Ethics and Conduct

As a state-owned company, CP is committed to conducting its activities with responsibility, integrity, and transparency.

To ensure compliance with this commitment, internal processes are in place to align and guide the organization across all areas of its operations.

The Ethics Committee of the CP Group, CP-Comboios de Portugal, E.P.E., Fernave - Formação Técnica, Psicologia Aplicada e Consultadoria em Transportes e Portos, S.A., Ecosaúde - Educação, Investigação e Consultoria em Trabalho, Saúde e Ambiente, S.A. and Saros – Sociedade de Mediação de Seguros, Lda.. appointed the following members for the three-year period 2024-2026 on 1 May 2024:

Chair – Aires São Pedro;
Member – Eduarda Loureiro;
Member – Rosa Gomes;
Member – Hermenegildo Rico;
Member – Sílvia Dourado.

Its main mission is to ensure compliance with and dissemination of the Code of Ethics, promote the information and good practices contained therein, clarify doubts about the matters covered therein and issue opinions on issues related to its compliance. It also oversees the improvement of ethics in the governance model of each of the CP Group companies.

In terms of regulations, the CP Group approved the CP Group Code of Ethics and Conduct in January 2025. The code constitutes the principles and rules of ethics and conduct for the CP Group companies, which includes the structural values and ethical and professional principles that guide ethical behaviour, which all employees. members of their governing bodies, employees, suppliers and partners must observe in the performance of their duties and in their internal and external relations whenever the CP Group is involved, contributing to the dignity of the service provided by the companies of the CP Group, to their credibility and prestige and to the strengthening of the ethical infrastructure of the Public Administration.

The CP Code of Ethics was revised in 2025 to incorporate a series of fundamental Company values and behavioural guidelines for its employees regardless of the bond they have with CP group.

The mission of the Ethics Commission, which answers directly to the Chair of the Board of Directors, is, among others, to ensure that everyone if aware of the Code of Ethics and complies with it, to encourage the consolidation and knowledge of good practice in this area, to clarify any doubts about the matters it covers and to issue professional opinions related with its compliance. It also aims to increase ethics in the Company governance model.

View the CP Code of Ethics.

CP, as the entity responsible for processing personal data, adopted a Privacy Policy in 2018, which establishes how it processes Personal Data, ensuring compliance with the principles of the General Data Protection Regulation (GDPR) regarding lawful, fair and transparent processing, with purpose limitation and minimisation of the data processed, its accuracy and compliance with data retention limits, as well as ensuring its integrity and confidentiality.

Considering the obligations arising from the GDPR regarding the processing of personal data and the free movement of such data, CP has appointed the Data Protection Officer (DPO) of CP, FERNAVE - Formação Técnica, Psicologia Aplicada e Consultadoria em Transportes e Portos, S.A. (FERNAVE), da ECOSAÚDE - Educação, Investigação e Consultoria em Trabalho, Saúde e Ambiente, S.A. (ECOSAÚDE) and SAROS – Sociedade de Mediação de Seguros, Lda. (SAROS)

The DPO’s duties are:

to inform and advise CP and its employees on their obligations under data protection legislation;
to monitor CP’s compliance with all data protection legislation, including raising awareness and training staff involved in processing operations;
to ensure that audits are carried out;
to raise awareness among employees of the importance of early detection of security incidents and the need to inform the security officer immediately;
to provide advice, when requested, on data protection impact assessments and monitoring their implementation;
to ensure relations with data subjects in relation to data protection;
to cooperate with the National Data Protection Commission and act as its contact point on issues relating to processing.