Code of Conduct & Ethics

M.C. Rabaçal & Aragão, Lda is committed to ensuring that all its operations — from the reception of the olives to the packaging and dispatch of the oil — fully respect the human rights, safety, dignity and well-being of workers, suppliers, visitors and the surrounding community.

This Code is inspired by the standards of the International Labour Organization (ILO) and the Universal Declaration of Human Rights, ensuring that the mill meets the most demanding applicable requirements.

The company is committed to:

• Implementing ethical and transparent labour practices.
• Ensuring safe working conditions.
• Protecting the environment and natural resources.
• Maintaining a culture of integrity, responsibility and continuous improvement.

• Worker(s): All company employees, permanent or seasonal, including foreign or migrant workers.
• Facility: The mill, warehouses, olive reception areas, production lines, packaging and support areas.
• Supplier: Entities that provide olives, packaging, materials, services or equipment.
• Subcontractor: Any external entity performing activities related to production, maintenance, cleaning, transport or specialised services.
• Goods: Olive oil and all derived products packaged and marketed by the company.
• Unauthorised Subcontracting: Any transfer of production or packaging to third parties without prior approval from Costco.

M.C. Rabaçal & Aragão, Lda ensures that:

• The entire supply chain complies with this Code and applicable legislation.
• All suppliers and subcontractors are assessed and approved in advance.
• Full traceability of the origin of olives, materials and packaging is maintained.
• Any homeworking practice is prohibited, unless legally authorised and duly documented.

The company maintains:

• Records of workers, contracts, schedules, wages and training.
• Legal licences, authorisations and certifications.
• Safety, health, environmental and audit records.

The company ensures that:

• It does not employ minors.
• Workers under 18 do not perform hazardous tasks, such as operating machinery, moving heavy loads or working night shifts.

The company ensures that:

• It does not use forced, coerced or prison labour.
• Workers retain control of their personal documents.
• No recruitment fees are charged.
• Freedom of movement is guaranteed.
• Subcontractors fully comply with these standards.

The following are prohibited:

• Physical, verbal, sexual or psychological abuse.
• Threats, coercion or corporal punishment.
• Abusive disciplinary practices or unlawful fines.

The company maintains clear disciplinary policies and records of all actions.

A. Terms of Employment

• All workers receive a written contract.
• No pregnancy, HIV or other discriminatory tests are required.
• The company verifies the legality of employment status.
• Personal data is protected.

B. Wages and Benefits

• Full compliance with the minimum wage and payment of overtime.
• Complete and transparent pay slips.
• Monthly payment or as required by law.
• Legal benefits ensured (Social Security, holidays, parental leave, sick leave).

C. Working Hours

Normal working hours at M.C. Rabaçal & Aragão, Lda fully comply with the Portuguese Labour Code, which establishes 8 hours per day and 40 hours per week. The company ensures that:

• Total normal and overtime hours do not exceed Portuguese legal limits, including weekly average limits.
• At least one day of rest is granted in each seven-day period.
• “Off-clock” work — work performed without record, authorisation or pay — is not permitted.
• Workers may refuse overtime without any penalty.
• Where required by law, formal authorisations for overtime are obtained.

D. Non-Discrimination

• Discrimination on the grounds of gender, age, origin, religion, sexual orientation, disability, political opinion or any other personal characteristic is prohibited.

E. Freedom of Association

• Workers may join or not join trade unions without retaliation.

F. Foreign or Migrant Workers

• Full compliance with labour and immigration laws.
• Threats of deportation or abusive dismissal are prohibited.

G. Grievance Mechanism

• Confidential and anonymous system for internal reporting.
• Recording and follow-up of all complaints.

• Mandatory training in safety, hygiene and machinery handling.
• Clear signage, unobstructed emergency exits and annual drills.
• Adequate fire extinguishers and monthly inspections.
• First aid available on all shifts.
• Adequate ventilation in extraction, filtering and packaging areas.
• Free personal protective equipment (gloves, masks, goggles, safety footwear).
• Clean sanitary facilities, separated by gender.
• Drinking water always accessible.
• Accommodation (where applicable) in line with legal requirements.

• Responsible handling and disposal of waste, pomace and olive mill wastewater.
• Prohibition of illegal discharges.
• Encouragement of recycling.
• Minimisation of environmental impact in the mill's operations.

• Documented policies and procedures.
• Appointment of officers responsible for quality, food safety, environment and occupational safety.
• Continuous monitoring of compliance with the Code.

The company accepts internal, external and Costco audits, ensuring:

• Full access to the facilities.
• Documentary transparency.
• Confidential interviews with workers.
• Prohibition of retaliation.

The company prohibits:

• Bribery, corruption or falsification of records.
• Gifts, favours or offers to auditors or Costco representatives.
• Retaliation against whistleblowers.

• Critical violations lead to immediate action and may result in termination of the business relationship.
• Other violations require corrective action plans.
• Unauthorised subcontracting may result in cancellation of contracts.

The company provides an internal reporting channel.

All workers and partners of M.C. Rabaçal & Aragão, Lda must know, understand and comply with this Code. Ethical commitment is an essential part of the company's identity and of the trust of our customers.