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Whistleblower Policy

1. Background

Sotecnisol S.A. is committed to the highest standards of ethics, integrity, and transparency in the conduct of its business. The purpose of this Whistleblower Policy is to establish the principles and procedures for receiving, handling, and following up on reports of unlawful conduct or violations of legal, regulatory, or internal rules.

2. Scope

This policy applies to all employees, service providers, suppliers, customers, and any third parties associated with Sotecnisol S.A. who wish to report an irregular situation or suspected misconduct.

Complaints may include, among other things:

  • Corruption or bribery;
  • Financial or accounting fraud;
  • Violation of environmental regulations;
  • Moral or sexual harassment;
  • Discrimination;
  • Serious risks to people’s health, safety, or physical well-being;
  • Any violation of the company's values, standards, or policies.

3. Reporting Channel

Sotecnisol S.A. provides a secure, confidential, and independent channel for receiving reports:

View the Reporting Channel

Reports may be submitted anonymously or with the reporter’s identity disclosed, and the confidentiality of the reporter’s identity is guaranteed whenever requested.

4. Handling of Complaints

All complaints received will be reviewed thoroughly, impartially, and promptly by a team designated for this purpose. When necessary, additional information may be requested from the complainant.

The company agrees to:

  • Assess the veracity and severity of the complaint;
  • Take the appropriate corrective or disciplinary action;
  • Protect the whistleblower from any form of retaliation;
  • Respect the principle of adversarial proceedings and the rights of the defense.

5. Whistleblower Protection

No whistleblower will be harmed, intimidated, or subjected to retaliation for filing a complaint in good faith. Sotecnisol S.A. takes measures to ensure this protection, in accordance with Law No. 93/2021 (General Regime for the Protection of Whistleblowers).

6. Information Retention

All documentation related to the complaint process will be retained for the legally required period and handled in accordance with the General Data Protection Regulation (GDPR).

7. Policy Review

This policy will be reviewed periodically, or whenever warranted, to ensure that it remains in line with current legislation and best organizational practices.