Article 1

(Compliance with law)

1. CEM and all its employees are committed to ensure the full conformity of their professional activities with the legislation of the Macau Special Administrative Region (MSAR) in force. Employees shall never carry out any action on CEM’s behalf that violates the rules and regulations applying to its activity.

2. CEM shall work in a spirit of collaboration with the MSAR’s Supervising and Auditing Authorities and shall not behave in a way that may hinder the Authorities from performing their supervising and auditing duties.

Article 2

(Ethics)

1. CEM ensures that the Code of Ethics shall be made available to all employees and that there will be channels for communication and resolution of doubts.

2. CEM’s approach towards the implementation of this Code of Ethics shall be pro-active, open and complemented by proper regulations.

3. CEM assumes this Code as the privileged tool in the resolution of ethical issues and ensures its concordance with the legal practices in force in MSAR.

Article 3

(Transparency, honesty and integrity)

1. CEM and all its employees shall act under the highest ethical standards of integrity, honesty and transparency, always standing above any suspicion.

2. Employees shall fulfill their professional obligations with competence, responsibility and care, striving for excellence even in difficult situations.

3. CEM and its employees shall agree to explain and clarify with total transparency their decision-making and professional performance whenever duly requested, provided that professional confidentiality is observed.

4. Employees are obliged to inform the Company in situations where conflicts of personal and Company interest may arise in dealing with suppliers, customers, individuals or organizations doing or seeking to do business with the Company. Employees should not use the Company’s name, logo, information or other properties to further personal interests.

5. Unless prior approval is given by the Company, employees should not directly or indirectly engage in any other business or occupation for reward, nor receive any commission or fee.

6. Employees having family relationships or similar should not exercise any professional activity that implies direct operational or hierarchical dependence, unless authorized by the Company.

7. Employees must report any conduct that may disregard this Code of Ethics. Confidentiality and legal protection of the reporting person is ensured in accordance with specific regulations, and a fair treatment will apply to the reported person.

8. Employees shall maintain confidentiality on all issues regarding the Company, its clients or suppliers. Information acquired in the course of their work shall not be disclosed except where it involves the interest of the Company or whenever consent is expressly obtained.

9. Employees should protect the Company’s property, which should not be used other than in business procedures, unless authorized by the Company.

Article 4

(Working environment)

1. CEM shall promote the correction, politeness, affability and professional dignity in the relationship among employees, as well as respect for the respective rights, sensitiveness and diversity.

2. Safety, health and well-being of employees are the very first priority of CEM. All employees must be aware of, follow and enforce hygiene and safety rules at work and report any misconduct.

3. Employees are expected to dress appropriately while on duty. Those who are required to wear a Company uniform at work must keep it in neat and tidy condition. The uniform must be returned to the Asset Owner Department or Human Resources Department upon leaving the Company.

4. Employees shall respect and encourage CEM values (Professionalism, Respect for the Community, and Respect for People) by promoting cooperation, individual responsibility and acceptance of diversity.

5. CEM is committed to develop internally an Environmental, Safety, Health and Quality culture by raising awareness, educating and training employees to carry out their activities in a responsible manner; and to promote awareness in the same areas amongst customers, contractors, suppliers and Macau society.

Article 5

(Development of human capital)

1. CEM shall take steps to afford to its employees professional satisfaction and motivation, paying fair remunerations, offering a safe and sound working environment and creating the right conditions for professional improvement throughout their careers.

2. Employees must make continuous efforts to improve and update their knowledge and skills and to make the most of professional training sessions promoted by the Company.

Article 6

(Human rights)

1. CEM recognizes that human rights should be considered fundamental and universal, based on conventions, treaties and international initiatives like the United Nations Universal Declaration of Human Rights and the International Labour Organization.

2. CEM shall neither use child or forced labour nor shall it consent to such practices by a third party that might do business with the Company.

Article 7

(Non-discrimination and equal opportunities)

1. CEM is committed to promote the respect for equal opportunities among all its employees or potential employees. All practices, policies and labour acts are focused on preventing discrimination based on race, sex, religion, marital status, disability, political orientation or opinions of any other nature, ethnic or social origin, place of birth or membership to unions.

2. CEM promotes the safeguard of moral integrity of all employees by ensuring their right to working conditions that respect their individual dignity. CEM tries to protect employees from psychological violence and condemns any discriminatory attitude or behavior or any action that contradicts their convictions, such as insults, threats, isolation, invasion of privacy or professional limitation.

3. CEM shall not permit either moral or psychological coercion, harassment or any other behaviour offending human dignity.

4. For the purpose of the previous number, harassment is deemed to be any unwanted behavior namely gesture, word or attitude carried out with reiteration and aiming or having as consequence to affect the dignity of a person or to create an intimidating, hostile, degrading, humiliating or destabilizing environment.

5. Harassment is moral when consisting in verbal or physical attacks of offensive or humiliating contents, or more subtle actions, comprising physical and/or psychological violence, aiming to lower the victim’s self-esteem and, in a later stage, the termination of the bond with the working place.

6. Harassment is sexual when the above mentioned behaviors of verbal or physical nature entail a sexual meaning namely invitations or messages of sexual nature, attempting forced or compelling physical contact, blackmail aiming employment or progression in career in exchange of sexual favors and obscene gestures.

Article 8

(Forbiddance of corruption and subornation)

1. Active and passive corruption is forbidden, either through acts and omissions or through the creation of situations of benefit or illicit influence.

2. CEM or its employees shall not pay any monetary or other contributions to political parties, anywhere in the world, with the intent to gain advantage or influence.

3. CEM and its employees shall refuse any gifts that may be considered or interpreted as an attempt to influence either the Company or the employee. Should there be any doubt, the employee shall communicate the situation, in writing, to his/her superior.

4. Employees may not negotiate or enter into any agreement with relation to prices, share of markets or clients, dealing with an activity likely to restrain competition.

5. Employees holding information likely to influence CEM’s competitiveness in the market, or lead to loss of pertinent contracts and the like, cannot disclose the information to a third party prior to the official disclosure by the Company.

Article 9

(Relationship with shareholders)

1. As a fundamental objective, CEM seeks to create value for shareholders based on the commitments to the practice of excellence when performing professional, economical, social responsibilities or sustainable development duties.

2. CEM is committed to respect the principle of equal treatment to shareholders, ensuring the disclosure of information in a timely, true, transparent and accurate manner.

3. Information to shareholders shall bear qualitative and quantitative data identifying economical, financial, social, environmental and sustainable risks and CEM is committed to the uncompromising defense, proposal and use of adequate measures to eliminate or to mitigate those risks.

4. CEM shall take all steps to implement mechanisms and rules of transparency, exemption and objectivity aiming at the separation of the interests of CEM from the interests of single shareholders or group of shareholders, regardless of the legal rights and the corresponding obligations, due to participation in the share capital.

Article 10

(Relationship with clients and suppliers)

1. CEM shall promote, as regards its clients and suppliers, the enforcement of safety regulations and practices in force in the Company.

2. CEM shall promote the correction, politeness, affability and professional pride in relations with clients and suppliers as well as the respect for their rights, sensibilities and diversity.

3. CEM shall not maintain relations with suppliers who are not in line with the spirit of this Code of Ethics. CEM is committed to monitor the ethical standards of its suppliers and to adopt immediate and accurate measures whenever the conduct on the part of the suppliers is questionable.

Article 11

(Disciplinary action)

Any employee who is in breach of the guidelines of this Code is subject to disciplinary actions under the applicable regulating provisions, namely the Disciplinary Regulation in force at the time.

Our Values:

Professionalism – Our professional ethics is above all.  We are honest, reliable and fair. We strive for continuous improvement.

Respect for the Community – We adopt a spirit of service.  We are committed and responsible to the community we serve.

Respect for People – We treat our employees with dignity, fairness and understanding.

Our Ethics:

We always act in such a way as to not call into question CEM’s reputation or its ethics.

Not all situations are covered in the Code of Ethics document.  Everyone must rely on their common sense and their ability to gauge a situation to adopt the appropriate behaviour.

In case of a difficult decision, contact the superior or the Ethics Officer.

• Is the action legal?

• Does it comply with the ethics code of my company and its values?

• Am I aware my decision could implicate others in the Company?

• Do I feel comfortable with my decision?

• How would I explain my decision to my colleagues?

• How will it look in the newspaper?

• What would my family think?

• What if everyone did the same?

• What if I asked my Ethics Officer?