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Whistleblowing Policy

 

Closer Whistleblowing Policy

This Whistleblowing Policy (Policy) of Closer – Software Development and Data Science Services (Closer) aims to establish the principles and rules applicable to the management of the implemented whistleblowing channel and to the reports received by Closer through it, in compliance with the general regime for the protection of whistleblowers, approved by Lei n.º 93/2021, de 20 de dezembro (RGPDI), and the general regime for the prevention of corruption, approved in annex to Decreto-Lei n.º 109-E/2021, de 9 de dezembro (RGPC).

Whistleblowers are considered to be all Employees, clients, business partners and any natural person who reports or publicly discloses an infringement based on information obtained within the scope of their professional activity, regardless of the nature of such activity and the sector in which it is carried out, as well as regardless of whether the professional relationship has meanwhile ceased or the information was obtained during a recruitment process or during another stage of pre-contractual negotiation of an established or non-established professional relationship.

 

You can read and download Closer’s full compliance plan here.

 
 

Whistleblowing Channel

A report is submitted when there is a suspicion of a non-conformity, irregularity, illegality or unlawful act, without any type of reward, for the benefit of the organisation’s interests or the public interest, and the +transparente Platform adopted by Closer must be used for reporting such situations. (At Closer, verbal reporting is not admissible for the purposes of the whistleblowing channel referred to in the RGPDI).

A report differs from a complaint in that the latter is a communication addressed to the author (or with that intention) regarding a non-conformity in an act or service provided by Closer employees to its CLIENT (namely through the provision of a service, supply of a product or conduct by an employee that does not meet Closer’s high ethical and quality standards).

Whenever a report constitutes the practice of a crime, the whistleblower shall be informed that they must communicate it to the competent Criminal Police Authority (Órgão de Polícia Criminal), where the complaint depends on them, or Closer shall forward it to the competent Criminal Police Authority if it concerns a crime that does not depend on a complaint from the injured party/victim.

 

You can access our whistleblowing channel here.

Closer is a Data Science company specialized in Data Engineering, Business Intelligence and Artificial Intelligence.

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