Disclosure Of Unethical Practices (WHISTLEBLOWING)
Background
The company monitors the activities of its employees and other stakeholders with regard to legislation and regulations and the policies and procedures adopted by the company.
Any information related with a suspected or confirmed unethical practice made by an employee or by any other interested party shall be reported here.
The company guarantees confidentiality to the participations and to the author.
Ethics
SYSTEM OF QUALIFIED DISCLOSURE OF UNETHICAL PRACTICES (WHISTLEBLOWING)
Following the best practices and ensuring the management transparency, PHAROL, SGPS S.A. ("PHAROL") has in place a "System for Qualified Communication of Undue Practices", internationally known as Whistleblowing.
The outlines of the Qualified Communication of Undue Practices System are:
Any unethical practice concerning accounting, financial reports matters, or any other relevant related issues known by someone outside the company (Shareholder, Customer or Supplier) or by the actual PHAROL employees can be communicated.
O que são "práticas indevidas"O que são "práticas indevidas"
Are considered "bad practice" all acts or omissions, intentional or negligent, which are attributed to the conduct of Board members or other officers, Directors, management and other employees of PHAROL's company, which might impact the financial statements or information sent to the U.S. regulator (SEC - Securities and Exchange Commission) or the Portuguese regulator (CMVM - Committee on Securities Market) or those that cause damage to assets and the good name of PHAROL.
Whistleblowing, this way, will be participation of occurrences or suspicion based on verified facts, by the person who knows or has reason to assume that consistent evidence exists, particularly in the following situations:
- Violation of any law, rule or regulation;
- Acts of Fraud;
- Mismanagement;
- Abuse of authority;
- Waste of funds;
- Crime of banking and financial.
Tramitação das participações
The powers and duties of action regarding the receipt and handling of complaints are assigned to the Secretary of PHAROL, SGPS S.A..
After the preliminary treatment, Center for Analysis of Qualified Participations ("NAPQ") will forward such complaints, participation and complaints to the Secretary of PHAROL which decides the relevancy, and will forward the information to the competent structures within the Company as well as to other entities, internal or external, whose involvement is required or justified.
Proteção dos participantes
Will be guaranteed – rigorously, the confidentiality of participation and the author thereof, and in any case not be tolerated any retaliation against those that submit the above-mentioned participations, although the complaint of improper practices, when carried out with notorious falsehood or bad faith, might be eligible to the legal and applicable measures.
Como efetuar as participações
Participation can be sent from any computer (within or outside of PHAROL, SGPS S.A.), whose identification is impossible to anyone.
The output of the information received will only access the elements of NAPQ (Center for Analysis of Qualified Participations) and the Secretary of PHAROL, SGPS S.A..
The participation of any evidence of improper practices may be done by one of the following means:
- For registered mail, classified as "confidential" addressed to PHAROL, SGPS, S.A. / NAPQ to the following address:
- Rua Gorgel do Amaral, nº4, CV Esqª 1250-119 Lisboa, Portugal;
- Filling in and sending the form below:
