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Whistleblowing Channel

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Your report will be dealt with under the Law n.º 93/2021, 20 de dezembro

Whitlesblowing policy

I. GENERAL.

Introuction

At RJRI – The Ericeira Real Estate, Lda. (hereinafter referred to as RJRI), we strive to be transparent and uphold a high level of business ethics. Our whistleblowing channels provide an opportunity to alert the company about suspected misconduct, serving as an important tool to reduce risks and maintain trust in our operations, allowing us to detect and act on potential wrongdoing at an early stage. The existence and implementation of these channels are primarily aimed at protecting those who report or publicly disclose breaches of EU law, ensuring full conditions of secrecy, confidentiality, and security for the whistleblower.

Thus, we encourage potential whistleblowers who are aware of potential violations or actual breaches to use the available channels, as established in this Policy.

Definitions
In this Policy, unless the context or legislation clearly indicates otherwise, the following terms and expressions shall have the following meanings:

“Violations”: acts or omissions that are illegal or contrary to the purpose and/or objectives of European Union rules, in the areas listed in the section “III. WHAT IRREGULARITIES ARE COVERED?”
“Internal Report”: verbal or written communication of information about violations within a private or public sector entity.
“External Report”: verbal or written communication of information about violations to the competent authorities.
“Public Disclosure”: the public release of information about violations.
“Whistleblower”: an individual who communicates or publicly discloses information about violations obtained in the context of their professional activities.
“Person Targeted”: an individual or entity referred to in the report or public disclosure as the perpetrator of the violation or associated with it.
“Retaliation”: any act or omission, direct or indirect, occurring in a professional context, motivated by an internal or external report, or public disclosure, that causes or may cause unjustified harm to the whistleblower.
“Competent Authority”: any national authority designated to receive reports and provide feedback to whistleblowers.
“Document”: a written statement, or one recorded on a disk, tape, or any other technical means, understandable to the general public or a specific group of people, which, allowing the recognition of the issuer, is suitable to prove a legally relevant fact, whether this purpose is assigned to it at the time of issuance or later; also, a mark materially made, given, or placed on an object or animal to prove a legally relevant fact, recognizable by the general public or a specific group of people and proving the fact it results from.

II. WHO CAN BE A WHISTLEBLOWER?

A whistleblower is an individual who reports a violation based on information obtained in the context of their professional activity, which they, in good faith, believe to be true at the time of reporting. Whistleblowers can be:

Employees;

Shareholders and individuals in corporate management, including non-executive board members;

Volunteers;

Paid or unpaid interns;

Service providers, contractors, subcontractors, and suppliers, as well as individuals acting under their supervision and direction;

Applicants.

Whistleblower status also applies:

When information about violations obtained during a professional relationship, as described above, is reported after the relationship has ended (e.g., a former employee);
When the professional relationship has not yet begun, in cases where the whistleblower obtained the information during pre-contractual negotiations.

III. WHAT IRREGULARITIES ARE COVERED?
a) Acts or omissions contrary to European Union rules, in the following areas:
b) Acts or omissions that harm the financial interests of the European Union;
c) Acts or omissions that violate internal market rules, including competition rules, state aid rules, and corporate tax regulations;
d) Violent crime, especially violent and highly organized crime, as well as the crimes listed in Article 1, paragraph 1 of Law No. 5/2002, of January 11, establishing measures to combat organized and economic-financial crime;
e) Acts or omissions that contradict the purpose of the rules or standards covered by points (a) to (c).

Excluded Matters
Personal workplace complaints, such as interpersonal conflicts between employees and/or their superiors, or decisions by the employer concerning the employee in question, are not eligible for protection under this Policy or whistleblowing legislation and should not be made through the whistleblowing channels described here.

For such complaints, we recommend contacting:

	Phone	Email
Andreia Portela	962060559	andreia.portela@acasadascasas.pt
Ricardo Isidoro	966826233	ricardo.isidoro@grupodascasas.pt
Sandra Esteves	926593017	qualidade@grupodascasas.pt

If it is found that the content of the report does not fall within the scope of this Policy, it will be archived, and the whistleblower will be notified that the case has been archived. The communication will be forwarded to the person responsible for handling the matters in question within RJRI.

IV. SHOULD I MAKE AN INTERNAL OR EXTERNAL REPORT?
We are committed to addressing all internal reports submitted to us, aiming to resolve violations internally whenever possible. For this reason, we encourage you, before making an external report to the competent authorities, to submit your report through our internal channels.

You may resort to external reporting channels when:

You have reasonable grounds to believe that the violation cannot be effectively addressed or resolved internally, or that there is a risk of retaliation;
You have submitted an internal report without receiving any communication about the measures taken following the report, within the established timeframes; or
The violation constitutes a crime or administrative offense punishable by a fine exceeding €50,000.

External reports can be made to authorities that, according to their duties and powers, are competent to address the matter, including:

Criminal police authorities;

The Bank of Portugal;

Independent administrative authorities;

Public institutes;

Inspectorates and equivalent entities, as well as other central state administration services with administrative autonomy;

Local municipalities;

Public associations.

You may also resort to public disclosure of the violation in the following circumstances:

When you believe the violation may pose an imminent or clear danger to the public interest, which cannot be effectively addressed or resolved by the competent authorities, given the specific circumstances of the case, or when there is a risk of retaliation, even in the case of external reporting; or
When you have submitted both an internal and external report, or directly an external report, without adequate measures being taken within the legal deadlines.

V. WHAT PROTECTION DO I HAVE AS A WHISTLEBLOWER?

A whistleblower benefits from the protection granted by the Directive and the Whistleblower Protection Law if they acted in good faith, having reasonable grounds to believe that the information is, at the time of the report, true.

Regarding the protection measures:

Guarantee of confidentiality regarding the whistleblower’s identity;
Prohibition of retaliation acts against the whistleblower, with threats and/or attempts also considered retaliation;
The right to legal protection under general terms;
The benefit of measures to protect witnesses in criminal proceedings, particularly those set out in Law No. 93/99 of July 14;
If the whistleblower suffers retaliation, they may be compensated for the damages caused by such acts and may request appropriate measures to prevent or stop the damage;
Possibility of exemption from disciplinary, civil, administrative, or criminal liability regarding the report or public disclosure of an infraction made in accordance with the procedures of this policy and Law No. 93/2021, of December 20, both for the reported facts and the means of gathering evidence.

This protection granted to the whistleblower also extends, with the necessary adjustments, to:

A person who assists the whistleblower in the reporting procedure, whose assistance must be confidential;
A third party connected to the whistleblower (such as a colleague or family member), who may be subject to retaliation in a professional context;
Legal entities or equivalent entities controlled by the whistleblower, for which the whistleblower works or is connected to in a professional context.

Article 21, paragraph 6 of the Whistleblower Protection Law indicates the acts that are presumed to be motivated by an internal report, consisting of retaliation acts – unless proven otherwise.

VI. WHAT PROTECTION DO I HAVE AS A SUBJECT OF A REPORT?

The reported person also has the right to protection under applicable legislation, being entitled to:

All procedural rights and guarantees, including the presumption of innocence and the right to defense in criminal proceedings;
In the event of a false or misleading report, and without prejudice to the possible criminal and administrative liability of the whistleblower, the reported person may be entitled to compensation for damages caused by the report, with the person assisting the whistleblower in the reporting procedure, including union representatives or workers’ representatives, also being held liable;
Guarantees of confidentiality regarding their identity.

VII. CONFIDENTIALITY

The identity of the whistleblower, as well as information that may directly or indirectly reveal their identity, is confidential and accessible only to those responsible for managing reports. This protection also applies to any other information that may directly or indirectly reveal the whistleblower’s identity.

The same principle of confidentiality regarding the whistleblower’s identity also applies to the identity of the reported person.

VIII. HOW CAN I FILE AN INTERNAL REPORT?

When can I file a report?

You may file a report when you have reasonable grounds to believe that the reported facts are true, based on the circumstances and the information available at the time, and when the facts fall under the scope of this policy. Only when these conditions are met can you benefit from the protection granted to the whistleblower.

If the whistleblower files a report in bad faith, frivolously, or abusively, or if they knowingly communicate false or misleading information, they will not benefit from the legal protection granted to whistleblowers.

If an RJRI employee promotes a report that is determined to be malicious, in bad faith, and fraudulent, as described above, they may be subject to disciplinary, civil, and criminal liability.

How can I file a report?

RJRI provides the following reporting channels:

Online report through the form available at the following link: https://grupodascasas.pt/canal-de-denuncia/
Report via the following email: canal.denuncia@grupodascasas.pt
Report by sending a letter to the following postal address: Rua Dr. Eduardo Burnay nº 71 2655-368 Ericeira A/C RJRI Whistleblowing Team

Procedure for online reporting:

Access the form through the link provided;
Fill out the report form with the whistleblower’s identification (Name and Email) or anonymously (just leave the identification fields blank);
Add documents as evidence, if necessary and possible;
All communication will take place via email (if indicated).

Procedure for email reporting:

Send the report to the email address provided above;
In the email body, include your identification as a whistleblower (Name and Email) or, if you wish to report anonymously, use the online report option;
Add documents as evidence, if necessary and possible;
All communication will occur via email.

Procedure for postal reporting:

Send the report to the postal address provided above;
In the letter, include your identification as a whistleblower (Name and Address) or, if you wish to report anonymously, do not include any identifying information (Name, address, email);
Add documents as evidence, if necessary and possible;
All communication will occur via postal mail to the address you provide or via email (if indicated).

About the whistleblowing channel:

The whistleblowing channel is managed solely by RJRI, with the management, follow-up, and investigation of reports carried out exclusively by the following individuals:

Head of the Process Department;
Head of the Quality Department; and
Management Representative.

If the report is anonymous, the individuals responsible for managing the whistleblowing channel will not attempt to identify the whistleblower.

We remind you that the reporting of irregularities can only be made through these channels.

Any RJRI employee who receives a report through other means than the identified channels must direct the whistleblower to them, to centralize all occurrences in these channels and facilitate the flow of information, as well as subsequent investigation.

Can I file an anonymous report?

Yes. The implemented whistleblowing channels allow you to report anonymously. You will also benefit from the protection granted to you as a whistleblower if you are identified later.

What should the report contain?

The report should contain as much information as possible that the whistleblower deems necessary for the subsequent investigation.

The following information is considered relevant, as an example:

Identification of the persons involved (name, role, company…);
Nature of the report (description of the facts);
How the whistleblower became aware of the facts;
Identification of possible witnesses.

Only information relevant to handling the report should be included. Personal data that is not relevant for processing and analyzing the report will not be retained and will be deleted by the team responsible for managing reports.

How can evidence be obtained?

All documents containing information about the reported infractions, to which the whistleblower had legal access or obtained in the course of their duties, are admissible.

Obtaining information or documents relevant to the evidence of the report through actions that may constitute a crime does not exclude the whistleblower's criminal liability.

IX. PROCESSING OF REPORTS.

Report

Receipt of the report through the implemented internal channels.

Preliminary Analysis

Acknowledge receipt of the report to the whistleblower within 7 days from the receipt of the report.
Preliminary analysis of the reports.
Triage and categorization of reports by the nature of the irregularity.

The following situations may occur:

Archiving and forwarding reports that do not fall under this Policy, reports made in bad faith, and others that justify such actions.
Opening an investigation.

Investigation

Investigation of the report.
Conducting the necessary internal actions to verify the allegations contained in the report.
Gathering evidence (e.g., interviews with witnesses indicated by the whistleblower).

Conclusion

The final outcome of the investigation will determine the next steps, which may include:

Archiving.
Adoption of identified corrective measures necessary to cease the infraction or regularize the situation, or
Reporting irregularities to the competent authorities.

Communication to the whistleblower, within a maximum of three (3) months, about the measures planned or taken to follow up on the report and their justification.

Who is responsible for receiving and investigating reports?

Reports are handled by the team responsible for processing and managing reports, composed of the individuals mentioned in point VIII 2.

The team receives all reports, conducting a preliminary analysis to safeguard any potential conflicts of interest that may exist and to forward the follow-up to the team members that ensure greater impartiality.

The members of the team responsible for processing and managing reports are subject to a special duty of confidentiality.

Access to the reports submitted is restricted to the team responsible for processing and managing reports. When necessary, individuals with specialized knowledge may access the information and thus may be included in the investigation process. These individuals can access relevant information, appropriately anonymized, excluding data related to the identity of the whistleblower and other participants, and are also bound by confidentiality obligations. If the information communicated to these individuals allows the identification of the whistleblower, such information will not be disclosed.

Feedback to the whistleblower.

Within seven (7) days from the receipt of the report, the RJRI will acknowledge receipt of the same, informing them, in a clear and accessible manner, of the requirements, the competent authorities, the manner, and admissibility of the external report.

Within a maximum of three (3) months from the date of receipt of the report, the RJRI will inform the whistleblower of the measures planned or adopted to follow up on the report and their justification.

The whistleblower may request at any time that the obligated entities communicate the result of the analysis of the report within fifteen (15) days after its conclusion.

How is the investigation conducted?

All reports will be carefully analyzed to determine if they fall within the scope of this Policy and if an investigation is necessary, determining if there is sufficient evidence to support the reported facts. If applicable, the RJRI will take necessary actions to cease the reported infraction.

The management of each report will be carried out by the team responsible for processing and managing reports.

Whenever it is necessary to hear witnesses, indicated by the whistleblower or deemed pertinent by the RJRI for the investigation, a record of the witness's statements will be drafted. After the meeting with the witness, the record will be made available for validation via email. Once validated through the witness's email response, the final document will be archived, along with the witness's validation email, in the respective report process.

The identity of the whistleblower will not be disclosed by the RJRI to any potential witnesses.

In what situations can the identity of the whistleblower be disclosed? And to whom?

The identity of the whistleblower is disclosed by the RJRI only if one of the following circumstances occurs:

Legal obligation; or
Judicial decision.

In any case, whenever this occurs, the RJRI will inform the whistleblower in advance, indicating the reasons for the disclosure of the confidential data in question, unless providing such information compromises investigations or related judicial processes.

X. RECORDS CONSERVATION.

The RJRI will retain reports for the legal period of five (5) years, as defined by Law No. 93/2021, of December 20, without prejudice to the need for longer retention due to pending judicial or administrative processes related to the report. After this period, the records will be definitively eliminated/anonymized.

XI. PERSONAL DATA.

The RJRI is responsible for processing personal data.

All personal data processed under this Policy will be handled with respect for the confidentiality guarantees provided by applicable legislation on Whistleblowing and the protection of personal data.

Only personal data deemed necessary for the analysis and follow-up of reports will be processed, so excessive data will be deleted.

The basis for processing your data is compliance with legal obligations.

The collected data will be retained for the same period as the reports—five (5) years—after which it may be deleted or anonymized.

The personal data of different participants in a report process will be archived confidentially and securely, with access limited to the team responsible for managing reports. However, such data may be communicated to competent authorities for the investigation of reports. In addition to this communication, personal data may also be disclosed to other entities when there is a legal obligation to do so or by judicial decision.

The RJRI has implemented all necessary technical and organizational security measures to safeguard your personal data.

You may exercise your rights under the law (access, rectification, deletion, limitation, opposition, portability) by contacting the following email: apoio.cliente@grupodascasas.pt, without prejudice to the right to lodge a complaint with the competent control authority, www.cnpd.pt. However, we warn that the exercise of these rights may be limited based on the protection of participants and the prevention, investigation, detection, or prosecution of criminal offenses.

For further questions regarding the processing of data in this context, you can contact the RJRI at the email apoio.cliente@grupodascasas.pt.

XXI. CLARIFICATIONS ABOUT THIS POLICY.

For additional information regarding this policy or other clarifications, you can contact:

	Phone	Email
Andreia Portela	962060559	andreia.portela@acasadascasas.pt
Ricardo Isidoro	966826233	ricardo.isidoro@grupodascasas.pt
Sandra Esteves	926593017	qualidade@grupodascasas.pt

I. GENERAL.

Introuction

At RJRI – The Ericeira Real Estate, Lda. (hereinafter referred to as RJRI), we strive to be transparent and uphold a high level of business ethics. Our whistleblowing channels provide an opportunity to alert the company about suspected misconduct, serving as an important tool to reduce risks and maintain trust in our operations, allowing us to detect and act on potential wrongdoing at an early stage. The existence and implementation of these channels are primarily aimed at protecting those who report or publicly disclose breaches of EU law, ensuring full conditions of secrecy, confidentiality, and security for the whistleblower.

Thus, we encourage potential whistleblowers who are aware of potential violations or actual breaches to use the available channels, as established in this Policy.

Definitions
In this Policy, unless the context or legislation clearly indicates otherwise, the following terms and expressions shall have the following meanings:

“Violations”: acts or omissions that are illegal or contrary to the purpose and/or objectives of European Union rules, in the areas listed in the section “III. WHAT IRREGULARITIES ARE COVERED?”
“Internal Report”: verbal or written communication of information about violations within a private or public sector entity.
“External Report”: verbal or written communication of information about violations to the competent authorities.
“Public Disclosure”: the public release of information about violations.
“Whistleblower”: an individual who communicates or publicly discloses information about violations obtained in the context of their professional activities.
“Person Targeted”: an individual or entity referred to in the report or public disclosure as the perpetrator of the violation or associated with it.
“Retaliation”: any act or omission, direct or indirect, occurring in a professional context, motivated by an internal or external report, or public disclosure, that causes or may cause unjustified harm to the whistleblower.
“Competent Authority”: any national authority designated to receive reports and provide feedback to whistleblowers.
“Document”: a written statement, or one recorded on a disk, tape, or any other technical means, understandable to the general public or a specific group of people, which, allowing the recognition of the issuer, is suitable to prove a legally relevant fact, whether this purpose is assigned to it at the time of issuance or later; also, a mark materially made, given, or placed on an object or animal to prove a legally relevant fact, recognizable by the general public or a specific group of people and proving the fact it results from.

II. WHO CAN BE A WHISTLEBLOWER?

A whistleblower is an individual who reports a violation based on information obtained in the context of their professional activity, which they, in good faith, believe to be true at the time of reporting. Whistleblowers can be:

Employees;

Shareholders and individuals in corporate management, including non-executive board members;

Volunteers;

Paid or unpaid interns;

Service providers, contractors, subcontractors, and suppliers, as well as individuals acting under their supervision and direction;

Applicants.

Whistleblower status also applies:

When information about violations obtained during a professional relationship, as described above, is reported after the relationship has ended (e.g., a former employee);
When the professional relationship has not yet begun, in cases where the whistleblower obtained the information during pre-contractual negotiations.

III. WHAT IRREGULARITIES ARE COVERED?
a) Acts or omissions contrary to European Union rules, in the following areas:
b) Acts or omissions that harm the financial interests of the European Union;
c) Acts or omissions that violate internal market rules, including competition rules, state aid rules, and corporate tax regulations;
d) Violent crime, especially violent and highly organized crime, as well as the crimes listed in Article 1, paragraph 1 of Law No. 5/2002, of January 11, establishing measures to combat organized and economic-financial crime;
e) Acts or omissions that contradict the purpose of the rules or standards covered by points (a) to (c).

Excluded Matters
Personal workplace complaints, such as interpersonal conflicts between employees and/or their superiors, or decisions by the employer concerning the employee in question, are not eligible for protection under this Policy or whistleblowing legislation and should not be made through the whistleblowing channels described here.

For such complaints, we recommend contacting:

	Phone	Email
Andreia Portela	962060559	andreia.portela@acasadascasas.pt
Ricardo Isidoro	966826233	ricardo.isidoro@grupodascasas.pt
Sandra Esteves	926593017	qualidade@grupodascasas.pt

If it is found that the content of the report does not fall within the scope of this Policy, it will be archived, and the whistleblower will be notified that the case has been archived. The communication will be forwarded to the person responsible for handling the matters in question within RJRI.

IV. SHOULD I MAKE AN INTERNAL OR EXTERNAL REPORT?
We are committed to addressing all internal reports submitted to us, aiming to resolve violations internally whenever possible. For this reason, we encourage you, before making an external report to the competent authorities, to submit your report through our internal channels.

You may resort to external reporting channels when:

You have reasonable grounds to believe that the violation cannot be effectively addressed or resolved internally, or that there is a risk of retaliation;
You have submitted an internal report without receiving any communication about the measures taken following the report, within the established timeframes; or
The violation constitutes a crime or administrative offense punishable by a fine exceeding €50,000.

External reports can be made to authorities that, according to their duties and powers, are competent to address the matter, including:

Criminal police authorities;

The Bank of Portugal;

Independent administrative authorities;

Public institutes;

Inspectorates and equivalent entities, as well as other central state administration services with administrative autonomy;

Local municipalities;

Public associations.

You may also resort to public disclosure of the violation in the following circumstances:

When you believe the violation may pose an imminent or clear danger to the public interest, which cannot be effectively addressed or resolved by the competent authorities, given the specific circumstances of the case, or when there is a risk of retaliation, even in the case of external reporting; or
When you have submitted both an internal and external report, or directly an external report, without adequate measures being taken within the legal deadlines.

V. WHAT PROTECTION DO I HAVE AS A WHISTLEBLOWER?

A whistleblower benefits from the protection granted by the Directive and the Whistleblower Protection Law if they acted in good faith, having reasonable grounds to believe that the information is, at the time of the report, true.

Regarding the protection measures:

Guarantee of confidentiality regarding the whistleblower’s identity;
Prohibition of retaliation acts against the whistleblower, with threats and/or attempts also considered retaliation;
The right to legal protection under general terms;
The benefit of measures to protect witnesses in criminal proceedings, particularly those set out in Law No. 93/99 of July 14;
If the whistleblower suffers retaliation, they may be compensated for the damages caused by such acts and may request appropriate measures to prevent or stop the damage;
Possibility of exemption from disciplinary, civil, administrative, or criminal liability regarding the report or public disclosure of an infraction made in accordance with the procedures of this policy and Law No. 93/2021, of December 20, both for the reported facts and the means of gathering evidence.

This protection granted to the whistleblower also extends, with the necessary adjustments, to:

A person who assists the whistleblower in the reporting procedure, whose assistance must be confidential;
A third party connected to the whistleblower (such as a colleague or family member), who may be subject to retaliation in a professional context;
Legal entities or equivalent entities controlled by the whistleblower, for which the whistleblower works or is connected to in a professional context.

Article 21, paragraph 6 of the Whistleblower Protection Law indicates the acts that are presumed to be motivated by an internal report, consisting of retaliation acts – unless proven otherwise.

VI. WHAT PROTECTION DO I HAVE AS A SUBJECT OF A REPORT?

The reported person also has the right to protection under applicable legislation, being entitled to:

All procedural rights and guarantees, including the presumption of innocence and the right to defense in criminal proceedings;
In the event of a false or misleading report, and without prejudice to the possible criminal and administrative liability of the whistleblower, the reported person may be entitled to compensation for damages caused by the report, with the person assisting the whistleblower in the reporting procedure, including union representatives or workers’ representatives, also being held liable;
Guarantees of confidentiality regarding their identity.

VII. CONFIDENTIALITY

The identity of the whistleblower, as well as information that may directly or indirectly reveal their identity, is confidential and accessible only to those responsible for managing reports. This protection also applies to any other information that may directly or indirectly reveal the whistleblower’s identity.

The same principle of confidentiality regarding the whistleblower’s identity also applies to the identity of the reported person.

VIII. HOW CAN I FILE AN INTERNAL REPORT?

When can I file a report?

You may file a report when you have reasonable grounds to believe that the reported facts are true, based on the circumstances and the information available at the time, and when the facts fall under the scope of this policy. Only when these conditions are met can you benefit from the protection granted to the whistleblower.

If the whistleblower files a report in bad faith, frivolously, or abusively, or if they knowingly communicate false or misleading information, they will not benefit from the legal protection granted to whistleblowers.

If an RJRI employee promotes a report that is determined to be malicious, in bad faith, and fraudulent, as described above, they may be subject to disciplinary, civil, and criminal liability.

How can I file a report?

RJRI provides the following reporting channels:

Online report through the form available at the following link: https://grupodascasas.pt/canal-de-denuncia/
Report via the following email: canal.denuncia@grupodascasas.pt
Report by sending a letter to the following postal address: Rua Dr. Eduardo Burnay nº 71 2655-368 Ericeira A/C RJRI Whistleblowing Team

Procedure for online reporting:

Access the form through the link provided;
Fill out the report form with the whistleblower’s identification (Name and Email) or anonymously (just leave the identification fields blank);
Add documents as evidence, if necessary and possible;
All communication will take place via email (if indicated).

Procedure for email reporting:

Send the report to the email address provided above;
In the email body, include your identification as a whistleblower (Name and Email) or, if you wish to report anonymously, use the online report option;
Add documents as evidence, if necessary and possible;
All communication will occur via email.

Procedure for postal reporting:

Send the report to the postal address provided above;
In the letter, include your identification as a whistleblower (Name and Address) or, if you wish to report anonymously, do not include any identifying information (Name, address, email);
Add documents as evidence, if necessary and possible;
All communication will occur via postal mail to the address you provide or via email (if indicated).

About the whistleblowing channel:

The whistleblowing channel is managed solely by RJRI, with the management, follow-up, and investigation of reports carried out exclusively by the following individuals:

Head of the Process Department;
Head of the Quality Department; and
Management Representative.

If the report is anonymous, the individuals responsible for managing the whistleblowing channel will not attempt to identify the whistleblower.

We remind you that the reporting of irregularities can only be made through these channels.

Any RJRI employee who receives a report through other means than the identified channels must direct the whistleblower to them, to centralize all occurrences in these channels and facilitate the flow of information, as well as subsequent investigation.

Can I file an anonymous report?

Yes. The implemented whistleblowing channels allow you to report anonymously. You will also benefit from the protection granted to you as a whistleblower if you are identified later.

What should the report contain?

The report should contain as much information as possible that the whistleblower deems necessary for the subsequent investigation.

The following information is considered relevant, as an example:

Identification of the persons involved (name, role, company…);
Nature of the report (description of the facts);
How the whistleblower became aware of the facts;
Identification of possible witnesses.

Only information relevant to handling the report should be included. Personal data that is not relevant for processing and analyzing the report will not be retained and will be deleted by the team responsible for managing reports.

How can evidence be obtained?

All documents containing information about the reported infractions, to which the whistleblower had legal access or obtained in the course of their duties, are admissible.

Obtaining information or documents relevant to the evidence of the report through actions that may constitute a crime does not exclude the whistleblower's criminal liability.

IX. PROCESSING OF REPORTS.

Report

Receipt of the report through the implemented internal channels.

Preliminary Analysis

Acknowledge receipt of the report to the whistleblower within 7 days from the receipt of the report.
Preliminary analysis of the reports.
Triage and categorization of reports by the nature of the irregularity.

The following situations may occur:

Archiving and forwarding reports that do not fall under this Policy, reports made in bad faith, and others that justify such actions.
Opening an investigation.

Investigation

Investigation of the report.
Conducting the necessary internal actions to verify the allegations contained in the report.
Gathering evidence (e.g., interviews with witnesses indicated by the whistleblower).

Conclusion

The final outcome of the investigation will determine the next steps, which may include:

Archiving.
Adoption of identified corrective measures necessary to cease the infraction or regularize the situation, or
Reporting irregularities to the competent authorities.

Communication to the whistleblower, within a maximum of three (3) months, about the measures planned or taken to follow up on the report and their justification.

Who is responsible for receiving and investigating reports?

Reports are handled by the team responsible for processing and managing reports, composed of the individuals mentioned in point VIII 2.

The team receives all reports, conducting a preliminary analysis to safeguard any potential conflicts of interest that may exist and to forward the follow-up to the team members that ensure greater impartiality.

The members of the team responsible for processing and managing reports are subject to a special duty of confidentiality.

Access to the reports submitted is restricted to the team responsible for processing and managing reports. When necessary, individuals with specialized knowledge may access the information and thus may be included in the investigation process. These individuals can access relevant information, appropriately anonymized, excluding data related to the identity of the whistleblower and other participants, and are also bound by confidentiality obligations. If the information communicated to these individuals allows the identification of the whistleblower, such information will not be disclosed.

Feedback to the whistleblower.

Within seven (7) days from the receipt of the report, the RJRI will acknowledge receipt of the same, informing them, in a clear and accessible manner, of the requirements, the competent authorities, the manner, and admissibility of the external report.

Within a maximum of three (3) months from the date of receipt of the report, the RJRI will inform the whistleblower of the measures planned or adopted to follow up on the report and their justification.

The whistleblower may request at any time that the obligated entities communicate the result of the analysis of the report within fifteen (15) days after its conclusion.

How is the investigation conducted?

All reports will be carefully analyzed to determine if they fall within the scope of this Policy and if an investigation is necessary, determining if there is sufficient evidence to support the reported facts. If applicable, the RJRI will take necessary actions to cease the reported infraction.

The management of each report will be carried out by the team responsible for processing and managing reports.

Whenever it is necessary to hear witnesses, indicated by the whistleblower or deemed pertinent by the RJRI for the investigation, a record of the witness's statements will be drafted. After the meeting with the witness, the record will be made available for validation via email. Once validated through the witness's email response, the final document will be archived, along with the witness's validation email, in the respective report process.

The identity of the whistleblower will not be disclosed by the RJRI to any potential witnesses.

In what situations can the identity of the whistleblower be disclosed? And to whom?

The identity of the whistleblower is disclosed by the RJRI only if one of the following circumstances occurs:

Legal obligation; or
Judicial decision.