The whistleblowing channel is a secure means you can use to report any infraction that is being committed or whose commission can be reasonably foreseen within CanalCentro, SA.
The Whistleblowing Channel is a self-regulation and self-monitoring tool that allows the Organisation, based on facts reported in good faith, to act and correct any unlawful conduct and prevent its future occurrence, ensuring compliance with applicable laws, regulations, and procedures, and an action strictly oriented towards serving the public interest.

You may report any act or omission that violates national or EU rules, including those concerning crimes or administrative offenses in areas such as public procurement, product safety and compliance, transport safety, environmental protection, food safety (for human and animal consumption), animal health and welfare, public health, consumer protection, privacy and personal data protection, and network and information system security.

You may also report any act of corruption or related offense that is being committed or whose commission can reasonably be foreseen, in areas of activity such as the granting of subsidies, grants, or benefits, commercial or industrial activities, and sanctioning procedures.

A whistleblower is considered to be any natural person who reports an infraction based on information obtained within the scope of their professional activity, regardless of the nature of that activity or the sector in which it is carried out, such as employees, service providers, contractors, subcontractors and suppliers, volunteers, and interns.

However, any citizen may also report infractions using the “Whistleblowing Channel”, even if they have no direct relationship with the organisation.

“Corruption” refers to the commission or omission of any act—whether lawful or unlawful—in exchange for or under the promise of an undue benefit for oneself or for a third party.

Corruption and related offenses include crimes such as active and passive corruption, undue receipt or offer of advantage, embezzlement, economic participation in business, extortion, abuse of power, malfeasance, influence peddling, money laundering, or fraud in obtaining or misappropriating subsidies, grants, or credit, as provided for in the Penal Code, approved in annex to Decree-Law No. 48/95, of March 15, in its current version.

The report must be submitted through the whistleblowing channel, to the email address canaldedenuncias@canalcentro.pt

The report should be as detailed as possible, objectively describing the facts you are aware of and including any documents or other evidence you may have.

After the submission of the report, the whistleblower is notified within 7 days of receipt and provided with the relevant information, as established in Article 11(1) of Law No. 93/2021, of 20 December.

CanalCentro, SA verifies the allegations and may request additional clarification from the whistleblower, if necessary, to validate and complete the information transmitted. The appropriate procedural steps will then be taken, which may include communication to the competent authority responsible for investigating the infraction.

CanalCentro, SA informs the whistleblower, within a maximum period of three months from receipt of the report, of the measures planned or adopted to ensure proper follow-up, including the respective justification.

1 – Right to Anonymity

To benefit from anonymity, you must state this intention. However, please be advised that anonymity will prevent you from being notified, as well as prevent requests for additional clarification regarding the reported facts. Please also be advised that submitting a report via email or in an in-person meeting guarantees the confidentiality of the whistleblower's identity, but not their anonymity.

2 – Right to Identity Confidentiality / Personal Data Protection

Identity confidentiality is always guaranteed, except in situations involving compliance with legal obligations or judicial rulings. The Whistleblowing Channel is operated by technicians specially trained and dedicated to the receipt, processing, and follow-up of reports, ensuring their independence, impartiality, confidentiality, absence of conflicts of interest, and respect for data protection in the performance of these duties. The Whistleblowing Channel is operated solely by technicians specifically designated for this purpose, and access is prohibited to unauthorized persons. You may request that the confidentiality of your identity be guaranteed, even from the restricted team that receives and processes the report; simply indicate in the report email your wish to conceal your identity within the process. In this case, your identity will only be known by the designated Responsible Officer, for notification purposes and any necessary requests for clarification. The processing of personal data collected for the submission of a report complies with the General Data Protection Regulation (GDPR), the Privacy Policy of CanalCentro, SA, and other applicable legislation.

3 – Right to Whistleblower Protection, granted by Law no. 93/2021, of December 20

Reporting an infringement, done in good faith and with serious grounds to believe that the information is true at the time of reporting, grants the whistleblower the protection conditions set forth in Law no. 93/2021, of December 20. The whistleblower is specially protected against potential acts of retaliation; threats, acts, omissions, or attempts that, directly or indirectly, occur in a professional context and are motivated by an internal report, and which cause or may cause the whistleblower unjustified financial or non-financial damage, are prohibited.

The whistleblower is entitled, under general terms, to legal protection and may benefit, under general terms, from witness protection measures in criminal proceedings. Reporting an infringement, carried out in accordance with the requirements imposed by Law no. 93/2021, of December 20, does not, in itself, constitute grounds for disciplinary, civil, administrative offense, or criminal liability on the part of the whistleblower.

4 – Right to Report Follow-up

The whistleblower has the right to be notified within seven days regarding the receipt of the report, as well as, within a maximum period of three months from the receipt of the report, of the measures envisaged or adopted to follow up on the report and the respective rationale. They may, at any time (once 15 days have passed since the conclusion of the report processing), request that the result of the analysis carried out on the report be communicated to them.

The use of the Whistleblowing Channel is an exercise of civic responsibility. Misuse of the channel and/or knowingly providing false statements may compromise its purpose.

The whistleblower must submit the report in good faith, presenting substantiated and detailed indications/facts and, as far as possible, including evidence.

Whistleblower protection does not override the legal rights or procedural guarantees granted to persons targeted by the report.
If the allegations are not confirmed, those targeted may take legal action, particularly under Article 365 of the Penal Code, which states:

“Anyone who, by any means, before an authority or publicly, knowingly makes a false accusation or casts suspicion on someone for committing a crime, with the intention of triggering proceedings against them, shall be punished with imprisonment for up to 3 years or with a fine.
If the conduct consists in falsely imputing an administrative offense or disciplinary infraction, the offender shall be punished with imprisonment for up to 1 year or with a fine of up to 120 days.”