1. Purpose

Granorte – Revestimentos de Cortiça, LDA adopts this procedure with the aim of not only ensuring compliance with a legal obligation but also establishing a set of internal rules and procedures for receiving, recording, and handling reports of infractions. This is done in accordance with the applicable legal and regulatory provisions, as well as the rules, principles, and values outlined in the Ethics, Anti-Corruption, and Anti-Bribery Policy.

To achieve this goal, reports of infractions under this procedure will be submitted through an effective, prompt, and reliable system for detection, investigation, and resolution, in line with the highest ethical standards recognized by Granorte. The principles of confidentiality and non-retaliation are safeguarded in relation to whistleblowers and to individuals and third parties, including legal entities, who assist or are linked to the whistleblower.

2. Scope

This procedure establishes the rules for receiving, recording, and handling reports of infractions that occur within Granorte.

Granorte – Revestimentos de Cortiça, LDA provides a Whistleblowing Channel in accordance with Law No. 93/2021 (which transposes EU Directive 2019/1937 – Whistleblowing Law).

The whistleblowing channel serves as the company’s internal mechanism for managing and analyzing practices, actions, or events reported by internal or external agents that violate national or EU legislation in the following areas:

a) Employment practices and contracting;
b) Products and/or services (compliance, safety, and consumer protection);
c) Financial and economic practices;
d) Environmental protection and public health;
e) Privacy, personal data protection, and network/information system security.

Reports should include as much detail and information as possible and, when available, be supported by documentation. Depending on the content of each report, additional information or clarification may be requested.

Reports may be submitted by:

a) Employees or former employees;
b) Service providers;
c) Members of statutory bodies;
d) Interns;
e) Job applicants.

The whistleblower is guaranteed confidentiality and anonymity unless disclosure is necessary for internal investigations or legal proceedings. All reports must be made with reasonable grounds and in good faith. Retaliation against the whistleblower is strictly prohibited.

3. Subjective Scope of Application

For the purposes of this procedure, a whistleblower is defined as an individual who reports an infraction based on information obtained within their professional activities, regardless of the nature or sector of the activity.

Whistleblowers may include employees, service providers, contractors, subcontractors, suppliers, and any other individuals acting under their direction or supervision, as well as management members and interns (paid or unpaid).

4. Internal Reporting Priority and Prohibition of Public Disclosure

Since an Internal Whistleblowing Channel exists, whistleblowers cannot resort to external reporting channels or publicly disclose an infraction unless in the cases referred to in paragraphs 2 and 3 of Article 7 of Law No. 93/2021 of December 20.

A whistleblower who, outside the legally established cases, publicly discloses an infraction or informs the media will not benefit from the legal protection provided by the law.

5. Confidentiality

All reports of infractions covered by this procedure will be treated as confidential. Access to information related to a report, including the whistleblower’s identity (if known), is restricted to Granorte personnel responsible for receiving and handling reports. The obligation of confidentiality extends to all individuals who receive information about reports, even if they are not directly responsible for handling them.

The whistleblower's identity may only be disclosed to comply with legal obligations or court decisions. In such cases, the whistleblower will be notified in writing with the reasons for disclosure, except when doing so would compromise ongoing investigations or judicial proceedings.

6. Reception, Recording, and Handling of Reports

Reports under this procedure must be submitted through the Internal Whistleblowing Channel, in writing:

a) By letter sent to the postal address: Avenida Santiago, nº68 – 4520-470 Rio Meão
b) By email to: whistleblowing@granorte.pt

The whistleblower may choose their preferred reporting method.

7. Follow-up Process

The whistleblower will receive:

• Within seven days – Acknowledgment of receipt of the report;
• Within three months – Notification of the outcome, reasoning, and any measures taken as a result of the report;
• Within 15 days after conclusion (upon request) – Communication of the results of the analysis conducted. Reports will be retained for five years or for the duration of any related legal or administrative proceedings.

8. Effectiveness

This procedure takes effect immediately upon publication.