Introductory note

The Wondercom Group has always sought to conduct its business based on standards of integrity, transparency, honesty, professional ethics, and respect for others, the environment, and compliance with the law.

As part of our growth and evolution process, and aware that each of us plays a fundamental role within the organization, it is the Wondercom Group’s responsibility to promote and ensure compliance with the ethical principles and values that characterize our identity.

The guidelines contained in this code therefore represent a shared commitment within the Wondercom Group. For this reason, all our employees must be familiar with this document, incorporate these principles into their daily professional lives, and promote their dissemination within the Organization, contributing positively on a daily basis to improving these guidelines.

Recipients

This Code of Conduct defines the ethical standards for all Wondercom Group employees (Wondercom, KnowledgeWorks, and Wondertrade), regardless of their hierarchical level, and it is expected and encouraged that everyone acts in accordance with the fundamental principles and values of the Organization.

It is also intended that these guiding principles be known and accepted by all those who collaborate or interact with us, namely service providers and partners.

Professionalism and diligence

Employees must strive to perform their professional duties with the utmost rigor, diligence, and competence, acting in the interests of the Organization and always complying scrupulously with the laws and internal procedures applicable to their activity.

Our organization values personal responsibility and professionalism in its employees. It also considers attendance and respect for working hours to be essential for all its employees.

Without prejudice to recording attendance using the means provided by the company, employees must notify their manager and the Human Resources Department as far in advance as possible of any situation that compromises compliance with working hours, providing the necessary justifications.

Confidentiality

The information obtained while working for the Wondercom Group is privileged information and may only be used by Employees in the performance of their duties. It may not be used to obtain advantages for themselves or for third parties.

Therefore, during their relationship with the Wondercom Group and for up to two years after that relationship, they must maintain absolute confidentiality regarding any information relating to the Wondercom Group or any other persons or entities related to it, namely:

Personal data or other data considered privileged;

Information about business opportunities or ongoing business;

Information about technical skills, working methods, and project management developed by the Wondercom Group;

Information relating to any projects or products completed or under development, knowledge of which is limited to Wondercom Group employees in the performance of their duties or by virtue of those duties.

Integrity and loyalty

The Organization’s Employees must behave in a proper and dignified manner, safeguarding the prestige of the company, its customers, and its brands.

Employees must refrain from any practices that may raise doubts about the ethics of their behavior, particularly with regard to offers from or to third parties. Offers received from third parties, including gratuities, gifts, or participation in events, must be reported to management. All offers from third parties must be refused if there are indications that they may give rise to unethical behavior on the part of the offerors or employees of the Organization.

Training

The Organization seeks to provide adequate training for the performance and improvement of its employees’ professional activities, the development of their skills, and the promotion of their safety.

Employees must also continuously seek to update their knowledge and skills, with a view to maintaining or improving their professional abilities and perfecting the functions they perform, by attending the training courses offered by the Organization.

Non-competition

In their relations with third parties, Employees must remain loyal to the Wondercom Group and look after its interests, refraining from engaging in activities that compete, directly or indirectly, with those carried out by the Organization.

Equal opportunities, discrimination, and harassment

The Organization respects the principle of equal opportunities and does not discriminate on the basis of factors unrelated to individual professional performance.

No form of individual discrimination that is incompatible with human dignity is acceptable, particularly on the basis of origin, ethnicity, gender, age, political beliefs, social class, religious beliefs, sexual orientation, disability, or any other factor. Any conduct constituting sexual or moral harassment, mobbing, abuse of power, or other conduct that undermines the normal dignity of the human person and behaviors contrary to normal practices is also not tolerated.

Mutual respect must be demonstrated among employees and an inclusive work environment must be promoted.

No abusive behavior that harms others is permitted, and the right to privacy must be respected.

Consumption of alcoholic beverages, tobacco, and drugs

The Wondercom Group does not allow its employees to be under the influence of alcohol or illegal drugs during working hours and in the workplace. The Organization reserves the right to monitor the consumption of these substances during working hours in order to comply with occupational safety, hygiene, and health requirements.

Smoking is strictly prohibited on company premises, whether in offices, corridors, restrooms, social areas, cafeterias, vehicles, etc.

Extra-professional activities

Extra-professional activities are not permitted during working hours if they compromise productivity or professional performance, including: personal phone calls that are not urgent, use of the internet and social networks, excessive breaks, among others.

Protection of company property and natural resources

All employees must respect and protect the Organization’s assets (movable and immovable) and not allow their use by third parties, unless duly authorized by their superior.

The space belongs to everyone and as such must be respected. Employees must therefore ensure that the company’s facilities are kept clean and tidy.

Employees who have been entrusted with company assets for the performance of their professional activities must ensure that they are used and maintained properly. They must not be used for personal gain, unless duly authorized by a superior.

Assets made available to employees must be used exclusively for their intended purposes, in compliance with safety standards in order to prevent accidents and personal injury or property damage.

All employees, in the performance of their duties, must also make efforts to minimize the consumption of natural resources, thereby contributing to mitigating the environmental impact of the company’s activities.

Image, appearance, and hygiene

All employees represent the organization in the performance of their professional duties and must therefore take care of their appearance in order to preserve that image.

Employees who are assigned uniforms for the performance of their duties must wear them without exception whenever they are on company business and ensure that they are in good condition and presentable. Whenever the uniform is damaged, this must be reported to the respective superior.

The use of uniforms in situations that may damage the company’s image is not permitted.

Use of computer and communications equipment

Computers, mobile devices, software, and other equipment or technological services related to information and communication technology must be used in accordance with the following rules:

• You must not deliberately access or store images, texts, or materials that promote violence, hatred, or religious intolerance or any other characteristic protected by law.
• You must not install or use unauthorized or prohibited software.
• Equipment and devices must be kept in good working order.
• The email provided by the Wondercom Group to its employees must be used exclusively for professional purposes.

Protection of personal data

The Wondercom Group processes the personal data of its employees, customers, and other stakeholders by adopting the best technical and organizational measures to ensure data security and compliance with applicable legislation. Employees who process personal data in the performance of their duties must comply with the procedures implemented and, in case of doubt, contact the DPO via email: dpo@wondercom.pt

Employees’ internet activity (social media)

The Wondercom Group disseminates and communicates with customers and other stakeholders on the internet through its website, Facebook, LinkedIn, and other platforms and social media. Employees who use the aforementioned social media or others must refrain from intervening or making any contacts on behalf of or in representation of the Wondercom Group, except in cases previously authorized.

Employees who wish to intervene or express their opinion directly and personally on matters related to the Wondercom Group must do so with their line manager or management, refraining from any type of conduct on the internet or social media that could damage the image of the Organization, its customers, or other stakeholders.

Relationships with colleagues

It is the duty of all employees to contribute to a good working environment and a spirit of teamwork and mutual support within the Organization. Relationships between employees should be based on friendliness and respect for others. Inappropriate conduct, namely behavior that causes disruption or embarrassment to employees, compromising their dignity or promoting an intimidating or destabilizing environment, will be subject to disciplinary action.

Conflict of interest

Whenever, in the course of their work, employees are called upon to intervene in decision-making processes that directly or indirectly involve entities with which they collaborate or have collaborated, or persons to whom they are related, they must inform their superior of the existence of such relationships.

Similarly, employees who have family or similar relationships with each other shall not, unless authorized by a superior, carry out their activities internally in a hierarchical relationship or one of direct functional dependence.

Relationship with customers

Employees must demonstrate professionalism, respect, and cordiality in their relationships with customers, seeking to ensure equal treatment and acting in a manner that provides quality, effective, and efficient service and conveys the best image of the Wondercom Group to the outside world. Wondercom Group employees must ensure compliance with the agreed conditions regarding service quality and guarantees and handle complaints received in a diligent manner. Complaints made by Wondercom Group customers, regardless of the form used (in person, letter, fax, email, telephone, etc.), are forwarded to the Customer/Project Manager and the QAS Department. All complaints addressed to the Wondercom Group are analyzed and must be responded to as soon as possible. The employees assigned to this task must ensure an effective and efficient response to complaints by acting immediately after receiving the complaint in order to promote its proper resolution and prepare the respective response.

Relationship with suppliers

Employees must demonstrate professionalism, respect, and cordiality in their relationship with suppliers, seeking to ensure equal treatment. The Wondercom Group and its employees must honor the commitments made to suppliers or service providers and verify that suppliers comply with the requirements defined in the contract. Contracts must be written clearly and unambiguously and in strict compliance with the rules regarding confidentiality of information. Situations of possible conflicts of interest must be verified and safeguarded. No Wondercom Group employee should ever receive any amount, gift, or advantage from any supplier, either directly or indirectly, except for symbolic gifts that have been previously approved by management.

Relationship with competitors

The Wondercom Group actively encourages the development of its business in an active, competent, and ethical manner, based on the merit and quality of its offerings. The Wondercom Group and its employees may not enter into any agreements that could restrict competition, particularly through sharing or price-fixing agreements, and must respect both material and intellectual property rights. Employees must compete in an open market, as vigorously and constructively as possible, refraining from activities that distort competition, abusive conditions, and discriminatory practices.

Relationship with the media

Employees may only make public statements, give interviews (namely to the media), and participate in any type of event that may involve the Wondercom Group when authorized by Management.

Violation of the code of conduct

Wondercom Group employees undertake to respect and comply with the guiding principles set out in this Code. Failure to comply with or violation of the ethical standards set forth herein is subject to disciplinary action, without prejudice to applicable criminal, civil, and administrative proceedings.

Wondercom Group employees are also required to report any violation of these principles that they witness. Such reports must be made to the human resources department, to their immediate superior, or to management.

The Organization hereby guarantees that it will use all the tools at its disposal to quickly and rigorously investigate the facts reported, ensuring the confidentiality of the information and the seriousness with which it is treated.

Final note

The Wondercom Group counts on everyone’s collaboration in adopting ethical conduct based on the principles and values promoted by this code.

This document is comprehensive in scope, but does not cover all situations that may arise in everyday professional life. For this reason, if you have any questions regarding compliance with the provisions of this code, or any ethical issues, you should inform your supervisor or the human resources department.

Validity, changes, and updates

This code comes into force immediately after its publication on the Forum and/or on the websites of the Group’s companies.

The provisions contained in this code are subject to changes and updates that are deemed appropriate in view of the evolution of the Wondercom Group’s business or as a result of any changes to the applicable legal regulations.

See the full document here