This document establishes and consolidates the Whistleblowing Regulation applicable to individuals who become aware of violations in a professional context, including employees, clients, suppliers, members of corporate bodies, and other professional collaborators.
It sets forth a set of rules aimed at ensuring the effective protection of whistleblowers across relevant legal and policy areas. It outlines the protective measures available, as well as the internal procedures for receiving, processing, and following up on reports of misconduct, in line with applicable legal provisions and the values and internal rules of Hexa.
CONDITIONS FOR REPORTING
Whistleblowers are eligible for protection under this Regulation if:
- They act in good faith;
- They had reasonable grounds to believe the information reported was true at the time of disclosure and that it falls within the Regulation’s scope;
- They are later identified and face retaliation, despite having reported or publicly disclosed the information anonymously.
PERSONAL SCOPE
This Regulation applies to:
- Employees;
- Clients;
- Suppliers;
- Members of the Board or shareholders;
- Members of management or supervisory bodies;
- Individuals working under the supervision of Hexa contractors, subcontractors, or suppliers;
- Individuals who report or disclose information obtained in a professional relationship that has since ended.
Protection is also extended to:
- Facilitators: natural persons who assist the whistleblower confidentially;
- Third parties: such as colleagues or family members at risk of retaliation;
- Legal entities: owned by or professionally linked to the whistleblower.
OBJECTIVES OF THE REPORTING CHANNEL
The reporting channel covers irregularities including, but not limited to:
- Public procurement;
- Financial services, markets, and anti-money laundering;
- Product safety and compliance;
- Transport and infrastructure security;
- Environmental and radiation protection;
- Public and animal health, food and feed safety;
- Consumer protection and data privacy;
- Information systems and cybersecurity;
- EU financial interest violations;
- Violent and organized crime, including economic and financial crimes;
- Violations of internal policies or codes of conduct.
REPORTING CHANNELS
Hexa provides an internal reporting channel that guarantees confidentiality. Reports may be submitted anonymously (in which case the whistleblower must expressly request anonymity at the time of submission) or with the confidentiality of the whistleblower’s identity ensured by the personnel authorised to handle the report. In either case, the report may be submitted in writing and/or verbally.
In any event, the written report (for written submissions) and/or the contact request to report verbally (for verbal submissions) must be sent to the following email address: compliance@hexa-group.pt.
HANDLING AND FOLLOW-UP
All reports will be treated as strictly confidential. Designated authorized personnel, who are subject to impartiality and confidentiality clauses, are responsible for:
- Acknowledge receipt of the report;
- Communicating with the whistleblower;
- Requesting additional information, where needed;
- Inform the whistleblower about the progress of the case.
GOVERNANCE AND COMPLIANCE
Given the sensitive nature of information received, Hexa Consulting applies the need-to-know principle:
- The identity of the whistlebloweris only accessible to the Compliance Officer and authorized staff;
- All handling is conducted independently, with full decision-making autonomy and appropriate resources;
- The identity of the Compliance Officer remains undisclosed to ensure integrity and neutrality of the channel;
- All authorised personnel are subject to a specific NDA safeguarding whistleblower information.
INVESTIGATION PROCESS
Each report is assessed to determine if it provides sufficient grounds to initiate an investigation. If substantiated, the report is documented and investigated accordingly.
- If found valid, corrective or disciplinary actions are taken, as appropriate.
- If unfounded, the report is formally closed and archived.
In all cases, the whistleblower will be informed of the outcome or follow-up.
PROTECTION MEASURES
Whistleblowers and facilitators are protected from retaliation of any kind, including:
- Professional harm, harassment, or dismissal;
- Direct or indirect acts of intimidation;
- Discrimination or unjustified disciplinary action.
Any person committing retaliationmay be held legally accountable and required to compensate the whistleblower.
EXCEPTION FOR DISCLOSURE OF IDENTITY
If exceptionally necessary for the investigation or to safeguard the rights of defense of the person concerned, the whistleblower’s identity may be disclosed only with prior, individualized, and explicit consent.
This consent may be waived only when required to protect national investigations or legal proceedings by competent authorities.
SUPPORT AND LEGAL ASSISTANCE
Whistleblowers may benefit from:
- Legal protection and guidance under general law;
- Witness protection measures applicable in criminal proceedings;
- Certification confirming whistleblower status, issued by Hexa if needed.
PERSONAL DATA AND CONFIDENTIALITY
Hexa guarantees:
- Confidentiality of the identity of the whistleblower and third parties involved;
- Exclusive use of collected information for purposes of reporting and investigation;
- Compliance with the General Data Protection Regulation (GDPR), especially regarding data minimization, processing limitations and confidentiality and access restrictions.
NON-WAIVABLE RIGHTS
The rights granted under this Regulation cannot be waived, limited, or overridden by any contract, policy, or internal document. Any clause to that effect is considered null and void.
DATA RETENTION AND EVALUATION
Reports will be retained, solely for the purpose of:
- Assessing the effectiveness of the Whistleblowing Channel;
- Supporting Hexa Consulting’s prevention strategy;
- Improving resource allocation and operational response;
- Contributing to broader insights on irregularities and organizational risks.
This Whistleblowing Process undergoes an annual review based on the report on the implementation and operation of the internal reporting channel and is fully endorsed and supported by the management of Hexa.
READ MORE ABOUT OUR WHISTLEBLOW PROCESS
