Comércio Têxtil Atlantic Sud Ltda.
Rua do Parque Industrial, No. 70, 4755-481
Rio Covo (Santa Eulália), Portugal
Telephone: 253 830 110
Visit our website at:
https://www.fportugal.com/pt/
INTRODUCTION
Comércio Têxtil Atlantic Sud, Ltda.—holding corporate tax identification number 506 762 777 and located at Rua do Parque Industrial, No. 70, in the parish of Rio Covo (Santa Eulália), municipality of Barcelos, district of Braga (postal code 4755-481)—is a limited liability company. Its primary business activity involves the sale of textile products and accessories related to the Portuguese National Football Team, other football teams that represent Portugal, and the iconic Cristiano Ronaldo product line.
In addition, the company sells textile products and accessories under its own brand, "Força Portugal."
The implementation of a Code of Ethics and Conduct is mandated by Article 7 of the General Regime for the Prevention of Corruption (RGPC), established by Decree-Law No. 109-E/2021 of December 9. A primary objective of this Code is to define a set of standards, rules, and principles to guide the conduct of all managers and employees regarding professional ethics, while consistently accounting for criminal laws concerning corruption and related offenses. Accordingly, this Code of Ethics and Conduct serves as the foundational document establishing the ethical and deontological principles and rules that must govern all activities carried out by Comércio Têxtil Atlantic Sud Ltda. This code also serves as a model of conduct for external entities—most notably our clients and suppliers—encouraging them to adhere to high ethical and professional standards, thereby fostering an environment of trust in their interactions with third parties. Mutual respect, ethics, and dignity at all levels of the workplace are fundamental characteristics of successful organizations—values that Comércio Têxtil Atlantic Sud, Lda. embraces and actively promotes in its own market operations. Through this Code of Ethics and Conduct, we make a formal commitment to consistently uphold the principles set forth herein.
1— CODE OF ETHICS AND CONDUCT
The growth that Comércio Têxtil Atlantic Sud, Lda. has experienced over the years is primarily due to the daily efforts of our employees and the solid partnerships we have built. Today, as always, this growth rests on an essential pillar: trust—both among our own staff and within the relationships we have established with our partners, clients, suppliers, and regulatory or oversight bodies. There can be no trust without ethics! Because the future holds complex challenges, and a single action could potentially jeopardize the results of decades of hard work and dedication, this code is designed to guide you—as an employee of Comércio Têxtil Atlantic Sud, Lda.—in acting with integrity. It helps ensure that the company maintains the high ethical standards that govern all of our activities. The Code of Ethics outlines the core principles and values of Comércio Têxtil Atlantic Sud, Lda. The Code of Conduct is mandatory for all employees of Comércio Têxtil Atlantic Sud, Lda., regardless of their specific roles, responsibilities, or hierarchical position. 2 — SCOPE OF APPLICATION
This Code of Ethics and Conduct applies to any person or entity that collaborates with Comércio Têxtil Atlantic Sud, Ltda., regardless of the nature of their relationship or the form of their engagement.
As parties involved—directly or indirectly—with Comércio Têxtil Atlantic Sud, Ltda., the following are required to comply with this Code of Ethics and Conduct:
▪ Shareholders;
▪ Directors and managers;
▪ Employees;
▪ Suppliers;
▪ Service providers;
▪ Contractors;
▪ Subcontractors.
2.1 — ENTRY INTO FORCE
This revised and updated version of the Code of Ethics and Conduct enters into force on February 14, 2025. Comércio Têxtil Atlantic Sud, Ltda. reserves the right to amend this Code of Ethics and Conduct should circumstances warrant such changes.
Any amendments to this Code of Ethics and Conduct will be promptly communicated to the relevant parties, with particular emphasis on employees.
3 — MISSION, VISION, AND VALUES
3.1 — MISSION
Comércio Têxtil Atlantic Sud, Ltda. and all its employees are committed to providing value-added services to their clients, contributing positively to the social, economic, and environmental sustainability of Portuguese society.
To this end, we demand efficiency, responsibility, and loyalty, ensuring:
▪ The fulfillment of commitments made to our clients and consumers;
▪ Compliance with the law and the adoption of socially, economically, and environmentally responsible conduct;
▪ The protection of our employees' rights, as well as their integration, training, and opportunities for professional growth.
3.2 — VISION
Comércio Têxtil Atlantic Sud, Ltda. aspires to be a benchmark in the textile trade sector, distinguished by excellence in customer service, constant innovation, and a commitment to social, economic, and environmental sustainability. It aims to be recognized as an ethical, responsible company committed to quality, contributing to the development of Brazilian society and the well-being of all its stakeholders.
3.3 — VALUES
For Comércio Têxtil Atlantic Sud, Ltda., values represent the fundamental principles that guide the daily decisions and actions taken in the pursuit of its commercial activities. The company is committed to fostering an ethical, responsible, and innovative work environment, ensuring that all operations—from product procurement to customer service—are aligned with the highest standards of quality and social responsibility. The company believes that its ethical stance and values are essential for long-term success and for strengthening relationships with employees, clients, partners, and regulatory bodies.
3.3.1 — THE SCOPE OF SOCIAL RESPONSIBILITY
Comércio Têxtil Atlantic Sud, Ltda. [The company] repudiates any and all forms of discrimination, slave labor, forced labor, or child labor; accordingly, the company ensures and requires the following from its employees:
▪ Respect for the values of justice, legality, integrity, honesty, loyalty, solidarity, inclusion, and transparency;
▪ Respect for fundamental rights regarding safety, health, and well-being in the workplace;
▪ Respect for the rights to privacy, equal opportunity and non-discrimination, freedom of expression, the right to representation, and the right to training and professional development.
3.3.2 — REGARDING ENVIRONMENTAL RESPONSIBILITY
Comércio Têxtil Atlantic Sud, Ltda. respects the environment and nature, adopting environmentally responsible practices:
▪ It promotes and requires the conservation of energy and natural resources;
▪ It utilizes clean and/or renewable energy sources whenever possible;
▪ It recycles and reuses materials;
▪ It implements solutions for efficient consumption.
3.3.3 — REGARDING ECONOMIC RESPONSIBILITY
Comércio Têxtil Atlantic Sud, Ltda. conducts all its operations based on principles of rigor, competence, professionalism, high quality, legality, fair competition, creativity, intelligence, and hard work; therefore:
▪ It rejects any form of tax evasion, fraud, or breach of fiscal trust;
▪ It requires strict compliance with competition laws;
▪ It remains independent of any political parties or pressure groups;
▪ It does not tolerate criminal practices;
▪ It rejects and does not tolerate corruption, influence peddling, bribery, or similar acts. 4 — PRINCIPLES OF CONDUCT
Comércio Têxtil Atlantic Sud, Ltda., along with all its employees and those involved with the company—whether directly or indirectly—carry out their activities and duties in adherence to the highest ethical and professional standards. They comply with all applicable legal and regulatory provisions, as well as with this Code of Ethics and Conduct.
4.1 — REPRESENTING THE ORGANIZATION
4.1.1 — LOYALTY
Employees of Comércio Têxtil Atlantic Sud, Ltda. must act to protect the company’s interests, consistently maintaining a stance of loyalty and striving to safeguard its credibility and positive reputation in every conceivable situation. Employees of Comércio Têxtil Atlantic Sud, Ltda. must remain impartial and independent, avoiding taking sides:
▪ Always acting in the best interests of clients, consumers, partners, the company itself, and its shareholders;
▪ Acting with complete independence from political interests or pressure groups;
▪ Refraining from making, influencing, or attempting to influence any decision—of any nature—when faced with a conflict of interest;
▪ Reporting any and all situations involving a conflict of interest, including potential ones;
▪ Recognizing that a conflict of interest arises whenever the employee—or someone close to them—stands to benefit, directly or indirectly, from a given situation.
4.1.2 — EQUALITY AND IMPARTIALITY
Comércio Têxtil Atlantic Sud, Ltda. is governed by the principle of equality; it shall not grant privileges or benefits to, nor cause harm or deprive of rights, or exempt from duties, any individual based on their ancestry, sex, race, language, territory of origin, religion, political and/or ideological convictions, education, economic status, social condition, and/or sexual orientation.
All employees of Comércio Têxtil Atlantic Sud, Ltda. must treat their clients in a fair, impartial, and egalitarian manner, acting in accordance with strict principles of neutrality.
4.1.3 — TRUST AND TRANSPARENCY
Employees of Comércio Têxtil Atlantic Sud, Ltda. shall always act in a trustworthy and transparent manner, specifically by:
▪ Fulfilling the obligations undertaken by the company they represent;
▪ Acting and communicating with truthfulness and transparency—ensuring information is accurate, complete, truthful, and not misleading—regardless of the circumstances;
▪ Recording and handling any data relevant to accounting, finance, taxation, or management in a reliable manner, in compliance with applicable standards;
▪ Always ensuring the quality and safety of, as well as providing information regarding, the products and services supplied, including the procedures associated with their production and delivery.
4.1.4 — LEGALITY
Employees of Comércio Têxtil Atlantic Sud, Ltda. must act strictly in accordance with current legislation, by:
▪ Staying informed and up-to-date on all legislation specifically applicable to their professional activities, and ensuring that their subordinates are similarly informed and updated;
▪ Refraining from any actions or associations that are inconsistent with this Code of Ethics and Conduct;
▪ Complying with—and ensuring that their subordinates comply with—all applicable laws, including, in particular:
— Labor and social security legislation; — Legislation regarding discrimination, slave labor, forced labor, and child labor;
— Legislation regarding discrimination;
— Legislation on hygiene, health, and food safety;
— Competition law;
— Data protection legislation;
— Tax, customs, and parafiscal legislation;
— Environmental and protection legislation;
— Anti-money laundering legislation.
4.1.5 — PROFESSIONAL CONFIDENTIALITY
Partners, employees, and other parties involved—whether directly or indirectly—are bound by a duty of loyalty and confidentiality toward Comércio Têxtil Atlantic Sud, Lda. They are prohibited from disclosing information related to the company’s commercial activities, particularly concerning its suppliers, clients, and colleagues. This excludes information that is customarily disclosed for the purpose of market prospecting or the ongoing conduct of business operations.
Furthermore, employees are specifically obligated to uphold these duties in accordance with the terms set forth in their employment contracts, and they remain subject to all requirements stipulated therein.
4.1.6 — SAFEGUARDING OF ASSETS
It is the responsibility of every employee at Comércio Têxtil Atlantic Sud, Lda. to ensure the protection and preservation of the company’s physical, financial, and intellectual assets. Company resources must be used efficiently to achieve the established objectives.
Employees of Comércio Têxtil Atlantic Sud, Lda. are responsible for the assets and valuables belonging to the company or its clients that are entrusted to them. Therefore, they must:
▪ Use such assets and valuables strictly for professional purposes and in the best interest of the company and its clients;
▪ Account for everything entrusted to them until it is fully returned;
▪ Take the necessary measures to:
— Prevent loss, theft, dissipation, misappropriation, excessive expenditure, or use by third parties. — To ensure their proper preservation and use by their subordinates.
Employees of Comércio Têxtil Atlantic Sud, Ltda. are also fully aware that the following are company assets:
▪ Objects and valuables placed at their disposal for the performance of their duties (work tools, computers, mobile phones, etc.);
▪ Information to which they are granted access;
▪ Intangible assets, such as the company’s reputation and its trademarks;
▪ Working time.
During working hours, employees of Comércio Têxtil Atlantic Sud, Ltda.:
▪ Shall not use working time for personal activities;
▪ Shall use the company’s communication and information resources strictly for professional purposes, refraining from downloading illegal, prohibited, or personal programs or content; viewing content unrelated to their work; or accessing social media or any leisure-related programs while at work or during working hours.
4.2 — INTEGRITY
Employees of Comércio Têxtil Atlantic Sud, Ltda. must ensure scrupulous compliance with the legal and regulatory standards applicable to their activities, and must refrain from any acts that violate this Code of Ethics and Conduct.
Employees must also comply with legitimate requests made by judicial authorities and refrain from any behavior that might hinder the exercise of their respective powers.
Any acts committed or omitted for the purpose of obtaining an undue advantage or compensation are considered corruption, which may take the following forms:
▪ Active Corruption: the offering or promising—by an employee, either directly or through a third party with the employee’s consent or ratification—of any value or undue advantage to another party in exchange for an act or omission that violates the duties and responsibilities of the recipient;
▪ Passive Corruption: the soliciting or accepting—by an employee, either directly or through a third party with the employee’s consent or ratification—of any value or undue advantage (or the promise thereof) for themselves or for a third party, in exchange for an act or omission that violates their own duties and responsibilities.
▪ Other Related Offenses: any similar offenses that undermine the proper conduct of business at Comércio Têxtil Atlantic Sud, Lda. in its dealings with stakeholders, including bribery, embezzlement, malfeasance, influence peddling, and the receipt of undue advantages.
4.2.1 — CONFLICT OF INTEREST
Employees of Comércio Têxtil Atlantic Sud, Lda. must notify their superiors and recuse themselves from decision-making processes that directly or indirectly involve organizations with which they collaborate, or individuals to whom they are—or have been—linked by kinship or affinity. Furthermore, employees must refrain from engaging in any activities outside of Comércio Têxtil Atlantic Sud, Lda. that could compromise the fulfillment of their professional duties, or from participating in entities whose objectives might conflict or interfere with the objectives of Comércio Têxtil Atlantic Sud, Lda.
Should an actual or potential conflict of interest arise, the employee of Comércio Têxtil Atlantic Sud, Lda. must immediately report it to their direct supervisor or to the Internal Audit Department.
4.2.2 — GIFT POLICY
Except in cases expressly authorized in writing, employees of Comércio Têxtil Atlantic Sud, Lda. shall not accept or offer—directly or indirectly—to or from clients, suppliers, or third parties:
▪ Any gifts or invitations that could influence their decision-making;
▪ Any gifts or invitations provided in exchange for services rendered to a client or supplier;
▪ Gifts, monetary amounts, or their equivalents;
▪ Invitations to meals, social events, trips, or similar activities;
▪ Special discounts on the purchase of goods or services provided to a client by a supplier or third party.
4.3 — RELATIONSHIPS WITH THIRD PARTIES
4.3.1 — CLIENTS
Employees and other members of management at Comércio Têxtil Atlantic Sud, Lda. must demonstrate a high level of professionalism, respect, honesty, good faith, and courtesy when interacting with clients or potential clients. They shall strive to provide efficient service and support, offering information regarding products, services, and pricing to assist clients in making the best possible decisions, while also addressing their requests, inquiries, and complaints. 4.3.2 — SUPPLIERS
Employees of Comércio Têxtil Atlantic Sud, Lda. must conduct negotiations based on the principle of good faith and fully honor their commitments to suppliers, partners, or service providers. This includes adhering to contractually defined standards, as well as fulfilling the ethical, social, and environmental commitments agreed upon in this Code of Ethics and Conduct.
The selection of suppliers or service providers must be carried out in accordance with market conditions. This process should take into account not only economic and financial indicators, but also commercial terms, the quality of products or services, and the ethical conduct of these companies. Furthermore, social aspects—such as respect for life, dignity, and human rights—as well as environmental awareness, must also be considered.
4.3.3 — COMPETITION
In the conduct of its business activities, Comércio Têxtil Atlantic Sud, Ltda. engages in competitive practices that are entirely transparent and fair. All employees and managers of Comércio Têxtil Atlantic Sud, Ltda. must adhere to market rules and standards, strictly avoiding any form of unfair competition—such as agreements to share markets or fix prices, collusion intended to gain an advantage over competitors, or the acquisition of commercial information through illegal means—while also respecting all material and intellectual property rights.
Employees of Comércio Têxtil Atlantic Sud, Ltda. are aware that competition law is complex; therefore, should they be asked to engage in any act or behavior similar to those mentioned above, they must refuse to do so, citing the Code of Ethics and Conduct and immediately reporting the situation to management or their direct supervisor.
4.4 — PEOPLE
4.4.1 — COLLABORATION AND INTERPERSONAL RELATIONSHIPS
All employees of Comércio Têxtil Atlantic Sud, Ltda. are expected to contribute to the creation and maintenance of a positive work environment through mutual collaboration and cooperation. To this end, employees must not seek personal gain at the expense of their colleagues; they must consistently implement decisions made by their superiors—provided these decisions align with company policies and strategies—and encourage and support their subordinates in the application of such decisions.
In the performance of their professional duties, employees must maintain a demeanor that is professional, serious, competent, loyal, principled, and cordial. They should remain mindful of the fundamental requirements for proper conduct, ensuring that their actions do not create unjustifiable obstacles or difficulties for the colleagues or clients with whom they interact. Conduct amounting to moral, sexual, or virtual harassment, or any other form of abuse of power, is not tolerated. Comércio Têxtil Atlantic Sud, Ltda. also upholds the freedom of expression, information, and opinion for all employees; any censorship or restriction of these rights shall be considered an affront to human dignity.
4.4.2 — CAREERS AND PROFESSIONAL MERIT
Comércio Têxtil Atlantic Sud, Ltda. respects the principle of equal opportunity and evaluates employee performance based on individual merit. The company strives to foster professional growth in accordance with established criteria, providing compensation commensurate with an individual’s competencies, level of responsibility, and demonstrated performance.
Employees of Comércio Têxtil Atlantic Sud, Ltda. are expected to continuously seek to improve and refine their knowledge to maintain their professional capabilities.
4.4.3 — WORKPLACE SAFETY, HEALTH, AND WELL-BEING
Comércio Têxtil Atlantic Sud, Ltda. ensures compliance with all applicable standards regarding safety, health, hygiene, and well-being in the workplace. Employees are required to strictly adhere to all laws, regulations, and internal instructions. Compliance with safety standards is a mandatory obligation for everyone; furthermore, employees have a duty to promptly report any anomalous situations to their direct supervisors.
4.5 — THE ENVIRONMENT AND SOCIETY AT LARGE
Comércio Têxtil Atlantic Sud, Ltda. assumes social responsibility toward all stakeholders and the communities in which it conducts its commercial and business activities, contributing to progress and well-being both within the company and in the surrounding communities.
Comércio Têxtil Atlantic Sud, Ltda. It considers the adoption and promotion of environmental sustainability to be of primary importance, contributing not only to the rationalization of its clients' environmental footprint and energy consumption, but also to the reduction of their carbon emissions—while embracing, whenever possible, a green and circular economy.
5 — DISCLOSURE
In order to avoid situations that might cause offense or discomfort, employees of Comércio Têxtil Atlantic Sud, Lda. shall ensure that this policy regarding gifts and offerings is communicated to and understood by all of the company’s clients and suppliers.
All employees of Comércio Têxtil Atlantic Sud, Lda. are required to read and learn the Code of Ethics and Conduct. The company is responsible for providing training initiatives it deems appropriate to assist employees in acting in accordance with this Code.
Should any questions, a need for clarification, or a request for additional information arise, employees should consult their direct supervisor—without hesitation and without fear of asking. Whenever there is uncertainty regarding the application of the Code of Ethics and Conduct in a specific situation, employees should consider the following questions:
1. Is it legal and in accordance with the principles, values, and objectives of this code?
a. If yes, you may proceed;
b. If no, do not proceed;
c. If in doubt, ask questions, but do not proceed.
2. Will this action or procedure allow those I interact with to maintain their trust in me and in Comércio Têxtil Atlantic Sud, Ltda.?
a. If yes, you may proceed;
b. If no, do not proceed;
c. If in doubt, ask questions, but do not proceed.
3. If this action or procedure were to become public knowledge, would the reputation of Comércio Têxtil Atlantic Sud, Ltda. remain untarnished?
a. If yes, you may proceed;
b. If no, do not proceed;
c. If in doubt, ask questions, but do not proceed.
Any offers or invitations that exceed the established limits must be politely declined—with an explicit reference to this Code of Ethics and Conduct—or otherwise turned over directly to the company itself. In case of doubt, any such situation must be reported in advance to your direct supervisor.
6 — PRIVACY POLICY
Comércio Têxtil Atlantic Sud, Ltda. respects the privacy of all its employees, business partners, clients, and suppliers, ensuring that their personal data is handled responsibly and in compliance with applicable laws—specifically, in full adherence to both national and European data protection legislation.
In this context, an employee of Comércio Têxtil Atlantic Sud, Ltda. shall:
▪ Treat all information accessed in the performance of their duties as confidential and protect it;
▪ Not disclose such information to: o Anyone outside the company; o Other employees of Comércio Têxtil Atlantic Sud, Ltda. who do not require it to perform their own duties;
▪ Not use such information for personal purposes. Furthermore, it provides specific protection for:
▪ Personal data (relating to employees, clients, suppliers, partners, among others);
▪ Strategic data (relating to strategic plans, marketing plans, forecasts, among others);
▪ Commercial data (lists of clients and suppliers, pricing, costs and their composition, among others);
▪ Technical data (technical product specifications);
▪ Legal data (contracts, agreements, mergers, acquisitions, among others).
It should be noted that the obligations to protect, respect, and maintain the confidentiality of information persist even after the professional relationship between an individual and Comércio Têxtil Atlantic Sud, Ltda.—or any other company with which they may collaborate—has ended.
7— WHISTLEBLOWING CHANNEL
Comércio Têxtil Atlantic Sud, Ltda. fosters an ethical and transparent work environment, encouraging all employees, partners, and other stakeholders to report any violations of this Code of Ethics and Conduct, as well as instances of illegal activity, fraud, corruption, or any other form of misconduct.
To this end, a whistleblowing channel has been established, allowing employees and entities directly or indirectly linked to Comércio Têxtil Atlantic Sud, Ltda. to report any violations or irregularities concerning this Code of Ethics and Conduct, or the associated Plan for the Prevention of Corruption Risks and Related Offenses.
7.1 — PRINCIPLES OF THE WHISTLEBLOWING CHANNEL
The whistleblowing channel ensures that all reports submitted are:
▪ Confidential: the identity of the whistleblower is protected.
▪ Impartial: all reports are analyzed with rigor, independence, and impartiality.
▪ Protected against retaliation: no whistleblower will be harmed or penalized for reporting concerns in good faith.
7.2 — HOW TO SUBMIT A REPORT?
Reports may be submitted through the following channels:
▪ Directly to one’s hierarchical superior;
▪ Via the link: https://fportugal.workky.com/portal-denuncias
▪ Directly to the Internal Audit Department.
7.3 — SITUATIONS THAT MAY BE REPORTED
Various types of issues may be reported through the aforementioned channels, including:
▪ Acts or attempted acts of corruption, bribery, or influence peddling;
▪ Financial and accounting fraud;
▪ Workplace harassment (moral or sexual);
▪ Discrimination or violation of workers' rights;
▪ Violation of environmental or safety regulations;
▪ Misuse of company assets;
▪ Among others.
7.4 — PROCESS FOR HANDLING REPORTS
Upon receipt, reports are handled in an impartial and confidential manner, with full protection for the whistleblower. The first phase consists of an initial analysis, during which the Internal Audit Department evaluates the report to determine whether an investigation is required. If an investigation is deemed necessary, an internal or external inquiry will be conducted to verify the accuracy of the report. If the report is substantiated, appropriate measures will be taken, which may include the dismissal of the individual(s) involved, as well as other, more serious legal actions. 8 — INFRACTIONS AND SANCTIONS
Failure to comply with the provisions of the Code of Ethics and Conduct—provided that the relevant legal criteria are met—may result in disciplinary and/or criminal liability.
Upon receiving a report of an alleged violation of the Code of Ethics and Conduct, the Internal Audit Department shall investigate the ethical conduct of the employee in question.
If the infraction is confirmed, the individuals involved shall be sanctioned in accordance with the law, based on the severity of the violation, the degree of the offender’s culpability, and the consequences of their actions. Sanctions shall be applied on a graduated scale, ranging from a formal reprimand to termination for just cause. Furthermore, such acts shall be immediately reported to the competent authorities.