Whistleblowing Channel

Consolidating an Ethical and Transparent Organizational Culture

JONIL Calçados Lda.'s Ethics and Conduct Channel aims to prevent and sanction legal and ethical violations, including corruption, in accordance with the General Corruption Prevention Regime (Decree-Law No. 109-E/2021) and Law No. 93/2021, which transposes Directive (EU) 2019/1937.

The reporting of irregularities or crimes is crucial to the integrity of organizations, helping to avoid serious consequences.

The channel ensures confidentiality and protection for whistleblowers.

Whistleblowers must act in good faith and based on reasonable belief. Confidentiality is guaranteed, except in cases of legal obligation or judicial decision.

Reports must be clear, objective, and properly substantiated, containing, whenever possible, detailed information about the facts, the location where they occurred, the justification for the report, and any other elements deemed relevant for proper analysis.

Confidential does not mean anonymous.

In the case of anonymous reports, it will not be possible to provide additional information beyond what is available on the report follow-up page. Reports outside the legal or ethical scope will be redirected internally.

Common Questions

1. What is the purpose of the Whistleblowing Channel?

The Whistleblowing Channel aims to promote transparency, integrity, and accountability within the organization. It allows any individual to report, in a secure and confidential manner, violations as set out in Law no. 93/2021 of December 20, and Decree-Law no. 109-E/2021 of December 9.

2. Who can file a report?

The following persons may file reports:
- Current or former employees;
- Service providers, subcontractors, and suppliers;
- Interns and volunteers;
- Job applicants;
- Shareholders and members of corporate bodies.

3. What types of violations can be reported through this channel?

Violations related to:
- Corruption and related offences;
- Money laundering;
- Food, environmental, and product safety;
- Public health;
- Protection of personal data;
- Harassment;
- Workplace harassment;
- Competition and public procurement.

4. When should a violation be reported?

The report should be submitted as soon as the whistleblower becomes aware of or has a well-founded suspicion of the violation, preferably promptly, to allow an effective response.

5.Can reports be submitted anonymously?

Yes. The channel allows anonymous reporting, and confidentiality and data protection are guaranteed, even when the whistleblower’s identity is disclosed.

6. Who has access to the Internal Whistleblowing Channel?

Only the individuals designated by Jonil Calçados, Lda., who are bound by confidentiality obligations and have received appropriate training, have access to the reports.

7.What means can whistleblowers use to file a report?

They may use:
- A secure digital platform;
- A dedicated email address;
- A dedicated phone line;
- An in-person meeting, by appointment.

8. How can reports be submitted?

Reports may be submitted:
- In writing (via online form or email);
- Verbally (by phone or in person);
- Either anonymously or with identification.

9. What are the steps in the report analysis process?

1. Receipt of the report
2. Preliminary assessment and validation
3. Investigation and fact-checking
4. Notification to the whistleblower regarding actions taken or planned

“Please note that public disclosure of a violation or the use of external reporting channels is only permissible under the specific conditions set out in Law no. 93/2021 of December 20, namely when no appropriate response has been given to the internal report, there is an imminent or manifest risk to the public interest, or there is a justified fear of retaliation.”

10. How long does it take to analyse a report?

The maximum response time is three months from the date the report is received, as established in Law no. 93/2021.
The whistleblower will be notified within 7 days of receipt of the report.

11. What should be included in a report? Are there formal requirements?

Yes. The report must:
- Be made in good faith;
- Contain a clear and objective description of the facts;
- Include, whenever possible, evidence or witness statements;
- Be submitted through the appropriate channels.

12. What rights does the whistleblower have? Are there any protections?

Yes. The whistleblower is entitled to:
- Confidentiality of their identity;
- Protection against retaliation;
- Legal support;
- Witness protection measures, if applicable.

13. Is the whistleblower subject to disciplinary, civil, administrative, or criminal liability?

No, provided that:
- They act in good faith and in accordance with the law;
- The information is obtained lawfully;
- Confidentiality is respected and the proper order of reporting channels is followed (internal, external, public).

14. Is this the correct channel to request information, make a complaint, or submit a recommendation?

No. This channel is exclusively for reporting legal violations. For other matters, please contact us at: [email protected].

15. What are the information security measures?

Reports are handled with:
- Absolute confidentiality;
- Restricted access;
- Secure storage;
- Technical and organizational data protection measures.

16. How can I track the status of my report?

Upon submission, a keyword will be generated that allows the whistleblower to securely and confidentially monitor the status of the process.