PT / EN

Risk Prevention Plan for Corruption and Related Offenses

SOAP – Só Apresentações Lda
Review Date: October 2025

Introduction

This Risk Prevention Plan for Corruption and Related Offenses aims to identify, prevent, and mitigate corruption risks and related offenses within SOAP – Só Apresentações Lda, ensuring integrity, transparency, and accountability in all company operations.

Objectives

  • Prevent Acts of Corruption:Implement effective measures to prevent corrupt practices at all organizational levels.
  • Promote Ethics and Integrity:Foster a culture of ethics and integrity among all employees.
  • Ensure Legal Compliance:Guarantee compliance with all applicable laws and regulations.
  • Promote Transparency and Accountability:Reinforce operational transparency and personal responsibility in all actions.

Plan Structure

  1. Risk Assessment
  2. Preventive Measures
  3. Monitoring and Control Procedures
  4. Training and Awareness
  5. Reporting and Investigation
  6. Review and Continuous Improvement

1. Risk Assessment

Identification of Risks

Critical areas include Finance, Procurement, Contracting, Commercial, Marketing, and Communication.

Main identified risks:

  • Payment or receipt of bribes
  • Financial fraud
  • Conflicts of interest
  • Manipulation of contracts
  • Undue favoritism in hiring or contracting processes

Impact and Probability Assessment

  • Impact:measures the potential harm or loss to the company.
  • Probability:assesses the likelihood and frequency of occurrence of each risk.

2. Preventive Measures

Policies and Procedures

  • Code of Conduct:clear implementation of ethical and behavioral standards.
  • Conflict of Interest Policy:mandatory disclosure of potential conflicts of interest.
  • Gifts and Hospitality Policy:definition of limits and rules for accepting gifts or hospitality.

Internal Controls

  • Segregation of Duties:separation of critical functions to prevent fraud.
  • Internal Audits:periodic audits of company processes and practices.
  • Access Control:restriction of access to sensitive or confidential information.

3. Monitoring and Control Procedures

Continuous Monitoring

  • Transaction Oversight:regular monitoring of financial transactions to identify suspicious activity.
  • Periodic Reviews:regular reviews of processes, procedures, and internal policies.

Risk Indicators

  • Data Analysis:use of analytical tools to detect irregular or suspicious patterns.

4. Training and Awareness

Training Programs

  • Initial Training:ethics and anti-corruption awareness sessions for new employees.
  • Continuous Training:regular refresher courses for all employees.

Awareness Campaigns

  • Internal Communication:regular campaigns to reinforce a culture of integrity and ethical behavior.

5. Reporting and Investigation

Whistleblowing Channel

  • Anonymous Channel:establishment of a secure and confidential channel for reporting irregularities.
  • Whistleblower Protection:guarantee of protection against retaliation for good-faith reports.

Investigation Procedures

  • Impartial Investigation:clear and objective internal investigation procedures.
  • Corrective Actions:implementation of corrective measures when applicable.

6. Review and Continuous Improvement

Periodic Evaluation

  • Annual Reviews:annual review and update of this Plan.
  • Employee Feedback:integration of employee contributions into the improvement of the Plan.

Continuous Improvement

  • Policy Updates:continuous revision of internal policies based on best practices and lessons learned.

Conclusion

The Risk Prevention Plan for Corruption and Related Offenses of SOAP – Só Apresentações Lda is a dynamic document that must be continuously evaluated and updated to ensure its effectiveness and relevance. The active participation of all employees is essential to promote a culture of ethics, transparency, and accountability within the organization.