1. Background

Sotecnisol S.A. is committed to the highest standards of ethics, integrity, and transparency in the conduct of its activities. The purpose of this Whistleblowing 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 who have a relationship with Sotecnisol S.A. and who wish to report an irregular situation or suspected misconduct.

Complaints may cover, among other things:

  • Corruption or bribery;

  • Financial or accounting fraud;

  • Violation of environmental regulations;

  • Moral or sexual harassment;

  • Discrimination;

  • Serious risks to the health, safety or physical integrity of persons;

  • 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 complaints:

See Reporting Channel

Complaints may be made anonymously or identified, with the confidentiality of the complainant's identity guaranteed whenever requested.


4. Handling of Complaints

All complaints received will be analysed rigorously, impartially and swiftly by a team designated for this purpose. Where necessary, additional information may be requested from the complainant.

The company undertakes to:

  • Assess the veracity and seriousness of the complaint;

  • Take appropriate corrective or disciplinary measures;

  • Protect the whistleblower against any form of retaliation;

  • Respect the principle of adversarial proceedings and the rights of defence.


5. Whistleblower Protection

No whistleblower shall be prejudiced, intimidated or retaliated against for having made a report in good faith. Sotecnisol S.A. adopts 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 kept for the legally stipulated period and handled in accordance with the General Data Protection Regulation (GDPR).


7. Policy Review

This policy will be reviewed periodically, or whenever justified, to ensure its alignment with current legislation and good organisational practices.