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Code of Conduct

ABOUT TRH

TRH – Remote Technology Services, Lda, is a young and innovative IT consultancy, specialized in the development of solutions focused on cutting-edge technologies, with our main target being the European market, with companies from several market sectors. Since its beginning in 2021, TRH has demonstrated a potential for growth and international expansion, through the quickly signing up of new clients with projects that are relevant to our business. We work with a hybrid model, allowing flexibility between remote work and our Hubs in Castelo Branco, Lisbon and Guarda. We believe in fostering autonomy, cooperation and motivation, essential for the success of teamwork. The revision of the Code of Conduct reflects our commitment to maintaining clear standards of behaviour for all stakeholders, whether they are Employees, Partners, Suppliers, Freelancers, Interns or Clients, and ensuring compliance with applicable legislation, including Decree-Law No. 109-E/2021, which establishes the General Corruption Prevention Scheme. TRH aims to provide even greater clarity on the standards we expect our employees to follow and the behaviours they should adopt to ensure that our individual behaviour is in line with TRH’s core values.

WHAT IS THE CODE OF CONDUCT?

The Code of Conduct sets out the ground rules, standards and behaviours necessary to achieve our goals. It provides requirements and guidance, expressed clearly, concisely and consistently, within a single company-wide document for all our employees regardless of their role in the organization. The Code of Conduct is a common reference point that clarifies to those who are not clear (whether they are Employee, Partner, Supplier, Freelancer, Intern or Client) about what is expected in a specific situation. It is intended to serve as a reference for ethical decision-making that is aligned with our core values.

OUR GOALS

We want to be the best in creating high-performance Information Technology (IT) teams, attracting people of excellence who want to learn and improve their technical and human skills. Once working at TRH, our focus is on training our people with the right skills and tools, supporting them in a quality and supportive environment, in order to provide a high quality service to our customers, in a flexible and cooperative relationship.

OUR MISSION

Hire the best resources from local educational establishments based on their skills and abilities, train and specialize them in innovative technologies and with current methodologies. We aim to provide our clients with customized service models with risk sharing and based on established deliverables and KPI’s. We want to create a large group of small teams (squads) that believe and act based on common principles shared by all. We believe in the definition that a team is a group of different people, with skills that complement each other and committed to common goals. Teams that communicate freely and honestly, that support each other and are mutually accountable. Teams that love what they do and also know how to have fun while doing their job. We believe that these principles will lead to consistent performance of excellence with our customers.

OUR VISION

Telecommuting or remote working has proven to be a valid option! Nowadays there are technologies that allow security, efficiency and cost reduction to provide excellent quality services from all over the world and for all over the world. Still, we provide facilities (Hubs), with infrastructures to support remote services and that allow employees to come together and work in person as a team when they wish.

OUR VALUES

We are committed to our values of quality, autonomy, value, commitment, kindness and coolness. We act ethically in every business and this means achieving success based on the quality services provided by our employees and excellent customer service.

  • Quality – exceeding the expectations of our customers and our employees is in our nature! The quality in the delivery of our work, and in the way we think and approach what we do should guide us, as well as what we expect from each other. Raising the bar in quality is not an innate skill, but something we acquire and improve, defining it as a core value.
  • Autonomy – we want to work in an environment of responsible and autonomous professionals, who think critically for their own minds. People who can formulate and defend an opinion, who appreciate guidance, but who are self-confident enough to follow their path and deliver their work.
  • Value – we all want to improve what we do, and personal improvement is a key factor in how we measure our success. Adding high value and contribution is an important sign of recognition by our peers, managers and customers. And let’s not forget that it also improves our self-esteem!
  • Commitment – everyone wants to make a difference, and contribute to a greater cause, a strong and consistent personal commitment that will make a difference, for our colleagues and customers, even when we don’t have all the answers. This sense of responsibility and resilience is a key value that will be effective for our clients, for business results and also a source of personal gratification.
  • Kindness – taking care of our employees, our customers, suppliers and business partners with respect and understanding is an important human competence, even in a demanding and competitive environment. It’s important to learn to listen better, and understand that everyone can have a bad day and be supportive, be empathetic, and use kindness to turn any handicap into an opportunity.
  • Coolness – we love technology, and our brains crave novelty and new challenges; we want to focus on “cool” technologies that bring innovation, technical sophistication and, of course, business results to our customers and society, but also an invigorating tonic for our curious minds. At TRH we encourage employees to submit their ideas. We believe that this openness creates awareness about your true abilities.

Once you start collaborating with us, it’s important that you’re committed to these values.

COMPANY DUTIES

In accordance with Article 127 of the Labour Code of Portuguese law, TRH assumes the following fundamental duties towards its employees:

  • Duty of retribution: ensuring timely and fair payment of agreed wages and benefits.
  • Duty of safety and health at work: to provide safe and healthy working conditions, complying with all applicable legal standards.
  • Duty of equality and non-discrimination: ensuring that all employees are treated equally, without any discrimination.
  • Training and development duty: to promote opportunities for professional growth and continuous training.
  • Duty of information: communicate clearly and transparently about the rights and duties of employees, as well as any changes that may impact their duties.
  • Duty to respect privacy: ensure the protection of employees’ personal data, in accordance with the GDPR and national data protection legislation.
  • Duty of organization and discipline: ensure a structured work environment, with clear and well-defined rules.
  • Duty of participation and active listening: promote the involvement of employees in decisions that affect their working conditions.

 

EMPLOYEES DUTIES

According to Article 128 of the Labour Code of Portuguese law, TRH employees have the following fundamental duties:

  • Duty of care: perform their duties diligently and responsibly, promoting the quality and efficiency of work.
  • Duty of loyalty: respecting the interests of the company, acting with integrity and avoiding conflicts of interest.
  • Duty of confidentiality: keep confidential the company’s commercial and strategic information, protecting sensitive data.
  • Duty of obedience: comply with the instructions and guidelines defined by hierarchical superiors, except when they are illegal or violate fundamental rights.
  • Duty of attendance and punctuality: attend work regularly and comply with the established schedules.
  • Duty of safety and health at work: respect hygiene, safety and health standards, ensuring a safe work environment for all.
  • Duty of politeness and respect: treat colleagues, customers and partners with courtesy and respect, promoting a harmonious work environment.
  • Duty to maintain equipment and assets: correctly use the company’s resources and avoid damage to corporate assets. 
  • Duty to participate in job-related training: updating knowledge and skills whenever necessary for the efficient performance of the function. 

Failure to comply with these duties may result in disciplinary action, as provided for in applicable law.

CONFIDENCE

We expect our employees, partners, suppliers and other stakeholders to operate with the highest standards of ethics and integrity. The Code of Conduct does not eliminate the need for all of us to exercise good value judgment; it only makes it easier for each of us to do so. We all have a responsibility, to TRH and to each other, to work with integrity and common sense, as well as in accordance with the law. By behaving ethically correctly, you will be building a foundation for a stronger relationship between you and TRH. We trust our employees, partners, suppliers, freelancers and interns with a wide range of technologies and other tools so that they can do their job effectively. These tools must be used wisely. All assets, such as instruments, data, systems, equipment, materials, facilities or vehicles, shall be used only for the authorized and intended purpose. Employees, partners, suppliers, freelancers, and interns have a responsibility to prevent the forgery, distortion, misuse, improper access, destruction, or sabotage of platforms or client assets, documents, or other assets. They should also protect them from theft, neglect, misuse, and abuse. In addition, they must follow all applicable data security and information security laws and regulations. We expect intellectual property rights to be respected, so it will not be allowed to obtain, distribute or use unauthorized software or information without proper authorization. Such information should not be disclosed to anyone without the express permission of TRH. If in doubt, we suggest that you check with the TRH People Manager or the People&Culture Team (peopleculture@techremotehub.com).

COMPANY RESOURCES

The company’s resources must be used responsibly and exclusively for professional purposes. Improper use may result in disciplinary action. This includes equipment, information, working time, and the company’s intellectual property.

GDPR AND DATA PROTECTION

TRH is committed to complying with the General Data Protection Regulation (GDPR) and other legislation applicable to data privacy and confidentiality. All employees must: • process personal data lawfully, fairly and transparently, only for the specific purposes for which they were collected. • ensure that only the data that is strictly necessary is stored and processed, respecting the principles of minimization and limitation of retention. • ensure that personal data is protected from unauthorized access, loss, destruction or improper disclosure. Any data breach incident should be reported immediately to People&Culture Team (peopleculture@techremotehub.com).

CORRUPTION PREVENTION AND RELATED OFFENCES

TRH has a zero-tolerance policy against corruption, unjustified receipt and offer of advantage, embezzlement, economic participation in business, extortion, abuse of power, prevarication, influence peddling, laundering or fraud in obtaining subsidies, in short to any illicit practice that may compromise the integrity of the business. In this sense, it is expressly forbidden: • offer, promise, or accept improper payments, bribes, or any benefit that may influence the decisions of others. • use company funds for illicit or unauthorized purposes. • engage in any kind of favouritism or influence peddling. If an employee suspects or is aware of a situation of corruption, they must report it immediately through the Whistleblowing Channel.

CONFLICT OF INTEREST

Employees should avoid conflicts of interest. They must report on conflicts of interest related to their activities, whether actual or potential. Some examples of situations that can create conflicts of interest include:

  • loans or favours that the supplier, an employee or a family member receives through their relationship with our customers
  • undue advantages gained by acting on information learned through your relationship with our customers
  • business opportunities that belong to our Clients.
  • If you feel that you may have a conflict of interest, we advise you to raise the issue immediately with People&Culture Team (peopleculture@techremotehub.com).

OFFERS AND OTHER FORMS OF PERSONAL BENEFITS

While it may sometimes be appropriate to exchange business courtesies in certain locations, it is never appropriate to give or receive a gift or entertainment offering if it is extravagant, creates a sense of obligation, or is given with the intention of influencing a business decision. Generally, employees should not offer or receive gifts from the customer valued at more than € 100 per offer, and in the event that they receive them, they should communicate them to the TRH People&Culture Team so that this offer can be registered and a brief objective explanation of the circumstance verified can be made. In addition, employees should not offer gifts to Customer’s employees at any time during a Request for Proposal (RFPs) or other supplier selection process. As part of our commitment to Quality, TRH will not tolerate, permit or be involved in any form of corruption, extortion or bribery. We value what we deliver and have full confidence in the work done by our employees. If there are any doubts about the acceptance of a gift or invitation, the employee should consult their manager or the TRH People & Culture Team (peopleculture@techremotehub.com).

RESPECT

At TRH we comply with all employment and safety laws, we are human rights supporters and promote a diverse and inclusive workplace. We respect safety and well-being standards in the workplace. Hate-related or violent speech will not be allowed, promoted or facilitated, either in the workplace or through electronic communications. We hope that everyone is treated with dignity and respect. TRH will not allow any kind of harassment or bullying. If such acts or behaviours arise, they will be punished with internal sanctions that may lead to the termination of the contractual relationship with TRH. These sanctions may include:

  • Formal warnings
  • Disciplinary sanctions, including suspension or dismissal for just cause in accordance with article 328 of the Labour Code
  • Criminal liability in cases of corruption, fraud or abuse of power, which may lead to prison sentences under Portuguese law
  • Fines and administrative penalties imposed by the Corruption Prevention Authority, as provided for in Decree-Law No. 109-E/2021
  • Civil proceedings if non-compliance results in financial loss for the company or third parties
  • Specific sanctions for cases of moral or sexual harassment, which may include immediate removal of the employee involved and reporting to the competent authorities.
  • Dismissal for just cause in the most serious cases of violation of the rules of the Code of Conduct.

These measures ensure that all infractions are dealt with in a thorough manner and in accordance with the applicable legislation, reinforcing TRH’s commitment to ethics and transparency. If you have witnessed this type of behaviour, we ask you to report it on the Whistleblowing Channel and share your testimony. All information shared will remain confidential.

WHISTLEBLOWER PROTECTION CHANNEL

TRH has implemented a secure and confidential Whistleblowing Channel to allow employees, partners and third parties to report infractions, irregularities or any unethical conduct without fear of reprisal. 

  • Complaints can be made through the Whistleblowing Channel link
  • Confidentiality about the identity of the whistleblower is guaranteed under the terms of article 18 of Law no. 93/2021, of 20 December, except for a legal obligation or court decision.
  • All complaints are registered and maintained for a minimum period of 5 years, and are auditable by the competent authorities.
  • The whistleblower receives confirmation of receipt of the report within 7 days.
  • Within a maximum period of 3 months, feedback will be provided on the measures adopted.
  • The handling of complaints will be done only by authorized persons, ensuring total confidentiality and protection of the whistleblower’s identity.
  • The whistleblowing channel complies with Law No. 93/2021, ensuring protection against retaliation.
  • Periodic audits are carried out to ensure the effectiveness of the channel and its legal compliance.

ENVIRONMENT

TRH is committed to protecting and respecting our environment. By being able to work remotely, all our employees are contributing to less air emissions and a smaller “environmental footprint”. We adopt practices that promote environmental and social responsibility, contributing to a positive impact on society and fostering sustainable practices in the daily lives of our employees.

NON-COMPLIANCE WITH THE CODE OF CONDUCT

Disciplinary measures may be taken against any person who violates the Code of Conduct, such as the initiation of disciplinary proceedings, in accordance with the provisions of the labour legislation, and the possible application of the sanctions provided for therein, namely reprimand, recorded reprimand, financial penalty, loss of vacation days, suspension from work with loss of remuneration and seniority, and dismissal without pay or compensation. For each infraction, a report is drawn up which includes the identification of the rules violated, the sanction applied, as well as the measures adopted or to be adopted, namely within the scope of the internal control system. We live by our motto: “Wherever you are, let’s grow together”!