Start Campus' corporate culture is guided by high ethical values, social responsibility standards, compliance and risk management principles, which ensure proper and efficient corporate governance.

Through its Code of Conduct, Start Campus establishes general ethical and deontological principles and guidelines, as well as the company's core values, based on a set of ethical rules that should guide the behaviour of all its employees in their relationships with each other, as well as in their relationships with customers, partners, competitors, suppliers, and all other entities that interact or establish an effective relationship with Start Campus, and which reflect its corporate culture.
Compliance with the guidelines set out in the Code of Conduct is essential, not only to ensure the protection of everyone, but also so that Start Campus is recognised as an example of excellence, responsibility and integrity, both nationally and internationally. Safety, compliance, sustainability (in its threefold aspect: planet, community and industry), business ethics and the enhancement and training of human resources are the fundamental values and main priority of Start Campus.

This Code of Conduct includes an Integrity Policy (Section 3.1), a Courtesy, Hospitality and Meals Policy (Annex A), a Conflict of Interest Policy (Section 15 and Annex B (form)), as well as a Whistleblowing Policy (Section 18 and Annex C).

In an effort to prevent corruption, Start Campus prohibits all practices of corruption in all its active and passive forms, including any attempts to engage in such practices. To this end, Start Campus has approved the Risk Prevention Plan for Corruption and Related Offences (PPR), committing itself to promoting full compliance with the Code of Conduct and the law, and to seeking best practices in terms of transparency. In accordance with these documents, the business and activities of Start Campus and its associated companies shall follow a structure of transparency, correctness, professionalism, rigour, good faith and full respect for the law.
 
Start Campus is committed to achieving excellence in the fight against and prevention of bribery, corruption and related offences, in particular those described in Annex I to this PPR, which represent a risk to the fundamental values, reputation and prestige of Start Campus, internal public peace, the safety and well-being of citizens and the stability of markets. Furthermore, Start Campus recognises that anti-corruption and similar policies are a fundamental tool for the implementation of a more robust, reliable, fair and inclusive democratic society.
 
Start Campus therefore prioritises assessment and management to prevent and mitigate the commission of these offences, in compliance with Decree-Law No. 109-E/2021 of 9 December, which created the National Anti-Corruption Mechanism and approved the General Regime for the Prevention of Corruption. In general, and when acting as an obligated entity, Start Campus intends for the PPR to be a reference tool for regulating the relationship between the members of the governing bodies and the people hired by Start Campus, thus constituting an essential element of the regulatory compliance programme. The adoption of this PPR aims to ensure compliance with the ethical standards that an entity such as Start Campus must follow and embody, governing relationships of trust and transparency with all persons and entities with whom it interacts, including, but not limited to, its employees and business partners.

With this PPR and other compliance policies, Start Campus fosters a culture of no tolerance for violations of this nature and encourages the identification and internal reporting of such violations by its employees in each business unit, highlighting the relevance of such conduct and its significant impact on the development of its business.

Start Campus' regulatory compliance programme includes, in addition to this PPR (and its Annexes I and II, which form an integral part thereof)

- The Code of Conduct (which includes the integrity policy, the courtesy policy, the conflict of interest policy and the whistleblowing policy);
- The training programme;
- The Whistleblowing Channel. 

In accordance with the most demanding international standards on Compliance and Human Rights, the Whistleblowing Channel is a key element in detecting and managing potential compliance risks, thus supporting Start Campus' commitment to promoting and respecting an ethical business culture.

Start Campus makes the Whistleblowing Channel available to all its employees, suppliers or third parties with whom it has a direct relationship and a legitimate commercial or professional interest, at all levels. The Whistleblowing Channel is a confidential ethics line for (i) reporting any violation of the Start Campus Code of Conduct, as well as any other internal conduct regulations and (ii) report any act or omission that is being committed in violation of applicable laws.
 
You can access the Whistleblowing Channel here 📢