05th July 2021
To our stakeholders:

I am pleased to confirm that COBA reaffirms its support of the Ten Principles of the United Nations Global Compact in the areas of Human Rights, Labour, Environment and Anti-Corruption.

In this annual Communication on Progress, we describe our actions to continually improve the integration of the Global Compact and its principles into our business strategy, culture and daily operations. We also commit to share this information with our stakeholders using our primary channels of communication.

Sincerely yours,
Fernando Prioste
CEO

The COBA Group ensures the respect and promotion of human rights, assuming that all its employees comply with occupational health, hygiene and safety rules, in order to prevent the occurrence of risks and harm to the health of employees.

COBA has just subscribed Valor T, a National Program related to the European Disability Forum, with the High Sponsorship of the Presidency of the Republic, which supports people with disabilities in the search and realization of their professional potential through a process of promoting employability focused on valuing the talent and merit of candidates and on monitoring and sharing opportunities by the Entities Employer. Next year COBA will hire candidates from the program.

The Group attempts on a daily basis, uninterruptedly and in a sustainable way, to ensure a healthy, safe and pleasant work environment, in a corporate climate of trust, and provides each individual with the adequate opportunities to develop their professional and personal competences.

The Group has a Code of Conduct and Ethics and any employee may address the Human Capital Direction directly for the purpose of clarifying their doubts about the application of the Code in concrete situations, whether in order to complain or to participate in any irregular situation that may be liable of posing as a violation of the standards set out in this document. Employees must subscribe the Code when they join the group and it is recalled frequently and made available again whenever revised.
There's also a Compliance and Integrity Provider - single person, independent from the upper management -, to whom can be addressed, through written letter or email, any communication of any irregularity / infraction to the Code or the Group’s policies and procedures.

Over the past year, one of the biggest concerns has been the adaptation of workplaces to protect employees from the COVID pandemic as well as the creation of conditions for better articulation between personal and professional life, taking into account the high challenges brought by the pandemic.
Each employee of the Group can address to the Human Capital Director (internal, dependent from the upper management) or to the Compliance and Integrity Provider (external, independent from the upper management), besides the legal authorities.
During the past year no situation has been reported to the Human Capital Direction concerning this issues.
The Compliance and Integrity Provider also produces an Annual Report with the occurrences. No situation has been reported in the past year.
During the past year the ACT (National Authority for Working Conditions), has also inspected the company and the installations without any abnormal situation being detected. This entity praised all the measures that were implemented as well as the care for employees.

The Group's principles are written and published in the Code of Conduct and in the Occupational Health and Safety Policy.
The Group daily seeks, uninterruptedly and in a sustainable way, to ensure a healthy working environment, in an organizational climate of trust and providing each individual with opportunities to develop their professional and personal competences.
In the course of their duties at the usual workplace or while traveling on duty, COBA’s staff are not allowed to practice any type of discrimination, whether based on its origin, gender, race, age, physical disability, political, religious or sexual orientation.
All salaries in the company are well above the national minimum wage and all the hires are carried out according to a comparative analysis with other employees in the company with similar experience and function.
Issues related to child labour, forced and compulsory labour never existed within the Group. These issues are also prohibited by the portuguese legislation.
The company will continue to stablish, implement and maintain an occupational health and safety management system in line with the good practices defined in the ISO 45001:2018 standard.
Also ensure the continuous improvement of the management system and the improvement of its performance in terms of safety and health, designing and adopting processes, practices and systems of safe work.

All the complaints can be made in the available platforms.
Also written in the Code of Conduct, all the situations of harassment at work, regardless of their type and form, can be reported to the Human Capital Direction are kept under strict confidentiality, namely the complainants, victims and witnesses.
The company trains and inform employees about the risks inherent in the work and measures to be adopted, making them aware of compliance with safety standards and also emphasize individual responsibility and accountability, at all levels of the organization for issues related to safety and health. The goal is to integrate Health and Safety in the daily's activity, compromising all employees and service providers.
The company has a non-sexual discrimination policy for many years, and the results are clearly visible in the evolution of its hierarchical structure. As a basic policy, it ensures equal treatment in hiring between men and women and equally remunerates equivalent functions.
Lines of support are also available for everyone: CITE – Commission for Equality in Labor and Employment [Comissão para a Igualdade no Trabalho e no Emprego] and ACT - Authority for Working Conditions [Autoridade para as Condições do Trabalho].

Several adjustments, improvements in working conditions, refurbishment of offices, change to ergonomic furniture, improvement in IT and remote access conditions and inclusion of specific COVID-19 protection measures were carried out during the last year.
No incidents were reported to the Human Capital Director or to the Compliance and Integrity Provider, as stated in the Annual Report, or even to the responsible for SST (Safety and Health at Work).
The Group employees were invited to respond to an anonymous organizational climate questionnaire in order to measure their perception of the company's effort. The results show, in a global way, a raise of satisfaction with an average between good and very good for most of the implemented measures.
Also de SST team ensures and enhance the performance of consultation and participation of the different employees.
The group was externally audited regarding hygiene, safety and health at work, and the final report demonstrated the company's commitment to these areas and the absence of accidents or situations worthy of investigation.

The company has an written Environmental Policy. This policy defines as goal for all its activities and the excellence of the services to be provided to its customers, developing them with the utmost respect for the environment.
The purpose is to Implement and maintain an Environmental Management System in line with the ISO 14001 standard, Comply with applicable environmental legislation, as well as other voluntarily assumed obligations; and Adopt good environmental practices aimed at the rational use of natural resources and the prevention of impacts on the Environment.
Replacement of all the windows and air conditioning equipment with more efficient ones, in order to save energy.

The company adopts good environmental practices aimed at the rational use of natural resources and the prevention of impacts on the Environment.
Annually establishes objectives and targets in terms of the Environment and take the necessary actions to pursue them.
Continuously raises awareness among employees to improve individual and collective environmental performance.
Informs and disseminates this Environmental Policy to interested parties (employees, suppliers, partners, customers and the community in general) conveying COBA's commitment to respect for the Environment.
Promote the use of public transportation and created a specific park for bicycles or scooters.

This environmentally friendly policy implemented some direct measures: no plastics (all the plastic bottles or glasses were banished; distribution of ceramic mugs to employees); green energy (when feasible, all the vehicles acquired have electric autonomy); Waste reduction (employees are advised to avoid wasting water and energy by turning off computers and lights after work); recycling program (garbage recycling program: paper, plastic, batteries, light bulbs, equipment, etc. - more than 49% of waste was recycled over the last year); efficiency: all existing lamps were replaced by LED (some even automatic) and purchased more efficient equipment.

Several internal and external audits were carried out, as part of the Quality and Environment audits and also within Health and Safety inspections.

The Code of Conduct and Ethics describes generally how should relations been conducted, with all the stakeholders, referring clearly:
Offers, payments or other benefits that may be interpreted as an expectation of possibly favoring a relationship with the company should not be accepted or made.
Any gifts that, received from third parties, exceed the mere courtesy or symbolic value and commercial insignificancy shall be refused and reported to the immediate superior, who shall in turn report it that to the Human Capital Direction for evaluation.
These rules are also applied to suppliers and partners with greater relevance and therefore, the Code is shared with them upon the definition of deals.
In the upcoming year the Code will be revised to include some additional specific details related to these themes, as well as direct references to national and international legislation.
In general, there is no systematic risk assessment of clients and transactions, since most of the contracts are based on public definitions or through multilateral agencies. However, risk assessments are carried out, both of customers and transactions, whenever they go beyond this definition.

The staff is encouraged to file a complaint on any matter or suspicion of misconduct.
In case the complainant chooses to remain anonymous, the Group has a Compliance and Integrity Provider. These communications are addressed by e-mail or written letter to the companies’ address, to the attention of the Provider.
The responsibility for anti-corruption policies belong to the company’s Board of Directors, which promote the Code’s execution and engagement of all employees.

For the reasons presented above, more specific training has not been required for employees with regard to anti-corruption practices.

During the past year no situation has been reported concerning this issues.
The Compliance and Integrity Provider (external) also produced an Annual Report with the occurrences. No situation has been reported in the past year.