Whistleblower Policy

Whistleblower Policy

This policy applies to Opensoft SA, which commits to complying with it in accordance with national and international legislation on the protection of whistleblowers reporting violations.

Law No. 93/2021, of December 20th, establishes the general protection regime for whistleblowers, transposing the European directive on the protection of whistleblowers reporting violations of Union law (Directive (EU) 2019/1937 of the European Parliament and Council on the protection of persons who report breaches of Union law).

Principles

The principles of this policy for handling reports of violations are:

• Independence and impartiality in the handling of the report, excluding from the investigation and decision-making process all individuals with a conflict of interest regarding the subject of the report;
• Treatment of all communications made based on the whistleblower’s good faith, who may submit supporting evidence either anonymously or identified;
• Confidentiality of the communications received, ensured by all those responsible for managing, receiving, processing, and filing such communications;
• Protection of personal data of both the whistleblower and the suspected offender, in accordance with applicable legislation;
• No retaliation through reprisals against those who lawfully report an irregularity or provide any information or assistance in the investigation of such reports.

This policy ensures the protection of whistleblowers in accordance with the provisions of Law 93/2021.

Process for submitting reports

Who can report?

All individuals considered whistleblowers under the aforementioned law.

How to report?

Reports of violations or suspected violations can be submitted in writing, via a Google Forms submission. For this purpose, the employee must fill out the form with relevant information concerning the report, and may attach relevant documents and provide contact details for follow-up.

Mandatory fields are marked with an asterisk (*).

Any communication method used to submit a report must be supported by facts that allow for the verification of the allegations, including:

• Type of report:
  • Acts or omissions detrimental to the financial interests of the European Union;
  • Public procurement;
  • Violent and highly organized crime and/or economic-financial crime;
  • Consumer protection, product safety, and compliance;
  • Privacy and personal data protection (GDPR), network and information systems security;
  • Environmental protection, radiation protection, and nuclear safety;
  • Internal market rules of the European Union, competition law, state aid rules, and corporate tax rules;
  • Public health, food safety for human and animal consumption, animal health and welfare;
  • Financial services, products and markets, and the prevention of money laundering and terrorist financing.
• Description of the supporting facts;
• The whistleblower’s relationship with Opensoft (employee / ex-employee / candidate / other).

Retention of reports

Opensoft ensures that reports are handled and safeguarded confidentially, and they are kept on a durable medium that allows for the complete and unaltered reproduction of the information, for the period provided for in Article 20.

If you wish to submit a report, you can do so via this form (only in Portuguese).