Code of Conduct

Preamble
The present Code of Conduct aims at establishing the ethical and professional conduct
rules and principles that should guide Portugal Telecom Foundation's employees, when
relating to each other and in their relationship with the community.
The Code of Conduct means to establish itself as a reference regarding the Foundation's
standard of conduct, as a fundamental pillar of transparency, confidence and
independence.
The Code of Conduct expresses Portugal Telecom Foundation's commitment to
consolidate the institutional image of the Foundation as an example of integrity,
accountability, accuracy and excellence.

Chapter I
Scope

Article One
(Scope)
1. The present Code of Conduct applies to all Portugal Telecom Foundation employees
including members of the corporate bodies, in the performance of their duties.
2. The rules and principles established in this Code of Conduct do not preclude or waive
the application of any other rules of conduct or ethics that may also apply.

Chapter II
Ethical Principles and Professional Conduct
Article Two
(General Principles)
1. In the performance of their official duties, the conduct of employees must be in
accordance with the principles of legality, good faith, responsibility, independence,
transparency, integrity and confidentiality, taking into consideration the Foundation's
mission and policies here defined.

Article Three
(Legality)
Employees must perform their duties in strict compliance with the law, ensuring that the
Foundation's decisions, especially those affecting the rights of individuals or legal persons,
are in conformity with the law.
Article Four
(Equal treatment and non-discrimination)
1. Employees must uphold the principle of equal treatment in every decision-making
process.
2. Employees are prohibited from discriminatory behaviour based on race, gender, religion,
political option, disability or sexual orientation.
3. Employees must uphold the principle of equal treatment when dealing with third-party
applications, handling records or making decisions, unless there is relevant justification.

Article Five
(Proportionality)
Employees shall strive to make the outcome of decisions proportional to the required
objective.

Article Six
(Abuse of Power)
Employees shall perform their professional duties strictly for the purposes for which they
were assigned, refraining from their use in self-interest or for purposes which are not in the
interest of the Foundation's.

Article Seven
(Impartiality and independence)
1. Employees must be impartial and independent and must not be swayed by personal,
family-related, or any other kind of influence, abstaining from behaviour that may arbitrarily
harm or benefit third parties.
2. Employees shall not accept or resort to offers, payment or other favours in exchange for
any activity in the performance of their duties.

Article Eight
(Diligence, efficiency and responsibility)
1. Employees must perform the duties assigned to them with zeal, efficiency, courtesy and
responsibility, by aligning their behaviour with the guidelines and regulations issued by the
Foundation.
2. Employees must respond correctly, accurately and comprehensively to any questions
put to them.
Article Nine
(Confidentiality)
Despite the principle of transparency, employees should act with reserve and discretion
with regard to the information they have acquired in the course of their duties and comply
with the established rules regarding the confidentiality of information.

Chapter III
Conflicts of interest and incompatibilities

Article Ten
(Conflicts of interest)
Foundation employees that are called upon, in the exercise of their duties, to intervene in
actions or decisions involving, directly or indirectly, themselves or persons who are, or
have been linked to them by kinship or affinity, or even organizations the employee is or
has been connected to in the past, must report the existence of such relationships to the
Foundation.

Article Eleven
(External activities)
1. Any activity, paid or unpaid, performed outside their working hours, may not interfere in
a negative way on the employee's obligations to the Foundation.
2. Taking on paid activities must be reported to the Foundation beforehand.

Article Twelve
(Scientific and academic activities)
Employees may undertake scientific or academic activities in a personal capacity and their
scientific or academic contributions should not involve the Foundation unless they are
requested or authorized to do so in advance.

Article Thirteen
(Political activities)
1. When participating in political activities, the employees must ensure the Foundation's
independence without limiting their ability to fulfil their assigned professional duties.
2. Employees will not make any contributions to political parties, either monetary or in kind.
Article Fourteen
(Governing bodies)
The Foundation's governing bodies are elected for a three year term with the possibility for
re-election as stated in the bylaws.

Article Fifteen
(Community and sustainability)
The Foundation is committed to preserving a socially responsible attitude in regard to the
community, contributing towards progress, welfare and improving the quality of life for all
citizens, while significantly furthering environmental, economic and social sustainability.

Chapter IV
External Relations and Representation
Article Sixteen
(External Relations)
1. Formal or informal contact with other public or private entities, national and foreign,
must reflect the Foundation's guidelines at all times.
2. Employees shall actively fight against all forms of corruption, active or passive, paying
close attention to situations that may lead to illicit advantages.

Article Seventeen
(Media)
1. Employees shall not make statements to the media on issues related to their duties or
the Foundation's image without previous consent from the Foundation.
2. Employees must inform their superiors whenever they wish to write articles or
communications related to their professional duties.

Chapter V
Correspondence, requests and procedures

Article Eighteen
(Responses)
1. Any response to correspondence sent to the Foundation should be dealt with within 30
days of reception.
2. A response may be waived in cases of insulting, repetitive, irrelevant or pointless
content.

Article Nineteen
(Requests and procedures)
1. Decisions regarding requests to the Foundation must be made within a reasonable time
frame.
2. Whenever a request is deemed too complex to allow for a timely decision, the author of
such request shall be informed accordingly.

Article Twenty
(Basis for decisions)
The reasons for all Foundation decisions shall be clearly justified. Employees should
refrain from making decisions based on summary or vague motives or influenced by
personal beliefs.

Chapter VI
Internal Relations
Article Twenty One
(Employee relations)
The behaviour and actions of the Foundation's employees should strive towards
involvement and participation, the maintenance of a climate of trust and civility while
respecting the hierarchical structure, proactive collaboration, the sharing of knowledge and
information and cultivation of team spirit.

Article Twenty Two

(Use of resources)
1. Employees must respect and protect the assets of the Foundation and prevent the
improper use of services and facilities by others.
2. The use of the Foundation's resources must be adjusted to the requirements of set
objectives. Employees should take appropriate measures to limit costs and expenses, thus
allowing for a more efficient use of available resources.

Chapter VII
Code dissemination and implementation and reporting of irregularities
Article Twenty Three
(Code dissemination)
The Foundation shall disseminate information on this Code, namely by making it available
and easily accessible through its internet site.

Article Twenty Four

(Code implementation)
1. In order to comply with the provisions of this Code of Conduct, employees should voice
their doubts and ask for any clarifications they deem necessary with respect to any matter
stated therein.

Article Twenty Five

(Reporting of irregularities)
The reporting of irregularities or violations of the Code of Conduct by any employee or
entity directly concerned, should be directed to the CEO of the Foundation, through the
available channels, namely by email to codigodecondutafpt@telecom.pt.