1. Who Can File a Report

The following individuals may report violations through the Whistleblowing Channel:

• Employees;
• Service providers, contractors, subcontractors, and suppliers, as well as anyone acting under their supervision or direction;
• Volunteers and interns, whether paid or unpaid.

2. In-Person Reporting

Reports can be submitted in person through a pre-scheduled meeting after filling out an appointment form. In-person reports will be recorded in minutes, and the whistleblower may read, edit, and approve the transcribed information before signing the record.

3. General Requirements for Reports

• A description of the facts as precise and thorough as possible;
• Sufficient information to support the assessment of the violation;
• Whenever possible, objective evidence.

The whistleblower must act in good faith with a serious basis to believe the information provided is true at the time of the report. To receive protection under Law No. 93/2021, of December 20, the whistleblower must adhere to the priority rules outlined in Article 7 of this law.

4. Security

Reports are recorded on a dedicated platform to ensure:

• Completeness, integrity, and preservation of the report;
• Confidentiality of the whistleblower’s identity or anonymity, as well as the identity of third parties;
• Prevention of access by unauthorized persons.

Whistleblowing management follows technical and organizational measures focused on data protection and information security, preserving the integrity of both the individuals providing the information and those identified in the report. Information is retained for 5 years and during any legal or administrative proceedings related to the report. Only authorized personnel have access to the Whistleblowing Channel platform.

5. Procedure

• Submission of the report;
• Preliminary review by a qualified employee;
• Verification of the report;
• Notification to the whistleblower of any planned or already adopted measures to follow up on the report.

6. Cost

No fees or costs apply to submitting a report.

7. Timeline

• Notification to the whistleblower acknowledging receipt of the report: 7 days.
• Communication to the whistleblower of the planned or adopted measures for follow-up and the respective justification: within 3 months, or up to 6 months for external reports if the complexity of the case requires it.