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Whistleblower Protection Policy

Whistleblowing Directive | Law 93/2021

Respecting the dignity of all people at the workplace is not just about creating positive conditions, challenging and enriching roles, autonomy and empowerment in everyday life. It is also in the prevention of inappropriate and deviant behaviour, whether it be violations of law and/or regulations, corruption or even deviations from the purpose and values that guide our activity.

Whistleblowing channels can serve as an important breach prevention and risk management tool for organisations and, therefore, the Wellow™ Group is committed to ensuring the protection of individuals who wish to report, internally, a breach or possible irregularity under European Directive 2019/1937.

The Wellow Group prohibits retaliation against any person who, on reasonable grounds to believe that a breach or suspected breach exists, reports it and provides information obtained in a professional context.

This Whistleblower Protection Policy applies to the Wellow™ Group, consisting of Wellow Brighter Future, S.A.; Header - Recruitment & Training Lda; Lusotemp - Empresa de Trabalho Temporário, S.A.; Talenter - Trabalho Temporário, S.A.; Knower Projects, S.A.; Knower Properties, S.A.; Talenter Drive, Lda; Futurcabo Telecomunicações, S.A.; Exato - Consultadoria & Mediação de Seguros, Lda and Tailor Made Deal, Lda.

1. What are the issues to report?

Whistleblowers may report information, obtained in a professional context, concerning suspected irregularities or violations - actual or potential - of:

  • Laws and regulations applicable to the Wellow™ Group;
  • Internal audit and control policies;
  • Policies on disclosure of information to customers or suppliers;
  • Situations that jeopardise the safety of people and property;
  • Situations that jeopardise the smooth running of the organisation;
  • Unethical behaviour.

The violation or suspected irregularity must be based on reasonable grounds, i.e. the whistleblower does not need to prove the violation or irregularity, but must be able to substantiate his/her suspicions based on observations, documents, e-mails, reports or photos. A rumour is not a sufficient or reasonable ground for making a complaint.

2. Who can report it?

Anyone who works or has worked for the Wellow™ Group, including temporary and freelance workers, interns, volunteers or candidates in recruitment, service providers, contractors, subcontractors and suppliers, as well as persons acting under their supervision and direction, may report information.

3. How can you report it?

Violations or suspected irregularities can be reported through various channels:

In person: in Carnaxide central services, during working hours (9h - 18h).

Via email: by sending written communication to the address corresponding to the corporate brand involved / affected by the complaint to be made

Wellow™ Rent & Propertiesdenuncia@wellowgroup.com
Exato® Insurancedenuncia@wellowgroup.com
Berkshire Hathaway HomeServices Atlantic Portugaldenuncia@wellowgroup.com

When making a complaint, the whistleblower may remain anonymous or give permission for their identity to be revealed, but must always provide the necessary information to enable the situation to be properly investigated and the consequences of the complaint to be communicated to them. Insufficiently substantiated, unreasonable or factual complaints will not be investigated and a whistleblower who is not in good faith will not benefit from protection.

4. What happens after the complaint?

Upon receipt of the complaint through one of the channels identified above, a receipt is issued to the complainant within a maximum of 5 working days.

The Wellow™ Group will handle reports confidentially and may, if it deems appropriate and necessary, report the breach or suspected wrongdoing to third parties, law enforcement, governmental or other entities.

Within 12 weeks of the date the complaint was lodged, the complainant will be informed of the proceedings and will be required to keep all information received confidential.

Whistleblowers who consider themselves subject to retaliation for reporting a possible violation or suspected irregularity should immediately contact the People & Culture (rh@wellowgroup.com). 

5. Alternative methods of denunciation

Whistleblowers benefit from the legal protection enshrined in Directive 2019/1937 when they first report information on breaches internally. If, after having reported internally, the whistleblower receives no response or considers that the matter has not been properly investigated, he or she may choose to report the breach or suspected breach to the competent public authority.

6. Protection of Personal Data

The Wellow™ Group, responsible for processing, uses the information collected to carry out investigations, to make the necessary communications to the course of the process and to comply with legal obligations. The grounds of legitimacy that allow the Group to process the data are the consent of the complainant and the compliance with legal obligations, as described in the Privacy Policy in force.