1. Framework
With the approval of Decree-Law No. 109-E/2021 of December 9 – General Regime for the Prevention of Corruption (RGPC) – entities as outlined in Article 2 are required to adopt and implement a Plan for the Prevention of Risks of Corruption and Related Offences (PPR).
According to Article 6.1, this plan must cover:
- Identification, analysis, and classification of corruption risks, including risks associated with the functions of management, operations, and administration.
- Preventive and corrective measures to mitigate the probability and impact of identified risks.
To fulfill these obligations, Work Squad has developed this PPR, ensuring full compliance with legal and ethical standards.
To oversee its implementation and supervision, [Designated Compliance Officer Name] has been appointed as Regulatory Compliance Manager (RCM) for Work Squad.
This PPR applies to all Work Squad operations, covering employees, service providers, trainees, and third parties engaged with the company.
2. Scope
Work Squad, established in 2019, specializes in temporary workforce placements, including recruitment, orientation, training, HR consultancy, and workforce management.
2.1 Values and Ethical Commitment
This PPR should be interpreted alongside Work Squad’s Code of Ethics and Conduct, which establishes the core ethical values governing all activities.
✔ Principle of Legality – Compliance with all applicable legal standards.
✔ Principle of Justice & Impartiality – Ensuring fairness and neutrality in decision-making.
✔ Principle of Equality – Non-discrimination in employment and business practices.
✔ Principle of Integrity – Upholding honesty, accountability, and professionalism.
3. Plan for the Prevention of Corruption and Related Offences
3.1 Methodology
To identify and assess corruption risks, Work Squad conducted internal risk analyses across all departments, evaluating:
- Probability (P) of risk occurrence
- Impact (I) of the risk on business operations
- Risk Level (NR = P x I)
Risk Probability Scale
| Probability | Description |
|---|---|
| High | Frequently occurring or ongoing risks |
| Moderate | Risks that occur occasionally but have significant potential |
| Low | Rare or unlikely risks, occurring in exceptional cases |
Risk Impact Scale
| Impact | Description |
|---|---|
| High | Severe consequences, significant financial or reputational damage |
| Moderate | Noticeable disruption to operations, requiring intervention |
| Low | Minor impact, no significant operational disruption |
Decision on Risk Levels
| Risk Level | Action Required |
|---|---|
| High | Immediate intervention required |
| Moderate | Requires mitigation in the medium term |
| Low | Acceptable risk, long-term monitoring required |
3.2 Risk Identification and Assessment
Preventing corruption requires a proactive approach, identifying and addressing risks before they occur. Work Squad has classified corruption-related risks into the following categories:
Table 1 – Categorization of Risks
| Type | Risk | Offence | Legal Reference |
|---|---|---|---|
| Corruption | Passive Corruption | Requesting or accepting benefits for improper actions | Article 8, Law No. 20/2008 |
| Corruption | Active Corruption | Offering benefits to influence decisions | Article 9, Law No. 20/2008 |
| Related Offences | Undue Receipt of Advantage | Accepting an unauthorized benefit related to duties | Article 372, Penal Code |
| Related Offences | Embezzlement (Peculato) | Misuse of company assets for personal gain | Article 375, Penal Code |
| Related Offences | Influence Peddling | Abusing influence for personal or third-party benefits | Article 335, Penal Code |
| Related Offences | Money Laundering | Concealing or disguising illicit financial transactions | Article 368-A, Penal Code |
| Related Offences | Fraud in Obtaining Subsidies | Providing false information to obtain benefits | Article 36, Decree-Law No. 28/84 |
| Related Offences | Misuse of Subsidized Funds | Using grants for unauthorized purposes | Article 37, Decree-Law No. 28/84 |
3.3 Prevention and Correction Measures
Table 2 – Preventive Measures Across Departments
| Department | Risk | Probability | Impact | Risk Level | Preventive Measures |
|---|---|---|---|---|---|
| All Departments | Conflict of Interest | Moderate | Moderate | Moderate | – Employees must disclose conflicts – Whistleblowing channels established – Internal conflict resolution policies in place |
| All Departments | Corruption & Undue Benefits | Moderate | Moderate | Moderate | – Enforce internal recruitment policies – Strict adherence to the Code of Conduct – Mandatory reporting of conflicts of interest |
| Legal & HR | Non-compliance with Code of Conduct | Moderate | Moderate | Moderate | – Regular training on ethics & compliance – Public availability of the Code of Conduct |
| Legal & HR | Lack of Review & Monitoring of PPR | Moderate | Moderate | Moderate | – Periodic updates to PPR every 3 years – Interim assessments for organizational changes |
| Finance & Accounting | Irregular Payments or Receipts | Moderate | Moderate | Moderate | – Clear financial policies on payments – Verification of invoices to avoid duplicate transactions |
| All Departments | Mismanagement of Company Vehicles | Moderate | Moderate | Moderate | – Implementation of a fleet management system – Proper record-keeping of vehicle assignments |
| Quality & Compliance | Lack of Professional Training | Low | Low | Low | – Conduct professional training in ethics & corruption prevention |
| All Departments | Whistleblowing & Risk Monitoring | Low | Low | Low | – Strengthen whistleblowing mechanisms – Provide clear communication on reporting procedures |
4. Compliance & Monitoring
Work Squad is committed to the continuous review and improvement of its PPR strategy. The Legal & Compliance Department is responsible for:
✔ Conducting annual reviews of corruption risks
✔ Ensuring timely updates to policies
✔ Monitoring the effectiveness of implemented measures
5. Reporting Violations & Whistleblowing Protection
Work Squad maintains a confidential whistleblowing system for reporting corruption-related risks. Employees and stakeholders can report:
📌 Via Online Platform – Available on the Work Squad website
📌 Via Email – [Insert Email Address]
📌 Directly to Compliance Officer – [Insert Contact]
All reports will be investigated promptly, and retaliation against whistleblowers is strictly prohibited under Law No. 93/2021.
6. Final Provisions
✔ This PPR is effective immediately upon publication.
✔ All Work Squad employees, partners, and stakeholders must comply with its provisions.
✔ Failure to comply may result in disciplinary or legal consequences.
For further details, contact the Regulatory Compliance Team at:
📧 [Insert Email]
📞 [Insert Contact Number]
