Núcleo Assets, a brand of Five Ducks Lda (NIPC 517041073), provides this whistleblowing channel for reporting breaches or irregularities related to its activities, in compliance with Law no. 93/2021 of December 20.
This channel may be used by employees—including fixed-term, part-time, or temporary workers—job applicants and former employees, service providers, contractors, subcontractors, suppliers, and individuals working under their supervision or direction, as well as shareholders or equity holders, members of management, administrative, audit, or supervisory bodies, volunteers and interns (paid or unpaid), and any natural person who, in a current, past, or pre-contractual professional context, has become aware of a breach or irregularity.
The channel is intended for reporting well-founded suspicions or actual instances of fraud, corruption, money laundering or terrorist financing, breaches of legal or regulatory obligations applicable to the company’s activities, undisclosed conflicts of interest, moral or sexual harassment, discriminatory behavior, violations related to personal data protection, and any other irregularities relevant to Núcleo Assets’ operations.
Reports may be submitted in writing or verbally, including by voice message or, at the whistleblower’s request, through an in-person meeting.
The whistleblower may choose to identify themselves or remain anonymous. In all cases, the identity of the whistleblower, the persons concerned, and any third parties mentioned in the report, as well as the information provided, will be handled with strict confidentiality and will only be accessible to those authorized to receive and follow up on reports, without prejudice to any legally required disclosures.
Núcleo Assets neither engages in nor tolerates any form of retaliation against individuals who report in good faith and have reasonable grounds to believe that the information provided is true at the time of reporting. This protection also extends, as provided by law, to individuals connected to the whistleblower who may be subject to retaliation, including colleagues, family members, or entities linked to them in a professional context.
Reports are reviewed independently, impartially, and confidentially, with due respect for the right of defense and the presumption of innocence of the persons concerned. The receipt and handling of reports are ensured by Management, through a designated officer, with guarantees of independence, impartiality, and confidentiality.
Reports received will be retained for at least five years and, regardless of this period, for the duration of any judicial or administrative proceedings related to the report.
The whistleblower will receive acknowledgment of receipt within seven days and, within a maximum of three months from receipt, information on the measures planned or taken in response to the report, along with the respective grounds.
This channel was implemented in compliance with Law no. 93/2021 of December 20, which establishes the general framework for the protection of whistleblowers and transposes Directive (EU) 2019/1937 into Portuguese law. For detailed information on how personal data is processed in connection with this channel, please refer to our Privacy Policy.
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