In compliance with Portuguese Securities Market Commission (CMVM) Recommendations on the corporate governance of listed companies, and to foster a culture of responsibility and diligence, Novabase has adopted a system for communicating irregular practices (“SPI”) occurring within the Novabase Group. Communication of irregular practices through the SPI is routed to the Auditing Committee, which designates an individual in charge of the SPI to manage the communications received. This individual must act with independence and autonomy (notwithstanding responsibility to the Auditing Committee for the proper performance of his or her duties) and is subject to confidentiality obligations.
Alleged irregularities may be reported in a safe and confidential manner to the care of Dr. Manuel Alves Monteiro, an independent member of the Audit Committee, in one of the following two ways:
After the investigation, the Auditing Committee routes communications indicating the likelihood of an irregular practice to the Board of Directors so that it may take the measures deemed appropriate.
Whenever the communication of irregular practices results in evidence of a crime or serious disciplinary offence, the Auditing Committee will recommend that the company forward the matter to (i) the internal boards of Novabase for proper proceedings; and (ii) to external investigative authorities, namely the police or Public Prosecutor, to determine applicable liability.
General conflict of interest rules apply to decisions to be approved by the Auditing Committee or Board of Directors concerning communications made under the SPI.