An offence or violation is any act or omission that contravenes applicable rules and regulations, be they national legal standards, Simoldes’ internal standards, policies or codes of conduct.

Through Simoldes’ existing whistleblowing channels, you can report violations of the legal regulations applicable in the national legal system, as well as violations of the internal regulations, policies and codes of conduct in force at Simoldes.

The object of the complaint or public disclosure may be offences that have been committed, are being committed or can reasonably be expected to be committed, as well as attempts to conceal such offences.

Yes, Simoldes provides several reporting channels for its employees and partners. These include

• Regular Mail: Addressed to the Whistleblowing Officer at the address indicated in the document.
• Email: Sent to compliance@simoldes.com.
• Telephone: (+351) 911 879 229, available between 9am and 6pm.
• Voicemail: (+351) 911 879 229, available between 6pm and 9am.
• Digital Platform: Through the link simoldes.whistleblowingofficer.com

A whistleblower is any natural person who reports or publicly discloses an offence on the basis of information obtained in the course of their professional activity. This includes

• Workers in the private, social or public sector.
• Service providers, contractors, subcontractors and suppliers.
• Shareholders and members of the administrative, management, supervisory or oversight bodies of legal persons.
• Volunteers and trainees.

The protection also applies to those who have had access to the information in a professional relationship that has already ended, during the recruitment process or in pre-contractual negotiations.

Yes, you can submit anonymous reports through any of Simoldes’ reporting channels. However, in order to monitor the processing of the anonymous report, it must be submitted via the Digital Platform, where an access code is provided for this purpose.

To benefit from protection, the whistleblower must:

• Act in good faith.
• Have serious grounds for believing that the information is true at the time of reporting.
• Follow the whistleblowing procedures established in the legislation and in Simoldes’ internal rules, including the rule of precedence between whistleblowing channels.

Yes, legislation and Simoldes’ internal rules establish an order of precedence for reporting offences.

• Internal reporting: This is the first recourse and should be used whenever possible.
• External reporting: Can only be used in specific situations, such as the lack of an internal channel, risk of retaliation or seriousness of the offence.
• Public disclosure: This is the last resort and can only be used in exceptional cases, such as imminent danger to the public interest or inaction by the competent authorities.

The use of external reporting channels is only permitted in the following situations:

• No internal whistleblowing channel.
  Internal whistleblowing channel restricted to employees.
• There are grounds to believe that the offence will not be resolved internally or that there is a risk of retaliation.
• Previous internal complaint without a response within the legal deadlines.
• Infringement constitutes a criminal offence or administrative offence with a fine of more than €50,000.

Public disclosure of an offence is only permitted when:

• There is an imminent danger to the public interest.
• The offence cannot be resolved by the competent authorities.
• There is a risk of retaliation even in the case of an external complaint.
  Appropriate measures have not been taken following internal and external complaints.

External whistleblowing or public disclosure without complying with the rule of precedence may result in the loss of the legal protection afforded to whistleblowers. The specific consequences will depend on the applicable legislation and the circumstances of the case.

There is no general obligation to report offences. However, Decree-Law no. 109-E-2021 (RGPC) establishes the obligation for covered entities, both public and private, to implement regulatory compliance programmes, including whistleblowing channels. Law 93/2021, in turn, defines the obligation for organisations with 50 or more employees and organisations covered by specific European Union legislation to set up internal whistleblowing channels. In addition, Simoldes Tools‘ Code of Ethics and Conduct encourages whistleblowing and Simoldes’ Whistleblower Protection Procedure is committed to protecting whistleblowers.

According to Law 93/2021, the entities obliged to implement internal whistleblowing channels are:
Legal persons, including the State and other legal persons governed by public law, that employ 50 or more workers.
Entities that fall within the scope of the European Union acts referred to in Part I.B and II of the Annex to Directive (EU) 2019/1937.
Simoldes Tools, as an organisation with more than 50 employees, is obliged to implement internal whistleblowing channels.

• Regular Mail: Addressed to the Whistleblowing Officer.
• Email: Sent to compliance@simoldes.com.
• Telephone: (+351) 911 879 229, available during working hours.
  Voicemail: (+351) 911 879 229, available outside working hours.
• Digital platform: via the link simoldes.whistleblowingofficer.com.

It is important to note that internal whistleblowing channels must guarantee the confidentiality of the whistleblower’s identity, the integrity of the complaint and prevent access by unauthorised persons.

The sources do not specify the names of all the members of the whistleblowing team. However, Simoldes Tools’ Code of Ethics and Conduct states that the team responsible for handling whistleblowing is under the remit of the Compliance Office, and the Whistleblower Protection Procedure states that the team can be contacted at compliance@simoldes.com.

To file a complaint with Simoldes Tools, you can use any of the reporting channels mentioned above. The complaint can be made anonymously or identified, in writing or verbally.

Yes, verbal complaints can be submitted by telephone or voice message. In addition, you can request a face-to-face meeting to submit your complaint. Telephone calls made via the main telephone channel are not recorded by default, but may be recorded in specific situations with the prior express consent of the complainant. Voice messages recorded via voicemail are processed with the complainant’s consent.

Yes, you can request a face-to-face meeting with the whistleblowing team to submit your complaint in person.

The sources do not provide a specific template for structuring the complaint. However, it is recommended that the report be clear, concise and factual, including:
Detailed description of the facts.
Dates, places and names of the people involved.
Documents or evidence to support the complaint.

Yes, the Digital Platform provides a model form for submitting complaints.

If you submit your complaint via the Digital Platform, you will receive an access code that will allow you to follow up on it. If you use other reporting channels and choose to remain anonymous, you will not be able to follow up on the report.

Yes, Simoldes undertakes to respond to your complaint within the time limits provided for by law and its Whistleblower Protection Procedure. You will receive a notification of receipt of the complaint within seven days, a communication on the preliminary decision to open an investigation within one month, and a communication on the measures taken and the reasoning within a maximum of three months. Simoldes also undertakes to inform the whistleblower of the outcome of the analysis of the complaint within a maximum of three months from the date of receipt.

Yes, Simoldes guarantees the confidentiality of reports and the identity of the whistleblower. The identity of the whistleblower and any information that could lead to their identification are confidential and restricted. The identity will only be disclosed under legal obligation or by court order. Simoldes also guarantees the confidentiality of information subject to trade secrets.
The processing of personal data in the context of whistleblower protection complies with the data protection rules in force, namely the General Data Protection Regulation.

The processing of personal data in the context of whistleblower protection at Simoldes Tools is carried out in accordance with the data protection rules in force at both national and European Union level, namely the General Data Protection Regulation (GDPR) and complementary legislation.
Simoldes Tools has a Personal Data Protection Policy and a Data Processing Information Sheet, both accessible on the Whistleblowing Channels Digital Platform, to ensure transparency and compliance with data protection regulations. In addition, Simoldes Tools has appointed a Data Protection Officer (DPO), who can be contacted at dataprotection@simoldes.com.

• Written complaints: These are kept in digital or physical format.
• Verbal complaints by telephone without a recording: These are transcribed completely and accurately and a reliable record of the communication is drawn up.
• Verbal reports by telephone with a recording or voice message: Are recorded on a durable and retrievable medium, with the prior consent of the complainant, or transcribed in full.
• Reports made in person: These can be recorded on a durable and retrievable medium or recorded in reliable minutes, with the prior consent of the complainant.

In all cases where verbal complaints are recorded (with or without a recording), the whistleblower has the opportunity to check, rectify and approve the transcript or minutes of the communication, signing them.

Simoldes Tools is committed to legal compliance and the protection of whistleblowers, who are entitled to legal protection. Protection measures include:

• Confidentiality: The identity of the whistleblower and information that could lead to their identification is confidential and restricted. Disclosure of identity only occurs under legal obligation or court order, and the whistleblower will be notified in advance, unless it jeopardises investigations or legal proceedings.
• Protection against retaliation: The law prohibits retaliatory acts against whistleblowers, including changes in working conditions, negative evaluations, threats or other types of intimidation.
• Legal support: Whistleblowers are entitled to legal protection and can benefit from witness protection measures in criminal proceedings. Simoldes Tools provides confidential counselling prior to reporting.
  Effective judicial protection: Whistleblowers have access to the courts to defend their rights and interests.
• Exemption from liability: Reporting an offence in accordance with the legal requirements does not constitute grounds for disciplinary, civil, misdemeanour or criminal liability. The whistleblower is not liable for the violation of any restrictions on the disclosure of information contained in the report, except in cases provided for in special legislation.

The team responsible for handling complaints at Simoldes Tools can be contacted by the following means:

• Email: compliance@simoldes.com.
  Telephone: (+351) 911 879 229.
• Regular mail: Address available in section 9.1 of the Whistleblower Protection Procedure.
  Whistleblowing Channels Digital
• Platform:
  simoldes.whistleblowingofficer.com/#

For more information on whistleblower protection, you can consult the following resources:

• Justice Portal: The Directorate-General for Justice Policy provides information on whistleblower protection on the Justice Portal.
  Simoldes Tools Whistleblowing
• Channels Digital Platform: https://simoldes.protecaodedenunciantes.com. The platform provides information on Simoldes’ whistleblower protection programme, including procedures, policies, applicable legislation and frequently asked questions.

The main legal rules applicable to whistleblower protection in Portugal are:
Law no. 93/2021, of 20 December:

• Establishes the general regime for the protection of whistleblowers, transposing Directive (EU) 2019/1937.
• Decree-Law no. 109-E/2021, of 9 December: Approves the General Regime for the Prevention of Corruption (RGPC).

• Code of Ethics and Conduct.
• Whistleblower Protection Procedure.
• Personal Data Protection Policy (available on the Digital Platform).
• Data Processing Information Sheet (available on the Digital Platform).

These documents are available on the Simoldes Tools Whistleblowing Channels Digital Platform, in the ‘Regulatory Standards’ section.

If you have any questions or need help and advice before reporting an offence, you can contact the team responsible for handling Simoldes Tools complaints via the contacts mentioned above. The team is available to provide confidential advice and clarify any questions related to the reporting process.

The link to access the Simoldes Tools Whistleblowing Channel Digital Platform is: simoldes.whistleblowingofficer.com/#.

The link to access the Platform for the Repository of Information and Documentation on Simoldes Tools’ Compliance and Whistleblower Protection Programmes is available on the Whistleblowing Channels Digital Platform at https://simoldes.whistleblowingofficer.com/#/.

• Personal Data Protection Policy: Available on the Whistleblowing Channels Digital Platform.
• Data Processing Information Sheet: Available on the Whistleblowing Channels Digital Platform.

These documents describe how whistleblowers’ personal data is collected, processed and protected by Simoldes Tools.