Code of Ethics

Grupo IP | Código de Ética Infraestruturas de Portugal, SA (IP) is a public company, constituted in the form of a public limited company, which was created after merging the National Rail Network REFER - Rede Ferroviária Nacional, EPE and the Portuguese roadways company EP - Estradas de Portugal, SA, pursuant to Decree- Law No 91/2015 of 29 May 2015. This new company was created to design, plan, build, fund, maintain, operate, upgrade, expand and modernize the Portuguese road and rail networks, including the command and control systems for rail traffic. In order to achieve its strategic objectives, IP also holds three companies, namely, – IP Engenharia, SA, IP Património, Administração e Gestão Imobiliária, SA and IP Telecom, Serviços de Telecomunicações, SA – which together constitute the IP Group and bring together the necessary technical know-how, experience and resources to ensure that road and rail infrastructure operate smoothly. Considering the added responsibility the IP Group has to society and the population owing to the public interest inherent to its activities, the IP Group is required to pursue sustainable development and 1. Background 3 ensure legality, transparency and rigor, as well as to actively promote social responsibility by encouraging civic participation by its employees, a good working environment and a balance between personal and professional lives. AS such, the IP Group’s success in performing its activities and achieving its strategic objectives depends on all of its employees adhering to the ethical principles set out in this Code of Ethics which has been revised to reflect the improvements identified over the course of the four years that the initial version was in force, as well as subsequent changes in legislation. 1.1.OBJECT The main objective of the Code of Ethics is to present the IP Group’s principles to its respective employees and stakeholders and to define the rules of conduct that shape and add value to the actions of employees while performing their professional activities. 1.2.SCOPE 1.2.1. This Code of Ethics applies to all the employees of the IP Group, regardless of the type of contract and the position they hold in the professional hierarchy, including management and members of the corporate governance of the IP Group’s companies. 1.2.2. Without prejudice to compliance with the standards of conduct binding the IP Group’s