Damia
business policies
Environment · Social · Governance
Our ESG Commitment
At Damia, we believe that building the future of tech recruitment also means shaping a better future for our people, communities, and planet.
Long-term sustainability and continuous improvement with responsible business practices are our commitment to ourselves and to the community. The following guidelines outline our approach and actions across these three pillars.
- Environmental: Minimizing our environmental impact and promoting sustainable practices.
- Social: Creating a diverse, inclusive, and empowering workplace while contributing to the tech community and society at large.
- Governance: Upholding ethical conduct, data privacy, and strong corporate governance standards.
Environment
As a growing company, we know that every step counts when it comes to protecting the planet. While we may not have a massive footprint, we are intentional about reducing it, and doing our part in the transition to a greener future.
Climate Action, One Step at a Time: Our small fleet is already 90% electric, and we encourage low-emission transport in our daily routines whenever possible.
Less Waste, More Purpose: We are a digital-first, remote-first company, and we embrace circular economy principles by promoting recycling, reducing unnecessary resource use, and raising awareness among our team and partners. Our teams keep office commuting to a necessary minimum, and we have also put in place simple internal systems to help us use energy more efficiently and avoid all sorts of waste.
Supporting a Low-Carbon Tech Ecosystem: Through the partnerships we build with tech companies, we also contribute by aligning with clients who are committed to sustainable practices, helping them meet their goals while we stay true to ours.
Supporting reforestation What’s the point of building growth if there’s no sustainable future to grow into? Everyone of our hires results in one tree planted in Portugal, by a specialised partner. This is the best metaphor for our mission: growing with intent and creating meaningful impact along the way.
Social
At Damia, people come first, always. Whether it is our team, our candidates, or the communities we are part of, we are committed to making a positive impact through how we work and who we work with.
Growing Together: We invest in our team's personal and professional growth by creating a space where learning happens every day, through real challenges, mentoring, collaboration, continuous training, and hands-on experiences. Structured career paths are part of the journey, but so is sharing knowledge and growing as a team.
A Workplace for Everyone: We believe in flexibility, inclusivity, and mutual respect. Our remote-first work model supports different lifestyles and geographic neutrality, boosts well-being, and helps everyone bring their best selves to work, wherever they are.
Championing Equal Access: Tech should be for everyone. We support digital inclusion by promoting equal opportunities and fair access to the industry, regardless of gender, background, identity, race, or beliefs. We actively look for ways to give back and make the tech world more open, diverse, and respectful, and we share these values with our community every day.
We are building a workplace where people feel seen, supported, and empowered, and we are just getting started.
Governance
We believe that doing good business means doing it the right way, with integrity, transparency, and accountability in everything we do.
Clear Values, Honest Actions: Our decisions are guided by a strong ethical foundation. We operate with fairness, respect, and honesty, both internally and in our relationships with clients, candidates, and partners.
Privacy and Data Protection: We take data seriously. Whether it is candidate profiles or client information, we follow best practices to protect personal data and ensure full compliance with GDPR and other privacy regulations.
Transparency You Can Trust: From the way we communicate to how we handle feedback, we keep things clear and open. We are committed to building long-term relationships based on trust, and that starts with being consistent, reliable, and transparent in how we operate.
At Damia, good governance is not just a checklist. It is how we build a company that earns the trust of everyone we work with.
Workplace
Code of Conduct for Preventing and Combating Discrimination and Harassment at Work
Within the scope of its activity, Damia Portugal, Lda. (DAMIA), its employees and holders of management positions and corporate bodies must be guided, among others, by the principles of diligence and transparency, legality, non-discrimination and good faith, and in compliance with a zero tolerance policy with practices of moral or sexual harassment, in order to grow and maintain the credibility and prestige of the organization, granting everyone increased responsibility with regard to their own conducts.
Now, therefore, considering:
- Undesirable behaviour which affects the dignity of women and men at work on the part of managers, members of management, employees with duties of responsibility/coordination and any other employee;
- Such behaviour may be explicitly or implicitly used as the basis for decisions affecting the employee's access to professional training, continued employment and any other work-related decisions;
- Such behaviour is likely to create an intimidating, hostile or humiliating atmosphere for the targeted person;
- The purpose for preventing harassment at work and, if it occurs, the need to ensure the application of appropriate measures to punish and prevent its recurrence;
- The provisions of article 127(1)(k) of the Portuguese Labor Code, particularly, those that state that the employer must "adopt codes of good conduct for preventing and combating harassment at work, whenever the company has seven or more employees";
- DAMIA's public commitment to upholding the values of non-discrimination and combating harassment in the workplace.
This Code of Good Conduct for Preventing and Combating Discrimination and Harassment at Work (henceforth the "Code") is hereby entered into, and will be used and considered the privileged instrument in resolving ethical issues, ensuring DAMIA's compliance with the legal practices to which it is obligated.
Article 1 Purpose and scope
- This Code establishes a set of principles, guidelines and procedures that must be observed in the performance of DAMIA's activities and serves as regulatory instrument and expression of a policy to disclose, identify, combat and punish situations and behaviours that may represent harassment in the workplace.
- This Code applies to all DAMIA's employees, holders of management positions and corporate bodies, regardless of their employment relationship, as well as to all collaborators without an employment relationship with DAMIA.
Article 2 General Principles
- DAMIA holds a policy to condemn and not condone any form of harassment, and to prohibit acts of harassment inside or outside the workplace for work-related reasons, including discriminatory behaviour toward others or third parties based on race, gender, age, disability, sexual orientation, opinions, political ideology or religion.
- In the performance of their duties, functions and responsibilities, all DAMIA's employees and collaborators must act in compliance with the principles of non-discrimination and combating harassment in the workplace, and all relationships must be based on loyalty, integrity and mutual respect.
- All those covered by this Code must, in their interpersonal conduct, promote a respectful and healthy working relationship, adopting in particular the following practices:
- Foster respect, availability to others, sharing of information, and team spirit;
- Act with courtesy, common sense and self-control when dealing with all situations that arise in a professional context;
- All reports of situations that may constitute harassment will be treated seriously, confidentially, promptly and with urgent proceedings.
- Those involved in harassment investigations shall be treated equally, regardless of career, category, organizational unit, and hierarchical position within DAMIA's organizational structure.
- This Code applies to all relationships established within the scope of DAMIA's activity, whether these take place during or outside working hours, in its offices or other locations, in person or through information and communication technologies.
Article 3 Definition of harassment
- "Harassment" means the practice of undesirable behaviour, namely any behaviour based on discriminatory factors, whether in job access procedures or during the performance of the job itself, with the purpose or effect of disturbing or embarrassing a person, affecting their dignity, or creating an intimidating, hostile, degrading, humiliating or destabilizing atmosphere.
- "Moral harassment" means any unwanted behaviour perceived as abusive, practiced persistently and repeatedly, that may take the form of verbal or non-verbal attacks with offensive or humiliating contents, or any act that may include psychological or physical violence, with the purpose or effect referred to in the previous number.
- "Sexual harassment" means any unwanted behaviour of sexual nature, whether verbal, non-verbal or physical, with the purpose or effect referred to in number 1 of this article.
- "Unwanted behaviour" means any gesture, word, or act, including sexual invitations, messages, unsolicited phone calls and attempts at physical contact.
- "Labor dispute" means any behaviour or attitude that, regardless of the discomfort it may cause or the infraction it may represent (disciplinary, criminal or labor), is practiced without the intention or effect of affecting the dignity of a person or creating an intimidating, hostile, degrading or humiliating atmosphere.
Article 4 Perpetrators and Victims
- Harassment may be considered:
- Vertical downward, when perpetrated by a superior against a subordinate;
- Vertical upward, when perpetrated by a subordinate against a superior;
- Horizontal, when perpetrated between employees at the same level;
- Other, when perpetrated by or against third parties.
- Victim means any person referred to within the scope of this Code, regardless of their hierarchical relationship with the harasser, as well as third parties who are the recipients of an act of harassment.
Article 5 Reporting
- Any person who considers having been a victim of harassment at work can report such situation in writing to their immediate superior, the next highest supervisor, or directly to DAMIA's Management.
- The aforementioned report may also be sent to the following email address: whistleblowing@damiagroup.pt
- Reports may also be filed through the Working Conditions Authority's (Portuguese Autoridade para as Condições no Trabalho) dedicated channels.
- Any person that becomes aware of acts that may be considered workplace harassment has a duty to report such acts to any higher supervisor, directly to DAMIA's Management, or through the email address mentioned in number 2 of this article.
- All reports must contain a description of the facts that may be considered workplace harassment, including circumstances, time and place, victim's and perpetrator's identities, as well as any evidence available.
- Verbal reports or complaints shall always be written down as soon as possible.
- When it is concluded that the report is unfounded or intentionally filed with the purpose of harming a person, contains false statements or defamatory material, particularly when the report itself constitutes harassment, DAMIA will initiate the appropriate disciplinary procedures, without prejudice to any imposing legal procedures.
Article 6 Procedure
- After investigating the reported facts, DAMIA will open a disciplinary proceeding, in accordance with the Portuguese Labor Code, whenever it concludes that the reported situation involves acts or behaviours that are considered harassment in the workplace.
- Harassment in the workplace is also a very serious offense as provided for in article 29(5) of the Portuguese Labor Code, without prejudice to any criminal liability provided for by law, that may originate the corresponding procedures by the competent authorities.
- The confirmation of a harassment in the workplace act grants the victim the right to compensation for material and moral damages, in accordance with the provisions of Article 28 of the Portuguese Labor Code.
- When acts or behaviours that may be considered harassment in the workplace are perpetrated by providers or suppliers of goods or services, or employees of companies providing or supplying goods or services, DAMIA shall initiate an investigation process aimed at determining the facts, and the contracts may be terminated on the basis of just cause for breach of the non-tolerance for harassment commitment assumed by DAMIA.
Article 7 Confidentiality and Guarantees
- A specific protection regime for victims, whistleblowers and witnesses is granted in procedures related to harassment in the workplace situations, and their confidentiality must be ensured until the accusation is filed.
- DAMIA's employees and managers may not disclose or make public information regarding harassment in the workplace procedures obtained in the performance of their duties or by virtue of such duties, even after termination, unless such information has already been authorized or made public, in accordance with the law.
- All procedures initiated after a report of a harassment in the workplace situation must be promptly concluded.
- Whistleblowers and witnesses, whether or not named by the victim, cannot be subject to disciplinary action unless they act intentionally, based on statements or facts contained in records of judicial or administrative procedures involving harassment in the workplace until a final, unappealable decision is made, without prejudice to the exercise of the right to be heard.
- Retaliation against victims, whistleblowers or witnesses constitutes a serious violation of this Code and will be subject to disciplinary actions.
Article 8 Final Provisions
- This Code will be made public via institutional email and will be available on DAMIA's intranet and website.
- This Code must be disclosed to those who begin their duties at DAMIA.
- This Code will be reviewed whenever necessary.
- This Code shall come into effect upon approval on the date of its publication.
Article 9 Interpretation
- This Code is written in Portuguese and English and, in case of any discrepancy or conflict, the Portuguese version shall prevail over the English version.
Sustainability
Corporate Social Responsibility
I Introduction
At Damia Portugal, Lda. we believe that our success is not only measured by financial performance but also by our commitment to the well-being of our community, environment, and stakeholders, while creating a positive impact for employees, clients and candidates.
As a provider of recruitment and IT outsourcing services, we recognize our role in shaping fair employment markets and promoting equality while contributing to a fairer, safer and more inclusive digital workforce in a sustainable and socially responsible manner.
This Corporate Social Responsibility (CSR) Policy outlines our broader commitments and actions towards ethical governance, information security and sustainable growth, guiding our actions, decisions and partnerships.
II Purpose and Principles
With this policy we aim to:
- Demonstrate our dedication to social and environmental sustainability;
- Establish a framework for integrating CSR into our business operations;
- Engage our stakeholders in meaningful and impactful initiatives.
In accordance with ISO 26000, our CSR framework is guided by seven foundational principles of social responsibility:
- Accountability
- Transparency
- Ethical behavior
- Respect for stakeholder interests
- Respect for the rule of law
- Respect for international norms of behavior
- Respect for human rights
To ensure that our social responsibility commitment reflects our stakeholders' priorities and significant concerns we have conducted a materiality analysis aligned with the abovementioned principles and international standards.
III Scope
This policy applies to:
- All employees (including management, contractors, consultants and temporary staff);
- All business operations;
- All partners, suppliers and service providers.
It encompasses all aspects of our operations and interactions with the community. By adhering to this policy, we aim to foster a culture of responsibility and stewardship that permeates every level of our organization.
IV Core Pillars
1. Ethical Governance and Compliance
We commit to:
Fair Operating Practices: Upholding all applicable employment laws and international human rights and labor standards.
Integrity and Transparency: Ensuring transparent, fair and non-discriminatory recruitment practices.
Anti-corruption: Implementing anti-corruption and anti-bribery measures in accordance with international standards and all applicable legislation; a mandatory anti-corruption compliance program is in force, including an anti-corruption Code of Conduct and whistleblowing channel.
Conflicts of interest: Avoiding conflicts of interest and promoting accountability at all levels.
2. Respect for Human Rights and Fair Labor Practices
As a company providing recruitment and outsourcing services, our primary impact on the world is through the employment we facilitate, and as such respecting human rights is paramount to our mission. We, therefore, ensure:
Inclusive sourcing: Support for diversity, equity and inclusion (DEI) within our workforce and talent pools, promoting equal opportunity and zero tolerance for discrimination based on gender, race, religion, age, disability, identity or any other protected characteristic.
Ethical sourcing: Promoting ethical sourcing of candidates against exploitation, coercion or forced labor practices.
Candidate advocacy: Treating every candidate with dignity, ensuring transparent communication and feedback, regardless of the placement outcome.
Fair work: Fair wages and compliance with employment standards.
3. Environmental Responsibility
While our operational footprint is mainly digital, we still strive to reduce our environmental impact by:
Energy efficiency and waste management: Minimizing our energy consumption by implementing energy-efficient practices and technologies, optimizing operational processes and promoting awareness among employees.
Electronic reconditioning: Restoring and encouraging reuse of electronic equipment.
Digital-first approach: Adoption of digital-first processes to minimize paper use by using e-signatures, digital repositories and online communication systems.
Sustainable commute: Encouraging low-emission transportation in daily routines; electric-powered fleet.
Reforestation partnership: Active partnerships in restoration and reforestation projects in regions affected by deforestation, helping mitigate the residual environmental impact of our digital operations and fleet.
4. Community Engagement and Social Impact
We aim to contribute meaningfully to the communities where we operate by:
Employment access: Supporting employment access programs and internships.
Continuous training: Providing training and career development programs.
Employee involvement: Encouraging employee community involvement.
Community partnerships: Partnering with educational institutions and local initiatives.
5. Employee Wellbeing and Development
Our people are our most valuable asset. We commit to:
Career development: Providing continuous learning and professional development opportunities.
Employee wellbeing: Prioritizing and supporting employee health, safety and welfare, including appropriate onboarding, development and work-life balance.
Workplace safety: Promoting safe and harassment-free workplaces for all employees and outsourced consultants; implementation of a Code of Good Conduct for Preventing and Combating Discrimination and Harassment at Work.
Remote first: Remote-first policy and flexible working arrangements as a standard.
Communication: Encouraging internal feedback and maintaining open communication channels.
Employee engagement: Recognizing and rewarding employee contributions.
V Responsible Supply Chain and Vendor Ethics
We expect all business partners to:
- Uphold ethical labor standards aligned with international human rights guidelines;
- Maintain data protection and cybersecurity practices equivalent to our own;
- Prioritize environmental responsibility and transparent operations;
- Commit to non-discrimination and ethical hiring practices.
VI Data Privacy and Cybersecurity
Given the sensitive data we handle, we commit to maintain:
- Strong cybersecurity controls to protect personal and corporate information, aligned with ISO 27001 principles;
- Compliance with the EU General Data Protection Regulation (GDPR) and all applicable data privacy laws;
- Clear data retention, consent and deletion policies;
- Regular training for employees on cybersecurity awareness.
VII Governance, Monitoring and Reporting
To ensure our CSR objectives are upheld:
- Management oversees the implementation of CSR initiatives;
- Performance is reviewed annually, including environmental practices, diversity progress and compliance results;
- Stakeholders are informed of CSR achievements through internal reports or published sustainability updates;
- Continuous improvement principles guide our CSR strategy.
CSR Governance is overseen by a designated CSR Lead and the Legal and Finance functions, with annual reporting to Management.
VIII Communication
This policy is communicated to:
- All employees during onboarding and through regular updates;
- Clients and candidates via our website or written materials;
- Suppliers and partners who must comply with our standards.
IX Reviews and Amendments
The CSR policy is reviewed at least once per year or when significant regulatory or organizational changes occur, in order to strengthen alignment with global standards and stakeholder expectations.
X Metrics
1. Ethical Governance and Compliance
| Area | KPI / Metric | Target / Frequency |
|---|---|---|
| Fair operating practices | Number of non-conformities with legal obligations | 100% of reported cases investigated |
| Integrity and Transparency | Number of CSR reports published | Min. 1 per year |
| Anti-corruption | Number of reported ethical violations investigated | 100% of reported violations investigated |
| Conflicts of interest | Number of reported conflicts | 100% of reported conflicts investigated |
| Contract compliance | % of contracts compliant with applicable laws | Achieve 100% compliant contracts |
| Privacy and Data Protection | Number of data breaches | 100% of substantiated cases resolved w/ corrective action |
2. Respect for Human Rights and Fair Labor Practices
| Area | KPI / Metric | Target / Frequency |
|---|---|---|
| Inclusive sourcing | % of candidates from underrepresented groups | Yearly growth of > 5% |
| Ethical sourcing | Number of discrimination and exploitation complaints | 100% of reported cases investigated |
| Candidate advocacy | Number of reported ethical violations investigated | 100% of substantiated cases resolved w/ corrective action |
| Fair work | Number of contractual disputes of unfair practices | 100% of reported disputes resolved |
3. Environmental Responsibility
| Area | KPI / Metric | Target / Frequency |
|---|---|---|
| Energy efficiency | Reduction of office energy consumption | Annually review practices to minimize lighting, heating and cooling usage |
| Energy efficiency | Reduction of digital carbon footprint | Annually review storage optimization, equipment and cloud usage settings |
| Energy efficiency | Reduction of office water usage | Annually review office practices to minimize water usage |
| Waste management | Reduction of recycled or reused office waste | Annually review waste management to improve reduction methods |
| Electronic waste | Electronic equipment reconditioning and reusing | Annually review maintenance and repairing processes to improve device lifecycle |
| Paper use | Reduction of paper use | Annually review paper use to enhance adoption of digital-first processes |
| Sustainable commute | % of employees under remote or hybrid work model | Min. 80% per year |
| Reforestation efforts | Annual contribution to certified reforestation projects | Min. 100 € per year |
4. Community Engagement and Social Impact
| Area | KPI / Metric | Target / Frequency |
|---|---|---|
| Employment access | Number of internships supported | Min. 3 per year |
| Employee involvement | Number of community events organized | Min. 1 per year |
| Community partnerships | Number of partnerships formalized | > 5 per year |
5. Employee Wellbeing and Development
| Area | KPI / Metric | Target / Frequency |
|---|---|---|
| Career development | Average annual training hours per employee | Min. 40h per year |
| Employee wellbeing | Number of reported incidents | 100% of incidents resolved w/ corrective action |
| Workplace safety | Number of reported complaints | 100% of reported complaints resolved |
| Communication | Number of yearly performance reviews | Min. 2 per year |
| Employee satisfaction | Employee yearly satisfaction score | Min. 95% per year |