What it is for
This is the internal whistleblowing channel of Sombra Verde, set up under Portuguese Law no. 93/2021 of 20 December (Lei n.º 93/2021 — General Regime for the Protection of Whistleblowers). It is used to report, securely and confidentially, breaches related to the company that you have become aware of. You may identify yourself or make the report anonymously.
Report registered
You will need these two items to follow up on the report and read our responses.
Save them now, somewhere safe. The key is shown only this once and we cannot recover or resend it — not even we know it. Without it, you cannot follow up on the report.
If you prefer to make the report verbally, you can ask for an in-person meeting through the channel above. The meeting is arranged within a reasonable time and, with your consent, is recorded in minutes that you can review and sign.
What happens next
Responses appear under “Follow up on a report”, using your code and key. The report is reviewed independently and impartially, by people with no conflict of interest in the case.
Who can report
- employees and former employees, job applicants and trainees;
- service providers, subcontractors, suppliers and the people who work for them;
- shareholders, members of the governing bodies and volunteers.
What can be reported
Acts or omissions, whether already committed or likely to be committed, in particular in the following areas:
- corruption, bribery and related offences;
- public procurement;
- money laundering and terrorist financing;
- product safety and compliance, environmental protection and public health;
- consumer protection, protection of personal data and security of network and information systems;
- tax fraud and other breaches affecting the financial interests of the Portuguese State and the European Union.
Everyday employment matters (working hours, holidays, disagreements between colleagues) should be dealt with by your line manager or human resources. Cases of harassment may also be reported through this channel.
Confidentiality and protection
Your identity and any information from which you could be identified are confidential and known only to the persons responsible for receiving and handling reports. They may only be disclosed where required by law or by a court decision, in which case you will be notified in advance, in writing, with the reasons.
For anonymous reports we do not store your name, contact details or IP address. The follow-up key is stored in an encrypted, irreversible form: not even the channel managers can see it.
Any form of retaliation against anyone who reports in good faith, or against those who assist them or their relatives, is prohibited — including dismissal, changes to duties or working hours, negative appraisals and suspension of contracts, among others. Reports made in bad faith, based on facts known to be false, may have legal consequences.
Personal data
Personal data that is not relevant to the report is not collected or is deleted immediately. Reports are recorded and kept for 5 years and, regardless of that period, for as long as any judicial or administrative proceedings concerning the facts are pending. Find out more in the privacy policy.
External reporting channels
You may also report directly to the competent authorities, in particular if you consider that the breach cannot be dealt with effectively through the internal channel or that you are at risk of retaliation:
- MENAC — Mecanismo Nacional Anticorrupção, the Portuguese National Anti-Corruption Mechanism (mec-anticorrupcao.pt);
- Ministério Público, the Portuguese Public Prosecutor’s Office (www.ministeriopublico.pt);
- the authority responsible for the area concerned (for example, ACT — the labour inspectorate, the Autoridade Tributária — the tax authority, or the CNPD — the data protection authority).