Closer’s Commitment to Compliance Program
Closer is committed to ensuring that its cultural values and the conduct of its activities are aligned with international best practices, the law and this Compliance Program.
To fulfil this commitment, Closer provides tools, namely a Whistleblowing system, through which Interested Parties may communicate actual irregularities (past or present) or potential irregularities (suspected or likely to occur) related to Closer’s activities, so that such concerns may be addressed appropriately and in a timely manner, while ensuring the confidentiality and anonymity of the whistleblower, should they so wish.
In situations where an Interested Party suspects that another party has committed, is committing or will commit an irregularity that violates the law or any component of the Compliance Program, that Interested Party must act in accordance with the provisions set out in this document.
On this page, you will find the Compliance Plan, links to relevant pages on the subject, and within these, links to the company’s full, officially signed documents, which are available to read and download.
You can read and download Closer’s full compliance plan here.
Compliance Plan
Introduction
At Closer – Software Development and Data Science Services (Closer), we value people who have freedom of thought and expression and who are not afraid to report non-conformities, irregularities, illegalities or unlawful acts/offences. In this way, we encourage everyone to engage in dialogue with us and foster a more transparent and ethical organisational culture.
Closer is committed to the strict compliance with ethical and legal standards in all its activities, requiring the CEO, directors, employees, consultants and stakeholders, meaning all Persons who work in and with Closer, to act in accordance with the applicable laws, regulations and policies, while observing high standards of personal and business ethics in the performance of their professional duties and responsibilities.
We are committed to carrying out our activities with honesty and transparency, expecting all employees (internal, external, interns or temporary staff), as well as shareholders, investors, clients, partners, suppliers and other interested parties, namely their subcontractors and third parties in general (Interested Parties), who interact with Closer, to maintain high ethical standards.
Accordingly, Closer has implemented this Compliance Program.
Our vision is to be a proactive and dynamic organisation that always acts with integrity and transparency as a service provider and employer, with our Compliance Program being based on the following principles:
We operate in strict compliance with all relevant laws and regulations;
We do what is expected of us;
We handle complaints and reports with diligence and seriousness;
We protect Employees against any suspicion of abuse.
Scope
This Compliance Program seeks to implement the rules established in Decreto-Lei n.º 109-E/2021, de 9 de dezembro, which establishes the General Regime for the Prevention of Corruption (RGPC), as well as Lei n.º 93/2021, de 20 de dezembro, which establishes the General Regime for the Protection of Whistleblowers (RGPDI), and applies to all persons professionally connected to Closer.
Ignorance or misinterpretation of the law does not justify non-compliance, nor exempt individuals from the sanctions established therein, under the applicable legislation.
This Compliance Program complements the provisions established in the RGPC and RGPDI and aims to raise awareness regarding the duty of care. It forms part of the Compliance Program adopted and implemented by Closer, which also includes the following elements. On the one hand, Closer established a set of measures and procedures based on this Compliance Program, configured as a unified document containing a Code of Ethics and Conduct, a Risk Prevention Plan and a Whistleblowing Policy, with the purpose of ensuring more effective and demonstrable compliance with the law and internal rules, while contributing to a culture of integrity and ethical conduct in the development of Closer’s activities.
Closer has also implemented a training programme and a whistleblowing channel in order to prevent, detect and sanction acts of corruption and related offences carried out against or through the entity, and has appointed a Compliance Officer responsible for ensuring and monitoring the implementation of the Compliance Program, including the components referred to above. This role is carried out independently, permanently and with decision-making autonomy, and Closer ensures the availability of the internal information and the human and technical resources required for the proper performance of these duties.
Finally, Closer shall ensure the implementation and assessment of the rules set out in this Compliance Program through the implementation of legal assessment mechanisms and an anti-corruption manual. Employees are expected to contribute to the identification of non-compliant situations, assessing and avoiding potential conflicts of interest, as well as preventing any corrupt practices, whether active or passive, including facilitation payments or the creation, maintenance or promise of irregular or preferential situations.
Closer is also committed to communicating the Code and the Risk Prevention Plan through its internal channels and to reviewing these documents every three years or whenever there are changes to the company structure, legislative or regulatory amendments, or incidents that justify such review.
Objectives
- Establish procedures to prevent, detect and/or correct situations likely to constitute acts of corruption and related offences, as defined by law, in order to prevent financial and reputational damage to Closer;
- Encourage Interested Parties to report, in good faith and with reasonable grounds, what they believe to constitute an offence under the RGPC and the RGPDI;
- Identify problems in advance;
- Detect unlawful acts in other organisations;
- Strengthen the company’s reputation;
- Increase employee awareness;
- Enhance the confidence of Closer’s stakeholders;
- Ensure the receipt and handling of reports submitted in accordance with this code; and
- Protect whistleblowers against any acts of retaliation.
The Value of Compliance
In addition to financial sanctions, a compliance failure may damage an organisation’s reputation, harm its relationship with clients and negatively impact growth and profitability objectives in the foreseeable future.
Therefore, Compliance, as a concept encompassing all forms of regulatory and ethical compliance, is a necessary business obligation and its importance and complexity will only continue to grow.
Accordingly, our role is to mitigate risk for the organisation, but not in a way that limits its ability to operate as intended, innovate, and generate results and dividends.
Risk is rooted in behaviour, which is why alignment with the business is fundamental to fostering a culture of compliance built around ethical conduct. Doing this well makes the business more resilient and can become a differentiating competitive advantage.
Compliance Team
The Compliance team is composed of the Compliance Officer and the Ethics Committee.
Closer has appointed Joana Santos as Compliance Officer, responsible for regulatory compliance and, in particular, for all legal requirements associated with the RGPC.
The Compliance Officer promotes:
The preparation and implementation of a training programme for organisational integrity areas;
The preparation and updating of a Code of Ethics and Conduct, which forms an integral part of this Code;
The preparation and review, in accordance with legal requirements, of a corruption and related offences risk prevention plan, which forms an integral part of this Code;
The implementation of an assessment system for the Compliance Program;
The provision of elements that guarantee the right to information and transparency;
The implementation of measures that ensure neutrality and impartiality, preventing conflicts of interest;
The implementation of internal control procedures and prior assessment procedures (due diligence); and
The implementation of a whistleblowing channel, under the terms and with the characteristics imposed by the RGPC and the RGPDI.
Closer has also established a Closer Ethics Committee, responsible for analysing all reports and/or irregularities submitted within the scope of the Compliance Program.
The Ethics Committee is composed of the following members: Janete Costa (Head of Outsourcing), João Leal Fernandes (COO and DPO) and Woitek Szymankiewicz (Board Member).
Relevant links:
You can read and download Closer’s full compliance plan here.
