Internal Complaint Channel

Any act or omission that is contrary to regulations contained in national or community legislation on matters related, among others, to public procurement, money laundering, financial markets, terrorist financing, product safety, transport safety, food safety, environmental protection, public health, consumer protection, protection of personal data and competition.

Infractions already committed, which are in progress or whose commission can be anticipated.

Anyone who comes across information relating to infringements that they have obtained in the course of their professional activity – here included candidates, workers in the private, social and public sector, former employees but also service providers, subcontractors, suppliers (or any persons under their supervision), holders of shareholdings or members of statutory bodies, volunteers or interns (regardless of whether they are paid or not).

Yes. It benefits from special protection conditions, which, among others, aim to ensure anonymity and avoid retaliatory actions (direct or indirect).

Sim. A confidencialidade da denúncia, bem como a proteção da identidade do denunciante e denunciado, são elementos essenciais para o cumprimento das regras dos canais de ética.

The complaint may be submitted in writing using the form available on the website of the Irmandade da Lapa at Internal Complaint Channel

Our whistleblowing channels are operated only internally, both in receiving and following up complaints, guaranteeing the presentation and safe follow-up of those, in order to ensure the confidentiality of the identity or anonymity of the whistleblowers and the confidentiality of the identity of third parties mentioned in the complaint.

Yes. Within 7 days, whistleblowers are notified of receipt of the complaint and of the requirements for submitting an external complaint (if applicable) – which will be the case when, for example, there is no internal whistleblower channel, or when it only admits the presentation of complaints by workers and the whistleblower is not, or when there is a risk of retaliation Within a maximum period of 3 months, counting from the date of receipt of the complaint, the complainant is informed of the planned or adopted measures and the respective grounds for following up on the complaint. The complainant may also request, at any time, that we communicate the result of the analysis carried out on the complaint within 15 days after its conclusion.