policies & Certifications

Considering the analysis of the internal and external contexts, the identified stakeholders, and the attributes of our products and services, the Quality Management System implemented in the company, in accordance with the NP EN ISO 9001, NP EN ISO 14001, and SA 8000 standards (1), has as its scope the activities of Consulting and preparation of international and national projects, which consists of:

• Design and implementation of public policies at international and national level, technical assistance to other organisations;
• Design and strategic planning of international and national projects;
• Design, execution, construction, and monitoring of projects;
• Provision of environmental consultancy services and development of solutions in the areas of Energy, Renewable Energy, Water, Climate Change, and economic studies and studies of investments in energy and water.

This policy was approved by the Managing Partners of S317 Consulting on March 24, 2021.

The continuous improvement and quality of our processes are part of the responsibility of the company and of each of its employees, ensuring compliance with the NP EN ISO 9001: 2015 standard, as well as the legal and regulatory requirements applicable to the activity, following these vectors:

1. Customer orientation: we have a service-oriented to each client and always with the intention of generating value for our customers;
2. Development of competencies: we provide to our employees training and skills development that are necessary to carry out their activities, and all those that we consider necessary for the renewal and innovation of our value chains;
3. Raising employees’ awareness for continuous improvement: we actively raise awareness among all our employees about the importance we all have in building our future and in particular the responsibilities we all have in learning, improvement, and ongoing evolution;
4. Promote partnership relations: we strive to develop cooperative links and promote true partnership relations with society in general and in particular with our suppliers, in order to improve the levels of performance and customer satisfaction we serve.

This policy was approved by the Managing Partners of S317 Consulting on September 7, 2017.

It is a commitment of S317 Consulting, as a consultancy firm that works in the water, energy, and environment sectors, to integrate protection and respect for the environment in the strategy, management, and continuous improvement of its management processes and responsibility towards their Compliance obligations.

This commitment, which involves the entire company, implies acting consciously, integrating measures for the protection and conservation of the environment, aiming to control, prevent and minimise damage to the environment in accordance with the Sustainable Development Goals for the year 2030.

The Management recognises the importance of its activity for the environment, and therefore defines its Environmental Policy as:

• Development of technical solutions that contribute to environmental preservation and sustainability;
• Development of technical knowledge contributing to the development of a robust environmental knowledge society;
• Taking operational actions that mitigate the ecological footprint.

This policy was approved by the Managing Partners of S317 Consulting on March 24, 2021.

Within the scope of Social Responsibility, S317 Consulting is committed to continuously improving its social performance, integrating the requirements of the SA 8000 Standard into the company’s management to develop a socially responsible activity and assumes the company’s commitment to the 9 requirements of the SA8000 Standard.

1. Child Labour: The Company does not use child labour nor does it accept such practices by its stakeholders.
2. Forced and Compulsory Labour: The Company does not use forced or compulsory labour, nor does it accept such practices by its stakeholders.
3. Safety and Health: The Company provides its employees with health and safety conditions in the workplace, minimising the risks inherent to the activity, strictly complying with the National Legislation in this matter, requiring the same practices from its stakeholders.
4. Freedom of Association and Right to Collective Bargaining: The Company respects the right to freedom of association and the right to collective bargaining, demanding the same practices from its stakeholders.
5. Discrimination: The Company does not allow internal practices of discrimination or accept such practices by its stakeholders.
6. Disciplinary practices: The Company does not allow internal practices of corporal punishment, mental or physical coercion, and mental abuse, nor does it accept such practices by its stakeholders.
7. Working Hours: The Company complies with the laws and standards applicable to its activity, requiring the same practices from its stakeholders.
8. Remuneration: The Company guarantees that monthly salaries are in line with national regulations, requiring the same practices from its stakeholders.
9. SA8000 Management Systems: The Company has integrated the requirements of the Social Responsibility Management System into its Management System, committing to comply with them.

The established policies apply to the entire company, as well as to entities that work in partnership or on behalf of S317 Consulting, nationally and internationally, always complying with local legislation and regulations, always ensuring compliance with the legislation promoted by the United Nations and World Labour Organisation, as well as requirements that may be determined and accepted by the organisation, its partners, customers, suppliers, subcontractors, and other relevant stakeholders, within the scope of Social Responsibility.

For further insights on social responsibility, please contact SGS, our Certifying Entity using the following email: [email protected]

Additionally, here is the email of the accrediting entity: [email protected]

S317 Consulting recognises the benefits of cultural diversity as a strategic part of the company. These benefits result mainly in the enrichment of management models, improving the quality of decision-making processes, through the plurality of knowledge, experience, abilities, and skills of employees and also in improving performance, increasing competitiveness and reputation of the company.

S317 Consulting is committed to efforts to promote diversity inside the organisation, especially in relation to the following criteria:

• Ensure compliance with local and international law, on equality and diversity, especially of non-discrimination and equal opportunities, arising from the Law and other applicable regulations, as well as the principles of the company’s Code of Ethics and other policies ;
• Ensure equal opportunities and treatment, including by age, sex, education, and previous work experience;
• Promote respect for human integrity and individual aspects of each employee;
• Ensuring an internal structure that reflects the ideology and the corporate philosophy based on diversity;
• Enhance an environment that values the social, ethnic, physiological, cultural, gender diversity and does not tolerate discrimination and differential treatment;
• Ensure representation of various areas of knowledge in the company, in terms of qualifications and skills, given the growing importance of a multidisciplinary approach in the performance of teams;
• Efforts to promote adequate representation of women and men;
• Promote awareness-raising measures internally and among stakeholders in order to promote good practices and monitor improvement plans in this area.

The Diversity Policy was approved by the S317 Consulting Managing Partners, on December 28, 2018.

This Privacy Policy presents the process of collecting and using personal data, as well as the safeguard and security measures adopted in the treatment of such data. S317 Consulting recognises the importance of privacy and we ask you to carefully read this Privacy Policy to know how your Personal Information will be handled when using our website. The website www.s317consulting.com is owned by S317 Consulting, LDA. with headquarters at Rua Rodrigues Sampaio nº31, 2º DRT, 1150-278 Lisboa, Portugal.

1. Data collection

Whenever it is necessary to collect personal information, the use of this information will be carried out in compliance with the applicable legislation in force for the Data Protection Policy imposed by the National Data Protection Commission (CNPD), to ensure the confidentiality and security of personal data provided.

The collection of personal data (name, email address, telephone contact), is applicable in commercial consultations and/or service agreements. The entity responsible for the collection and processing of personal data is S317 Consulting.

2. Use of the information collected

S317 Consulting undertakes to comply with the rules of personal data processing in force in Portugal.

The data collected data is exclusively for the use of S317 Consulting, being guaranteed the privacy and protection of the data of the users.

3. Right of Access, Rectification, Cancellation, and Opposition

In accordance with the provisions of the law in force, any person may request access to their personal data, its content, as well as require its rectification, update or request its destruction, by written request addressed to S317 Consulting to the email address: [email protected].

4. Security and Data Protection

S317 Consulting undertakes to treat your Personal Information with the utmost privacy, confidentiality, and security and undertakes to adopt the necessary security measures to ensure the safeguarding of the personal data of users against their possible misuse or against access not authorised.

Notwithstanding, and since the Internet is not 100% secure, S317 Consulting cannot guarantee the security of any information it disseminates online, nor be liable for any loss or damage caused to the user as a consequence of the loss of confidentiality of the information.

5. Responsibility

On this web page, users will be able to find links that take them to other web pages outside the domain of S317 Consulting servers that may themselves collect data or request personal information. This Privacy Policy does not apply to third-party sites, so you should read the Privacy Policy of the third-party sites you visit, and we are not responsible for the content and information on those same sites.

6. Privacy Policy Agreement

It is understood that the user accepts the conditions of this privacy policy when entering their data.

We assume that the user consents to the automated processing and use of the data in accordance with the privacy conditions described in this document wData Trehen filling out the forms. If you do not accept the terms and conditions of this Privacy Policy, we ask you not to provide any personal information to S317 consulting through this site.

7. Changes to the Privacy Policy

S317 Consulting reserves the right at any time to update or revise this Privacy Policy in order to adjust it to any legislative changes and/or other constraints. Any changes made will be published in this space, so the user should visit this area frequently to keep informed about the Privacy Policy in force.

The Management determines that data processing must be subject to the following principles (data protection policy):

a) determination, before data collection, of the purposes for their use, as well as their conservation and elimination;

b) identification of data subjects (personal and non-personal) and determination of their interests and rights;

c) provision of information to the holders of personal data on the specific purposes for the use, limitation, and interruption of use, rectification and conservation, deletion of data and right of opposition, when the holders are not aware of the information;

d) obtaining authorisation from the holder of personal data for their use, especially when they are or may be used for the purpose of offering goods and services, even if free of charge, or for analysing and controlling their behaviour;

e) interruption of the processing of data that no longer meet the purposes for which they were collected or when requested by their holders;

f) deletion of data when they are not used or at the request of their holders, subject to the applicable legal/fiscal permissions.

g) data protection through logical, physical, and other security measures.

These principles apply to data collected directly (personal and phone contacts) or indirectly (postal correspondence, own internet sites, and social networks), either in verbal and/or written forms (registration/information forms; postal mail, advertising, emails, posts, and others).

The Management determines that all data held and kept by the organisation must be treated lawfully, loyally, and transparently, within the principles of security and responsibility referred to above in this section and in the “Information Assets”.

The data collected from its holders and kept by the organisation is structured accordingly to “Mapping the Value Network: Transactions”.

The company does not appoint any Data Protection Officer, as there is no need for regular and systematic control of the data based on their nature, scope, and purpose, as well as the small scale of the data collected and stored.

This policy was approved by the Managing Partners of S317 Consulting on March 17, 2021.

PRESENTATION OF THE INTEGRITY POLICY

Introduction

S317 Consulting operates in accordance with high ethical standards, integrity and respect for the applicable legislation and its regulations, and it is its responsibility to ensure that all businesses and partnerships comply with the values and ethics of the company, in order to become a reference of good practices. This integrity policy aims to reduce the risk of employees and stakeholders to commit any infractions imposed by the current legislation and thus, reduce the possibility of damages to the reputation of the company.

Goals

S317 Consulting aims to conduct all its activities and partnerships with integrity, transparency and professionalism, complying with all applicable laws and adopting the guiding principles outlined in the company’s Code of Ethics, not being tolerated to its employees and business partners, behaviours that undermine these principles.

Receiver

Any employee of S317 Consulting and any person or entity who provides services to the company must, under all circumstances, conduct themselves by the principles described in this policy.

Disclosure

The integrity policy is available as an electronic version on the S317 Consulting website. The company also undertakes to provide the integrity policy to all its suppliers which shall act in accordance with the rules described.

Awareness and Training

Management will promote awareness-raising actions, which it deems necessary, in order to raise awareness and clarify the integrity policy.

PRINCIPLES OF ACTION

Anti-Corruption Policy

S317 Consulting has adopted a zero-tolerance policy towards corruption and bribery, and prohibits, under any circumstances, corruption or bribery in any of the countries where it operates.

The company values its reputation in terms of integrity, and corruption or bribery is a threat to the business and its values and, in that sense, its employees shall not request or accept bribes or benefits, as a counterpart to the practice of any act or omission.

In some insolvency proceedings, if it is found that the company has participated in corruption situations, it can be excluded from public or private tenders without being able to re-apply. Employees may also be subject to legal proceedings.

S317 Consulting regularly competes with projects of international development agencies, such as the World Bank, which follow strict anti-corruption guidelines and require applicants to respect ethical standards and practices in projects. If they do not meet these requirements, candidates can be blacklisted and cannot enroll in future projects.

Conflict of Interest Policy

S317 Consulting recognises and respects the right of all employees to make investments or businesses outside the company, provided that the activities are consistent with the obligations stipulated in the agreement. Each employee must inform the management about economic activities outside the workplace, assuming loyalty behaviour towards the company, thus avoiding any situation that could lead to a conflict of interest.

Training Policy

S317 Consulting has a training plan in order to form the company’s employees on the content and practical aspects of this policy at the time of the employee’s entry into the company, in the review of policy, and whenever the company deems it necessary.

Communication Channels and Complaints Policy

Employees are encouraged to report any misconduct or suspected misconduct that is not in compliance with company principles and values. Complaints must be submitted to management so that they can be duly evaluated.

Third Party Contracting Policy

The company hires others making sure, through information collected about the individual or company, that they share values and principles like those of the organisation, thereby reducing the risk of involvement in illegal practices.

This Integrity Policy was approved by the Managing Partners of S317 on December 28, 2018.

S317 Consulting company considers the safety and health of all employees, stakeholders, and the communities in which it operates, a priority objective, which should always be present in all company management processes. The well-being of employees and stakeholders is a priority for the company’s success.

The company protects its employees and stakeholders taking responsibility to maintain healthy workplace and safe and at the same time, promoting best practices and safe behaviour, minimising accidents, injuries, or illnesses.

The company priority is safety and, therefore, requires all employees to take an active role in promoting a safe and healthy environment.

Guiding principles of health and safety practice in S317 Consulting:

1. Ensuring a safe and healthy working environment for its employees and stakeholders, ensuring compliance with national and international legislation and good practice;
2. Ensure adequate safety, comfort and efficiency in all company facilities and equipment;
3. Promoting training and information of employees about the risks involved in activities, sensitising them to comply with the safety standards;
4. Ensure that all employees and stakeholders are responsible for ensuring that their activities take place within the required parameters, meeting the legal requirements, standards and procedures, reducing the risk.
5. Regularly review the measures established for the prevention of occupational accidents, occupational diseases and health promotion of employees and stakeholders;
6. Promote the principle of continuous improvement, always monitoring the results and make necessary changes where necessary;
7. Involve all employees, contractors, suppliers and stakeholders in the continuous improvement of performance in terms of safety and health at work and on the effectiveness of the policy;
8. Maintain safety procedures updated and regularly reviewed in accordance with applicable regulations.

The Health and safety policy at Work was approved by the S317 Consulting Managing Partners on December 28, 2018.

Stakeholders represent all individuals or groups that influence and are influenced by the company’s activity and, for this reason, we advocate and promote transparent honest and empathetic relationships in order to gain their trust.

S317 Consulting approach to stakeholders involves the following steps:

1. Identification and mapping of key stakeholders for S317 Consulting;
2. Communicable, open, transparent, and rigorous communication with stakeholders;
3. Identification of stakeholder needs and expectations.

(1) Identification and mapping of key stakeholders for S317 Consulting

It is fundamental to know who the stakeholders are to understand their importance to the organisation. This is strategic information for decision-making.

(2) Communication accessible, open, transparent, and accurate with stakeholders

S317 Consulting employees interact with the company’s stakeholders in an integrated, rigorous and transparent manner, based on the highest quality standards, fostering a collaborative relationship based on trust and the sharing of know-how and experiences, thereby facilitating the achievement of common objectives. The success of a company also depends on how it interacts with the community in which it operates.

Regular engagement with its stakeholders is crucial to enable S317 Consulting to position itself adequately in the face of its needs and perceptions, which in turn are constantly influenced by market conditions.

Our engagement strategy is made through four main guidelines:

1. Understand– Include in their strategies the interests of all stakeholders, as well as identify and classify stakeholders and how important they are to achieve organisational goals;
2. Communicate– Ensure that stakeholders have access to information through established communication channels;
3. Trust – Maintain a transparent, clear, and respectful relationship with the stakeholders, and ensure that the actions of S317 Consulting are based on the ethical principles of the company.
4. Collaborate – Build strategic partnerships that aggregate and share know-how and experiences, thus promoting the creation of shared value in a differentiating way.

(3) Identification of stakeholder needs and expectations

After identifying and mapping the stakeholders, it is essential, through continuous dialogue actions, to consult their needs and expectations and to evaluate them. The different stakeholders represent a certain type of interest in the process, and for this reason, it is important to identify, manage, monitor and respond to those expectations. The success of any company depends on the participation of its stakeholders and therefore it is necessary to ensure that its expectations and needs are known and considered by the managers.

This Stakeholder Relationship Police was approved by the Managing Partners of S317 Consulting on December 28, 2018.

S317 Consulting does not allow either support the utilisation of child labour. This means that any work developed by a child with minor age than the ages specified in the definition of a child, with an exception of what is foreseen in the Recommendation 146 of OIT: any person less than 15 years old, unless the minimum age for labour or mandatory education is stipulated higher by local law, in which case the highest stipulated age applies to the localisation in question.

In a case where is verified the existence of child labour among the collaborators or interested national and international parties of S317 Consulting, the following measures will be adopted:

• Immediate protection response, removing the child affected by the dangerous situation.
• All the support and needed actions to ensure the safety, health, education, and development of children that were exposed to child labour, and that the child labour practice has ended.
• Investigation in close cooperation with the affected parties and, when in need, specialists.
• Demand to the collaborator or the interested party to present one corrective action in order to solve the identified case as in non-compliance with our social responsibility policy, to correct the identified situation, and avoid the repetition of the situation in the future. This corrective action needs approval and monitorisation by S317 Consulting.
• Review and update policies, procedures, and action plans that contribute to the situation.
• In the case where the partner or supplier refuses to present or comply with a corrective action, report the situation to the competent authorities of the country and disqualify the collaborator or interested party (or end up with the partnership).

The organisation may employ young workers, only when they are subjected to their legal education obligations, and they can only work outside their school time. Under any circumstance, the school time, work, and commuting of these young workers can exceed 10 hours per day, and in any case, they should work more than 8 hours per day. They cannot work the night shift.

1. Presentation of the Code of Ethics

a) Introduction

S317 Consulting Code of Ethics is an alliance that the company establishes with its stakeholders and human resources. Whatever the geography, all employees of S317 Consulting must respect not only the laws and regulations but also the Code of Ethics of the company. This is based on a set of principles and rules that guide the behaviour of all S317 Consulting employees and all that relates to the company.

b) Objective

This Code aims to promote and encourage the adoption of operating principles and behavioural rules defined in the Code, namely the values of S317 Consulting in the relations of employees with each other, with the company, and with other stakeholders.

c) Receivers

Any employee of S317 Consulting and any person or entity providing services to the company, must always conduct themselves by the principles described in this Code.

d) Disclosure

The Code of Ethics is distributed to all employees of S317 Consulting and is still available as an electronic version on the S317 Consulting website. S317 Consulting is committed to providing the Code of Ethics to all its suppliers which shall act in accordance with the rules described.

e) Training and awareness

Management will promote awareness-raising actions, which it deems necessary, in order to raise awareness and clarify the Code of Ethics.

2. Principles of action

S317 Consulting conducts its activity in accordance with national legislation and international best practice but also based on the principles of this Code of Ethics. These principles should guide the conduct of employees in their relationships with the market, and especially with the communities in which they operate and with whom they interact.

The principles that guide S317 Consulting are described below:

a) Integrity

To act with honesty, reject all forms of fraud and corruption, and refuse to intervene in situations where there is, or may be, a conflict of interest.

b) Professionalism

Responsible and dedicated professional performance, based on know-how and using the most appropriate techniques and the necessary effort to fulfil the tasks of each employee, with the pursuit of operational excellence and the company’s development.

c) Human Dignity and Respect for People

Valuing life and affirmation of citizenship, respecting the social and cultural diversity of people with equality, equity, and justice without discrimination of social, cultural, gender, age, sexual orientation, religion, ethnicity, political opinion, physical and health condition.

d) Good faith

To act, with the stakeholders and, in general, with society, in a confident, correct, rigorous and transparent way.

e) Confidentiality:

Keep the information that the employee has access to in the exercise of his duties confidential. All information will be treated as confidential so that it will not be disclosed to third parties, free of charge or onerous, or in any way disclosed without prior consent.

f) Loyalty

Promote the duty of loyalty and respect for the company, and among its employees, as well as the credibility and prestige of S317 Consulting.

g) Legality

Always act in accordance with applicable law and regulations, avoiding any conduct that could harm the reputation and integrity of the company.

h) Prohibition of harassment

Promote prevention and combat all forms of harassment at work.

3. Environment

It is a commitment of S317 Consulting, as a consulting company in the water, energy, and environment sector, to integrate protection and respect for the environment in the strategy, management, and continuous improvement of its management processes.

This commitment, which involves the entire company, implies acting consciously, integrating protection measures and conservation of the environment in order to control, prevent and minimize damages to the environment in accordance with the Sustainable Development Goals set by 2030.

4. Relationship with Stakeholders

S317 Consulting is committed to engage to stakeholders by adopting the principles outlined in this Code of Ethics and integrating stakeholders’ concerns and needs into decision-making and management practices.

For this, S317 Consulting employees maintain appropriate communication channels and continuous dialogue actions with stakeholders, in order to allow the company to position itself adequately, to the needs and perceptions of those who, in turn, is permanently influenced by market conditions.

In this sense, in the relationship with the different stakeholders, S317 Consulting commits itself to:

• Achieve maximum satisfaction from all stakeholders;
• Scrupulously respect the confidentiality of the information and intellectual property of stakeholders;
• Respect contractual rights and commitments;
• Treat with respect, professionalism, and loyalty;
• Honouring commitments;
• Develop transparent and customized business proposals;
• Share information;
• Promote a spirit of cooperation and collaboration in relations with stakeholders;
• Respect the rules of the market, promoting fair competition;
• Provide a safe and healthy work environment;
• Promote the efficient use of energy and the adoption of more sustainable lifestyles.

5. Conduct in business

S317 Consulting and its employees are committed to creating value for the company, acting in accordance with the principles described in this Code of Ethics, providing an integrated and honest management in the following topics:

a) Legislation

Comply with applicable laws and regulations, the company activity, as well as the requirements that the company subscribes to.

b) Use of company resources

Employees are expected to monitor the company’s assets, made available for the performance of their duties, and to ensure that they are not damaged or misused.

c) Data processing and information

S317 Consulting recognizes the importance of confidentiality and privacy of information, not disclosing any documentation that has not been previously authorized for disclosure.

d) Conflict of interests

S317 Consulting recognizes and respects the right of all employees to undertake investments or business outside the company, provided that such activities are compatible with the obligations stipulated in the contract. Each employee must inform management about the economic activities outside the workplace, assuming a loyal behaviour towards the company, thus avoiding any situation that could lead to a conflict of interest.

e) Illegal business activities

S317 Consulting and its employees have the utmost care and attention to avoid being involved in criminal activities. As a preventive measure, all employees shall check available information on business partners and suppliers in order to verify its suitability.

f) Corruption and bribery

All S317 Consulting employees maintain relationships inside and outside the company with integrity, honesty and transparency S317 Consulting does not tolerate any behaviour that involves the promise or the direct or indirect supply of money or service, from which the company or employee can get any advantage.

This Code of Ethics was approved by the Management of S317 Consulting on December 28, 2018.