The Super Bock Group is a century-old group that has been building, throughout its history, a solid identity that we are very proud of and that positions us as a reference of integrity and excellence.
The identity of the Super Bock Group does not stem from any communication campaign nor does it come from a plan of intentions about what we would like to be. Our identity is based on the values and principles that are in the genesis of the commitments we have made. Those are the values and principles that, before being affirmed and disclosed, already existed in our daily basis work, in our relationship with co-workers and in the relationship we establish with our partners, with our clients and with the community.
It is this identity that leads us to affirm that our corporate ambition cannot affect our commitment to integrity, since the values and principles that guide our activity are part of our genetic heritage.
This document should be seen not only as a guide to our activity and actions, but also as an instrument of inspiration, since our ethical positioning cannot be left in second plan.
But it is not enough to feel, we must express and share with everyone, in a clear and unequivocal way, our values and principles, which we adopt and practice in our daily lives, in everything we do and in all the professional relationships we establish.
We owe the Super Bock Group our serious commitment to the values and principles reflected here.

This is the commitment I expect from you!

The Code of Ethics is the document that embodies the values, principles and norms of ethical and deontological nature to be observed and respected by all those who are part of the Super Bock Group and who relate to it daily.
It is the starting point of the policies, standards and procedures developed and applied in the Super Bock Group, thus ensuring the Company’s ethical positioning in everything that is done and in the way it is done.

WHY A CODE OF ETHICS?
To answer this question it is necessary to clarify a previous question: “What is business ethics?”. The simple answer translates into the application of values such as integrity, justice and respect in business behavior.
It relates to how we act and how we apply our individual rules.
It is about doing what is right, even when no one is watching us.
The Code serves as a guideline so that everyone knows how to manage the ethical dilemmas that may arise in the daily work and that can divert us from achieving the goals. All Employees who, within the scope of their duties lead teams, should assume responsibility for the application of the principles set forth herein.
No document can anticipate and address all situations that may arise, mainly because many of the ethical dilemmas occur in “areas of dubious interpretation” where the answer is neither obvious nor immediate.

IN THIS CONTEXT, THE CODE OF ETHICS OF THE SUPER BOCK GROUP WAS CREATED WITH THE FOLLOWING GOALS:

1. To affirm the identity and ethical positioning of the Super Bock Group, by sharing and disseminating the principles that guide our activity, in accordance with the mission, vision and values assumed in the sustainable development commitment made to the shareholders, employees, suppliers, customers, other partners and community;
2. To promote and foster the adoption of the principles and the rules of conduct defined in this Code;
3. Constitute a tool to help address any issues or dilemmas that may arise, related to how we work;
4. To consolidate the institutional image of the Super Bock Group, which should be characterized by the excellence and sustainability of the production, dissemination and commercialization practices; by the quality of our products; by innovation; by merit, competence and integrity of its people; by supporting the community and respecting the environment.

SCOPE OF APPLICATION
The Code of Ethics applies to all members of the Super Bock Group’s corporate bodies and employees, as well as to all those who represent the Company near our customers, suppliers, partners and other stakeholders.
In this context, to ensure the fulfillment of this Code’s goals and to allow a general knowledge of the values, principles and guidelines established in it, this code was published on the institutional website and on the Intranet page, and regular disclosure to all the mentioned Stakeholders will be promoted.
Whilst formalizing work contracts or service provision contracts, a copy of this document will be delivered, respectively, to the Employee or Partner and requested the signature of a declaration that will attest to the receipt of the Code and the individual commitment towards its fulfillment.

Any questions that may arise regarding the consultation and application of the Code of Ethics should be sent to the e-mail address: etica@superbockgroup.com.

We have an infinite passion. We are proud of our legacy, our brands and of what we build up day after day. We overcome ourselves. We mobilize people and funds to make the impossible happen. We are resilient. We resist and improve. We learn from mistakes and crises. We are ambitious. We know where we want to be. We are courageous – frustration does not stop us. We are vertical. We stand strong on unbreakable values and principles. We are committed. We strive for our mission and we never abandon the ship. We pursue excellence. We are responsible and we always do our best. We surpass ourselves daily to exceed the expectations of our clients and consumers. We are partners. We team up with those who add value to go further together. Our anchor is trust. We build strong teams that work together, promoting synergies. We are joyful. We are glad to work here. We celebrate who we are and what we do. We inspire. We grow and learn with the community that we challenge and support. We dare. Let us roam towards unknown oceans and take the wheel of our future.

Because we are authentic, we make our world more authentic!

Our Mission is to be a company with beer-making credentials, passionately dedicated to producing beverages and developing brands that are excellent and appreciated by all; to constantly innovate in order to engage and surprise clients and consumers; to focus on the growth and enhancement of our people and our brands, the Company’s greatest assets; and to generate a positive impact, in the medium and long term, in society, contributing to sustainable development, garnering the appropriate recognition and appreciation by the community and the shareholders.

We want to affirm Super Bock’s international presence as a relevant brand within the top priority countries of the 3 continents we operate in; we want to consolidate our leadership position in the Portuguese market, namely in beer, sparkling water and cider categories; we want to reinforce our dimension through brand and new businesses development.

We want to affirm our vision: “Local Passion Global Ambition”. For this, we revisited our values:

• As a Company
  We are the largest refreshing beverages Group in Portugal. Our strategy for leadership is based on a continued investment in Creativity and Innovation and Development (R&D), a circumstance that demonstrates that dissatisfaction and endless search for what is new are part of our identity. Our goal is achieving excellence, constantly challenging ourselves.We value honesty, transparency and passion, as this is the only way to build strong and long-lasting relationships with our consumers, customers, shareholders and business partners, based on trust and mutual benefit.We act with integrity: we respect the laws of the countries where we are present and adhere to good business management practices.

  We respect all entities within our professional sphere, including the competition.

  It is in our interest to work in an industry where business practices are very transparent.

  We follow the highest standards relating accounting and company management supervision, to ensure the integrity of financial statements, to ensure the effectiveness of the internal control system and risk management.

  We guarantee remuneration and value to our shareholders by using, in a more effective and sustainable way, the resources and assets of the company.

• As an Employer
  In the Super Bock Group the most important are the People. They are our greatest asset. People who work in tune with the values of the Super Bock Group and who incorporate them into the daily activity of the Company and who are committed by the same vision, mission and ambition.
  We want to make sure that the Super Bock Group is a great place to work.We want to ensure that our employees are entitled to:
  • to a safe and healthy working environment;
  • to an environment in which talent and merit are recognized;
  • the promotion of personal and professional development;
  • respect for diversity and respect for privacy; and
  • the consideration of the balance between professional and personal life

   

  Since People are the key to the development of the Group, we have adopted, as a strategic focus, the promotion of good team performance and the attraction and retention of employees who, by their abilities, attitudes and behaviors, are an added value and a competitive factor.
  We encourage an atmosphere of openness, courage, generosity and respect, so that all our Employees feel free to make their contribution by asking questions, sharing concerns and presenting ideas.

• With our Suppliers
  Choosing suppliers based on clear and unbiased criteria is our starting point. The path to follow is simple and beneficial for both parties.Treat suppliers with respect, honor our commitments and ensure that suppliers meet the ethical, environmental and social standards set forth in this Code.Implement solutions that generate competitiveness and sustainability for both sides.

  Optimize operational efficiency in the supply and distribution chain, while ensuring quality standards and compliance with ethical principles by suppliers and customers.

  Have a supply chain that guarantees the quality of the products of the Super Bock Group and is recognized in its principles and values, becoming the first choice of our business partners.

  Develop and strengthen partnerships with our suppliers.

• Relationship with our Clients
  Our Clients are the closest link between our products and our consumers. Our goal as Super Bock Group is to serve them with the highest quality, creating valuable partnerships.Treat our Customers with professionalism, dignity and respect.Offer excellent products and services.

  Provide the needed information to allow informed decision-making and ensure the strict compliance with the agreed conditions.

  Respect our Clients’ information privacy, complying with legislation.

• Regarding our Consumers
  At Super Bock Group we place the consumer and the customer at the center of our attention and action, seeking their recognition and preference at all times.Provide the consumer with all the necessary and truthful information for a conscious choice of our products.Offer innovative solutions that meet their preferences and needs.

  Respect our Consumers’ information privacy, complying with legislation.

• Protection of the Environment
  Managing the resources essential to our activity, so as to meet the needs of the current generation without limiting or compromising future generations, is our focus on environmental management.Promote integrated pollution prevention and control.Encourage the eco-efficiency of processes and products by promoting the sustainable use of water, the rational use of energy and ensuring the use of environmental criteria in the selection of raw materials and packaging.

  Minimize environmental impacts, promoting the reduction of emissions to air and water and the generated waste and favoring reuse and recovery solutions.

• Interaction with our Community
  Education and Creativity are the key words of our effort to support all those around us. We believe that there is no success without knowledge and that “creativity + companies” is the right formula to ensure its development.Support the development of local communities.Promote a strong link with local communities, supporting causes, institutions and social projects, within the framework of our social responsibility policy.

  Develop partnerships with educational institutions with the aim of promoting education and entrepreneurship among the younger generation.
  Develop partnerships with higher education institutions with the aim of stimulating applied research.

  Develop partnerships and stimulate initiatives around the Creative Industries sector, to promote entrepreneurship and the creative economy.

  Involve Employees in social responsibility actions and encourage the practice of corporate volunteering.

• As an Employer
  1. Respect for Employees and promotion of their Talent
     People are at the center of our activity.
     All employees must work in a professional and loyal manner, fostering a culture of respect, trust and solidarity.
     We must listen and acknowledge the ideas and contributions of others. Teamwork should be encouraged and successes shared.
     We must listen and share information.
     The Super Bock Group should not strain efforts when it comes to investing in the qualification and training of its people. On the contrary, it must attract and enhance their employees talent.
  2. Health, Safety and Security
     Everyone has the right to a healthy, safe and secure working environment.
     Super Bock Group standards for occupational health and safety, including the use of Personal Protective Equipment (PPE), must be respected.
     An employee should always alert if they witness a behavior or a situation that could compromise security
  3. Harassment and Abusive Behaviors
     No form of harassment or abusive behavior should be practiced, and any kind of physical and / or moral coercion is rejected and disapproved.
     Any form of sexual harassment is unacceptable.
  4. Data Protection
     If, because of the Super Bock Group’s role, an Employee has access to or is involved in the processing of personal data, it must comply with all legal provisions regarding the protection of personal data.
  5. Corruption and Bribery
     Personal payments, commissions, and bribes between the Super Bock Group and customers, suppliers, or government employees should not be accepted.
     No gifts or other gratuities are allowed that could be considered as an attempt to influence to obtain an illegitimate advantage.
     Employees of the Super Bock Group undertake to respect, in their relationship with employees and persons in charge of public entities, the duties of exemption to which they are subject, refraining from giving or promising to give any type of benefit that is not due.
     The Super Bock Group does not authorize or accept payments from third parties that may involve the attribution of bribes, unjustified favors and advantages, undue bonuses, gifts and / or payments, whether financial or otherwise.
  6. Competition
     The Super Bock Group undertakes to comply with competition laws, including the prohibition of restrictive practices, in accordance with the Compliance Manual.
     Employees of the Super Bock Group undertake to respect competitors and their representatives by avoiding any situations likely to constitute or seem an unlawful competitive bidding, and in particular not to negotiate or enter into price, market or customer sharing agreements.
  7. Compliance with legislation
     The Super Bock Group undertakes to act in full compliance with the laws and regulations in force and to provide the authorities with all cooperation within its possibilities.
• As to its Employees
  1. Legality
     Super Bock Group Employees must act according to the law, as well as to the instructions and internal guidelines.
  2. Justice and impartiality
     In the performance of their duties, Super Bock Group Employees shall treat in a fair and impartial manner all other employees and third parties, namely customers and suppliers, not being influenced by any personal interest or external pressure.
     They must also refrain from participating in activities or establishing relationships that may compromise the impartiality of their performance.
  3. Equality
     Employees of the Super Bock Group cannot discriminate in any way, especially based on race, gender, age, sexual orientation, disability, political opinions or religious beliefs.
  4. Collaboration and Good Faith
     In the exercise of their activities, the Super Bock Group employees must act with care and a spirit of cooperation and responsibility, in view of proper performance of their assigned duties and the adequate pursuit of the legitimate interests of the Super Bock Group.
  5. Loyalty
     For Super Bock Group employees, the concept of loyalty implies not only the proper performance of the tasks entrusted to them by their superiors and the respect for instructions and guidelines received by the appropriate channels, but also the transparency and ability to dialogue with their colleagues and superiors and with third parties with which they interact within the scope or their functions.
     The Employees must provide all the information they possess or comes to their knowledge that may be relevant for the activity pursued by other employees, or for the pursuit and protection of the legitimate interests of the Super Bock Group.
     Failure to disclose to superiors or colleagues the necessary or relevant information that may affect the normal pursuit of the Super Bock Group’s activity, in particular for obtaining personal or for third parties advantages, as well as providing false, inaccurate information or exaggerated and refusal to cooperate with other colleagues or hierarchical superiors will be considered a behavior that violates the principle of loyalty and cooperation.
  6. Integrity
     Employees must act with integrity, personal honesty and professional respect and respect for others, not performing any act that may, in any way, harm other employees, third parties with whom they are related due to their functions or, that may undermine the legitimate interests of the Super Bock Group.
  7. Independence
     Employees, in all contacts with the exterior, must act in accordance with the principle of independence, namely, not receiving or requesting instructions or guidance from any entity or organization outside the Super Bock Group.
     Compliance with this standard implies the rejection of offers, invitations and/ or payments or other benefits that may influence due to their value, frequency or exclusiveness, that may influence or may be interpreted as a way of influencing the work of the employee, their impartiality and independence, or impair the trust placed in them by the Super Bock Group.
  8. Use of company resources
     The resources of the company, be the work tools or products and services provided by the Super Bock Group, are designed to help employees achieve business goals.
     The incorrect use or wasted resources, including employee time, negatively affects the company’s performance and, consequently, its results.
     We must respect and protect the assets of the company to ensure that they are not lost, damaged, incorrectly used or wasted, nor lent to others or transferred without authorization.
  9. Undisclosed information and Confidentiality
     The Employees of the Super Bock Group pledge to keep confidential, not to disclose, transmit or use, themselves or let use by third parties, under any circumstances, information received confidentially, regarding the Super Bock Group activities, or information they may know due to their functions within the company (“Sensitive Information”), under penalty of incurring in the obligation to indemnify the Company, in the general terms of law, without prejudice to other disciplinary level that may ensue.
     Employees may not use information arising from the exercise of their functions in the Company to pursue purposes other than those of the Super Bock Group’s social interest, namely to obtain personal advantage for themselves or for third parties.
     Considering the current reality and the high Employee and Partners turnover, the signature of confidentiality agreements may be required, when this becomes relevant.
  10. Conflict of Interests
      Employees must promptly inform the Super Bock Group Personnel Department of any situation that may lead to a potential or actual conflict of interest and / or in any way limit their impartiality and / or independence or impair, in any way the interests of the Super Bock Group, by filling out the existing form for this purpose.
      For the purposes of this Code, a conflict of interests is deemed to exist whenever the impartial and independent exercise of functions by an Employee may be jeopardized by family reasons, affective, political affinity, economic interest, or for any reason of communion of interests between the Employee and third party.
      By way of example, the situations that might incur in a possible conflict of interests are listed:
      • Investment or direct participation in a company competing with the Super Bock Group, supplier, customer or through family or similar;
      • Family / spouse / related / other relevant personal relationships that collaborate with competing companies, suppliers or customers of the Super Bock Group;
      • Familiar / personal relationship with another Super Bock Group employee;
      • Gifts, invitations and other from competitors, suppliers and / or customers of the Super Bock Group.

      Whenever an Employee is aware that the Super Bock Group is considering a business, transaction, project, initiative or investment decision involving a competitor or entity to which it is directly connected or through personal, family or other relationships , which he maintains with a third party, must immediately inform their superior, without prejudice to the obligation to maintain the maximum confidentiality with respect to the information and knowledge that came to his possession, otherwise he may be held liable for the damages that their performance, or omission to communicate any conflict of interest, came to result for the Super Bock Group.

• As responsible entrepreneur / Citizens
  1. Political activities
     Super Bock Group Employees have the right to participate as citizens in political life, provided they ensure that such participation is not made on behalf of the Company.
     If Employees engage in political activities they should clarify that they do so in a personal capacity.
  2. Contribution to the Community
     Super Bock Group promotes volunteering actions among their employees who may freely choose to join as long as these don’t jeopardize the normal functioning of the Company.
     In the exercise of these activities, the Employee is representing the Company, and should therefore comply to and demonstrate the values of the Super Bock Group in their behavior as a volunteer.
  3. Environmental awareness
     We must be aware of the environmental impact of our activity and promote the most appropriate environmental practices.
     We must comply with and promote all the requirements defined in the Integrated Quality, Environment and Safety Policy.
     Promote efforts to reduce the ecological footprint of business processes, should be a constant concern in our daily activity.

This Code is intended to provide an opportunity for anyone to raise concerns about behaviour or decisions that they believe do not comply with this Code.
Irregularities detected in the company should be reported through the Super Bock Group Whistleblowing Channel.
All situations reported (“whistleblowing”), provided that duly identified by the author, will be treated or investigated with full confidentiality, in accordance with the provisions of the Speak Up Policy.
After a preliminary analysis of the reported situations, carried out by an external and independent entity, the Ethics Committee shall be responsible for defining the actions and procedures to be adopted following the reported or known situations. The Ethics Committee may, if it sees fit, be supported and assisted by other bodies, departments or employees of the Super Bock Group, whenever necessary, or even by external auditors or other experts hired to assist in the investigation. If the complaints presented involve any member of the Ethics Committee, or members of the Board of Directors, the external entity must submit them to the Supervisory Board for examination.
Any communication of a possible irregularity or infraction should be made through the Super Bock Group whistleblowing channel, available on the corporate website, at https://eu.deloitte-halo.com/whistleblower/website/Superbock.

Appointed by the Supervisory Board and having as a mission to monitor the implementation of the Super Bock Group’s Code of Ethics, the Ethics Committee will have the following responsibilities;

• Update the Code of Ethics whenever this is proven necessary, submitting its approval to the Executive Committee;
• Propose business ethics tools, policies and goals;
• Give opinion, when requested, on practices in the field of business ethics;
• Clarify any doubts that may arise regarding the matters contained in this Code;
• Analyze the (reported) conducts that violates the Code of Ethics, decide its relevance / admissibility and, in case of admission, decide and control the execution of subsequent corrective actions and / or disciplinary actions.

The Ethics Committee is made up of three elements: a president and two members who are appointed for their personal and professional qualities and, in particular, for their knowledge in one or more of the following areas: ethics, human resources, compliance, law or internal audit.