For the purposes of the General Regime for the Prevention of Corruption and Related Offences, approved as an annex to Decree-Law no. 109-E/2021 of 9 December, corruption and related offences shall mean the crimes of corruption, undue receipt and offer of an advantage, embezzlement, economic participation in business, extortion, abuse of power, malfeasance, influence peddling, money laundering, or fraud in obtaining or diverting subsidies, grants or credit, as provided for in the Penal Code, approved as an annex to Decree-Law no. 48/95 of 15 March, as currently amended, in Law no. 34/87 of 16 July, as currently amended, in the Military Justice Code, approved as an annex to Law no. 100/2003 of 15 November, in Law no. 50/2007 of 31 August, as currently amended, in Law no. 20/2008 of 21 April, as currently amended, and in Decree-Law no. 28/84 of 20 January, as currently amended.

Legal entities, including the State and other public legal entities, employing 50 or more employees must have internal whistleblowing channels in accordance with Law no. 93/2021 of 20 December, which establishes the general framework for the protection of whistleblowers.

The NAVARRA Group’s internal whistleblowing channel aims to facilitate the identification of potentially irregular situations or infringements, including actual or potential suspicions, that have occurred or are considered highly likely to occur.

Who can submit a report:

The following may be considered whistleblowers, namely:

a) Employees in the private, social or public sectors;

b) Service providers, contractors, subcontractors and suppliers, as well as any persons acting under their supervision and direction;

c) Shareholders and persons belonging to management, administrative, supervisory or auditing bodies of legal entities, including non-executive members;

d) Volunteers and trainees, whether paid or unpaid.

Matters that may be reported:

In order to benefit from the whistleblower protection regime established under Law no. 93/2021 of 20 December, which sets out the General Regime for the Protection of Whistleblowers, your report must concern an infringement related to one of the following matters:

• Public procurement
• Financial services, products and markets, prevention of money laundering and terrorist financing
• Product safety and compliance
• Transport safety
• Environmental protection
• Radiation protection and nuclear safety
• Food and feed safety, animal health and welfare
• Public health
• Consumer protection
• Protection of privacy and personal data, and security of network and information systems
• Acts or omissions contrary to and harmful to the financial interests of the European Union referred to in Article 325 of the Treaty on the Functioning of the European Union (TFEU), as specified in applicable European Union measures or the internal market rules referred to in Article 26(2) of the TFEU, including competition and State aid rules, as well as corporate taxation rules, or acts contrary to the purpose of the aforementioned rules or standards
• Violent, especially violent and highly organised crime, as well as the crimes referred to in Article 1(1) of Law no. 5/2002 of 11 January, which establishes measures to combat organised and economic-financial crime
• Corruption crimes and related offences
• Other

We emphasise that all matters not related to the topics described above should be addressed through other available channels.

Principles and protection of the whistleblower

Independence, impartiality, confidentiality, data protection, secrecy and the absence of conflicts of interest are guaranteed in the handling and analysis of all reports received.

In all circumstances, the whistleblower is protected against any form of retaliation, and anonymous reporting is permitted under the terms of the law.

Purpose and content of the report

The report may concern infringements that have been committed, are being committed, or whose commission may reasonably be foreseen, as well as attempts to conceal such infringements.

Responsibility for managing reports

Reports will be received by the competent department of the NAVARRA Group, which, after registration and classification, will proceed with the handling, analysis and follow-up of the case.

In accordance with the law, the handling, investigation and implementation of measures relating to reports received are the responsibility of the NAVARRA Group.

Anonymous Reports

The NAVARRA Group undertakes to respect anonymity in all cases where the whistleblower wishes to submit an anonymous report, regardless of the level of detail contained in the report or the possibility of identifying the whistleblower through the facts described.

All reports, whether anonymous or not, will be handled whenever they contain sufficient and relevant information to allow investigation. However, only whistleblowers who provide an email address for this purpose will receive notifications.

Protection of Personal Data

By completing the reporting form, you acknowledge that you are aware of the conditions relating to the processing of your personal data and should therefore consult the NAVARRA Group Privacy Policy.

To submit a report, please complete the form provided aqui
 

Please consult the 2025 RGPC Annual Evaluation Report aqui