depending on the legal framework, with fines and with prison sentences.

6.5 The RCN shall be responsible for preparing a report for each offence committed, which shall contain the identification of the rules violated, the sanction applied, and the measures adopted or to be adopted by iBET under its internal control system.

7.1 iBET has an Internal Whistleblowing Channel and follows up on reports of acts of corruption and related infractions under the provisions of the legislation transposing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law.

7.2 The receipt and forwarding of complaints follow the procedure applicable to complaints set out in the Infringement Reporting Procedure.

8.1 iBET provides periodic internal training on the content of this Policy to all employees, with a view to ensuring that they are aware of and understand all the rules and procedures relating to the prevention of corruption and related infractions.

8.2 The training provided shall be adapted to the functions performed by the Employees in question, considering the various degrees of exposure to the risks identified.

9.1 This Policy takes effect on the date of its approval by iBET’s Executive Committee and must be reviewed every 3 (three) years and whenever there are any changes, namely in iBET’s organic or corporate structure, which justify its revision.

9.2 This Policy is disclosed in its most current version to its employees and is available for consultation on the official website (www.ibet.pt).

Approved at the Executive Committee meeting of 13 September 2022.