Team size: Six

Jurisdictions your role covers: Portugal (primary); cross-border support to the Group’s operations in Africa in coordination with local teams.

What are the most significant cases or transactions that your legal team has recently been involved in?

Regulatory implementation and continuous interpretation. Leading implementation support and ongoing interpretation of major EU frameworks with direct operational impact, including the AI regulatory framework (with a focus on the classification and governance of AI systems), DORA (including the review of policies), the Insurance Recovery and Resolution Directive (IRRD) and sustainability-related disclosure obligations. This work has been central to translating complex regulatory change into practical governance, clearer internal decision-making and more consistent implementation across the business. 

“Right to be forgotten” in insurance. Leading the end-to-end legal implementation of the “right to be forgotten” regime in life insurance, including revision of underwriting documentation, internal guidelines, and engagement with industry and supervisory discussions. This required balancing legal certainty, operational feasibility and fair customer treatment in a particularly sensitive area of insurance practice. 

Market conduct, product governance and greenwashing prevention. Strengthening controls associated with product design and monitoring across the full product lifecycle — from conception to disclosure and subsequent changes — while ensuring the legal robustness of contractual documentation and customer communications. In parallel, developing a Greenwashing Prevention Guide for the Group, supported by a training plan that included international audiences, helping embed a more consistent and preventive approach to conduct risk across jurisdictions. 

Customer outcomes and global claims standards. Coordinating legal input into projects aimed at improving customer outcomes, including simplification of refund and indemnity processes and the development of a Global Claims Handling Policy to harmonise principles across the Group’s claims areas. This has helped align legal, conduct and operational perspectives around fairer, more consistent customer treatment. 

Group policy governance. Implementing, in close collaboration with our General Counsel and Company Secretary, a structured annual review cycle for Group policies — with standard review templates, deadlines and publication controls — creating a reliable governance audit trail across the Group’s policy repository. Beyond the immediate process improvement, this has helped build a more disciplined and scalable governance framework. 

Supervisory engagement and reporting. Centralising responses to regulatory and industry requests (ASF and APS), contributing to public consultations — including on legislation in the African jurisdictions where the Group operates — and coordinating recurring and ad-hoc regulatory reporting across multiple entities, including market conduct-related reporting and the annual conduct supervision report. This has strengthened consistency of external positioning, improved internal coordination and reinforced the legal function’s role as a point of convergence for governance and supervisory engagement, while also enabling us to contribute to more effective legal and regulatory solutions across jurisdictions.

How has the role of the legal function evolved within your organisation over recent years, and where do you see it adding the most strategic value today?

The legal function at Fidelidade has evolved from a largely reactive support role to an embedded strategic partner, particularly where legal risk, customer outcomes, regulatory expectations and market conduct responsibilities intersect. In practice, this means shaping business decisions earlier, influencing product development and customer communications upstream, playing a central role in Group governance processes, and engaging directly with senior management on regulatory risk, feasibility and implementation in both domestic and cross-border matters. 

We create strategic value by anticipating regulatory and conduct risk early, translating fast-moving EU and local requirements into actionable guidance (policies, manuals and internal positions), supporting executive decision-making with clear, pragmatic analysis, and helping identify solutions aligned with technological evolution and the modernisation of the insurance sector. In other geographies, we provide support by drawing on our Portuguese experience while adapting our approach to local legal, regulatory and market specificities. More broadly, the legal function helps turn regulatory complexity into practical execution, stronger governance and more consistent customer-facing standards across the Group. The growing breadth and intensity of regulation — AI, digital resilience, sustainability, accessibility — has reinforced the need for a proactive, business-embedded legal function that not only protects the business, but also enables responsible growth and customer trust.

Which recent regulatory or legislative change in Portugal has had the most significant impact on in‑house legal teams, and how have you adapted your approach in response?

Rather than a single change, the most significant impact has come from the sheer intensity and pace of regulatory evolution. From a business and market-conduct standpoint, this includes the AI regulatory framework, DORA and sustainability obligations, alongside ongoing “omnibus” discussions that may adjust or consolidate requirements. In insurance, this pressure is amplified by parallel sector developments: the review of Solvency II-related governance expectations, preparation for the Insurance Recovery and Resolution Directive, the Retail Investment Strategy, and ASF specific initiatives on gender diversity, claims handling and the standard health insurance product. 

We adapted by strengthening structured regulatory horizon scanning and building internal knowledge-sharing tools. This includes periodic legal newsletters, an internal legal knowledge hub and targeted training sessions. We also centralise supervisory and industry responses to maintain consistency across entities. The systematisation of our annual policy review process, with standard templates and a clear tracking workflow, has also been instrumental in building governance resilience amid this regulatory acceleration. More broadly, our response has been to build durable internal capability — not simply to react to change, but to help the Group absorb it with greater consistency, discipline and agility.