Whistleblowing Policy

1. INTRODUCTION

The Filbet – Technical Facility Services, Lda assumes a commitment to ethics, transparency and compliance with Portuguese legislation, namely Law No. 93/2021, of December 20, which establishes the general regime for the protection of whistleblowers of violations.

The purpose of this policy is to create a safe and confidential mechanism for reporting irregularities, ensuring that whistleblowers are protected from retaliation.

2. POLICY OBJECTIVES

• Establish clear procedures for reporting irregularities within the company.
• Ensure whistleblower protection against retaliation.
• Ensure proper investigation of reported irregularities.
• Comply with applicable legislation in Portugal.

3. POLICY TARGET AUDIENCE

This policy applies to all employees, suppliers, subcontractors and other interested parties that maintain a relationship with the Filbet.

4. IRREGULARITIES COVERED

The following situations, among others, may be reported:

• Corruption and bribery;
• Financial fraud;
• Violation of occupational health and safety standards;
• Conflicts of interest;
• Moral or sexual harassment;
• Other illegal or unethical behavior.

5. IRREGULARITIES COMMUNICATION CHANNELS

The Filbet provides the following channels for submitting complaints:

1. Email: etica@filbet.pt
2. Letter: Sent to the company's registered office.
3. In person: By appointment.

All reports will be treated confidentially, ensuring the protection of whistleblowers.

6. PROTECTION OF WHISTLERS

Under the terms of Law n.º 93/2021, whistleblowers are protected against any form of retaliation, including:

• Dismissal or suspension;
• Adverse changes in working conditions;
• Threats or intimidation.

The Filbet undertakes to ensure that no reprisals will be taken against good faith whistleblowers.

7. COMPLAINT MANAGEMENT PROCESS

1. Reception and Registration: All complaints are recorded and evaluated by the Compliance Department.
2. Preliminary Analysis: The seriousness and veracity of the complaint are determined.
3. Internal Investigation: If necessary, a detailed investigation is conducted.
4. Corrective Measures: If the complaint is confirmed, appropriate sanctions are applied.
5. Closing and Archiving: Complaints and respective conclusions are documented and archived for the legal period of 5 years.

8. DATA RETENTION

All reports and information collected will be treated in accordance with the General Data Protection Regulation (GDPR), being stored in a secure system for the minimum period legally required.

9. POLICY REVIEW

This policy will be reviewed annually or whenever there are relevant legislative changes.

Filbet – Technical Facility Services, Lda