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Framework: Decree-Law no. 109-E/2021, of December 9, which approves the General Regime for the Prevention of Corruption (RGPC) and Law no. 93/2021, of December 20, on the protection of whistleblowers of breaches of EU Law.

INESC TEC has approved a Compliance Program for the prevention of corruption, which includes a Code of Conduct, a Corruption Risk Prevention Plan, a Training Programme, and this Reporting Channel.

 

The legal framework for protecting whistleblowers of breaches of EU law also applies to the reporting channel for crimes of corruption and related offenses, so the reporting channel is the same.

 

There can be reported through this channel:

- the crimes of corruption and related offenses set out in the Annex to the Code of Conduct.

 

- breaches of European Union law in the following domains: public procurement; financial markets and the prevention of money laundering and terrorist financing; product safety and compliance; transport safety; protection of the environment; radiation protection and nuclear safety; food and feed safety, animal health and welfare; public health; consumer protection; protection of privacy and personal data; security of network and information systems; violent and organized crime; acts or omissions contrary to and detrimental to the financial interests of the European Union; acts or omissions contrary to the rules of the internal market, including the rules on the protection of public health and the protection of the environment; act or omission contrary to and damaging to the financial interests of the European Union; an act or omission contrary to the rules of the internal market, including the  competition and state aid rules, as well as the rules of corporate tax; violent, especially violent and highly organized crime, as well as the crimes provided for in Article 1(1) of Law no. 5/2002, of 11 January, which establishes measures to combat organized and economic-financial crime.

 

 

 

Person Responsible for receiving and following up on Reports: Compliance Officer, currently Prof. Ana Maria Mendonça

 

Response deadlines:

  • 7 days from the date of receipt of the Report: notify the complainant of the receipt and information on the requirements for submitting a Report through external channels managed by the competent authorities.
  • 3 months from the date of receipt of the Report: to communicate the measures planned or adopted to follow up on the Report.
  • At the request of the complainant, communicate the result of the analysis carried out on the Report within 15 days of its conclusion.

 

Record Keeping of the Report: 5 years, unless longer retention period is required by law.

 

Follow-up to the Report:  the report will trigger a series of internal actions suitable for verifying the allegations contained in the Report and, when proven, the cessation of the reported infringement, the possible opening of an internal investigation or the communication to the competent authorities

 

Anonymous complaints: notification of receipt of the Report and communication to the complainant of the measures planned or adopted follow the same deadlines as identified complaints. However, it can only be consulted, and the Report can only be followed up by entering the unique report number generated at the time of submission into the platform. This ensures that the identity of the whistleblower is not known to those who receive and follow up the Report.