INTRODUCTION AND POLITICS

Nosco Couture, in addition to strict compliance with applicable laws and regulations, is governed by principles of professional ethics that must, in all circumstances and in all locations, inspire the behavior of its employees. This is thus considered a distinctive factor in strengthening trust among all its stakeholders.

Through the implementation of this channel it is intended to allow the reporting, both of employees and third parties, of any situations that violate the rules on which the principles of Business Ethics are based, namely: Respect for legality, respect for people and fight against corruption.

Your report will be received and handled by the Manager of this channel. If the Channel Manager is eventually targeted in your complaint, you should exclude it from your receipt and follow-up.

For more information, please refer to the FAQs.

REPORTING OF INFRACTIONS

This Reporting Channel, in its entirety, is implemented according to the requirements of Law No. 93/2021 of 20 December, which establishes the general regime for the protection of whistleblowers of infractions, so Nosco Couture guarantees the whistleblower the same level of protection in any of the areas reported.

All personal data is protected in accordance with the Company’s Privacy Policy, which you can consult in the Guides and Documents area.

The record of complaints received shall be kept for at least five years and, irrespective of such period, for as long as legal or administrative proceedings relating to the complaint are pending.

Personal data that are clearly not relevant to the handling of complaints will not be kept and shall be deleted immediately.

FREQUENTLY ASKED QUESTIONS

1) Who can make a complaint?

This Reporting Channel may be used by Nosco Couture employees, regardless of their contractual relationship, as well as by all natural persons who in the course of their professional activity in any way relate to the Company (e.g. supplier s workers, service providers, contractors and subcontractors, public entities,…), including persons belonging to management or
management bodies or tax or supervisory bodies, volunteers and trainees, paid or unpaid, candidates in the recruitment process and competitors in procurement processes.

2) How can I report it?

The complaint can only be made in writing, and the whistleblower may choose to make it anonymously or identify himself, in the channel of denunciation

https://nos-co.form.maistransparente.com

3) What infractions can I report on this channel?

You may report, in good faith and on serious grounds to believe that the information is, at the time of the complaint, true, offences committed, that they are being committed or which can reasonably be foreseen, as well as attempts to conceal such offences of which you have personally known and that from your point of view constitute a serious violation of the rules on which the principles of Business Ethics are based, in particular respect for legality, persons and the fight against corruption falling into the following categories:
Public Procurement and Award of Concessions;
Private Contracting of Goods and Services;
Licensing;
Competition;
Environment;
Employee Safety, Service Providers, Contractors, Subcontractors, etc.;
Aeronautical Sector Safety;
Privacy and Data Protection and Networks and Information Systems:
Harassment and Discrimination;
Others (under Article 2 of Law No. 93/2021).

4) I want to make a complaint. Can I do it on this channel?

Any type of complaint is excluded from the scope of this Reporting Channel. For the purpose of complaints or suggestions, the email can be used eticaeconduta@nos-co.pt.

Any claim received by this route will not be followed up and will be returned with due reasoning.

5) Why should I file a complaint?

Because, in this way, we can contribute to the Company being able to take the necessary measures to rein in the situation, as well as to prevent it, or another similar situation, from repeating itself.

6) What happens after a complaint is submitted?

All complaints are received by an Independent Manager who operationalizes the Whistleblowing Channel, which will review it in order to decide on its admissibility, and may, depending on its assessment, make an effort to open an internal investigation and/or communicate it to the competent authorities to investigate the alleged infringement.
After submission of the complaint, its author will then:
• informed of the good reception and admissibility of the complaint;
• informed of the follow-up given to him;
• contacted if additional information is required;
• informed of the measures envisaged or taken to follow up the complaint and its reasoning.

7) How is my anonymity guaranteed?

When submitting your complaint, using the option of the form “Report anonymously”, your communication will be kept anonymous and, at no time during the communication process, you will be asked for personal information, so you should not mention data that may facilitate the recognition of your identity.

Anonymity will be guaranteed through the encryption of messages and other security routines ensured by the system, and all communications are made exclusively via the Reporting Channel, being accessible by clicking on the “Follow up existing complaint” button.

8) How is confidentiality guaranteed?

The identity of the whistleblower, as well as the information that, directly or indirectly, allows deducing his identity, as well as the identity of third parties mentioned in the complaint, are confidential in nature and are restricted access to the Independent Manager who operationalizes the Reporting Channel.

The obligation of confidentiality extends to those who have received information about complaints.

The identity of the whistleblower is only disclosed as a result of legal obligation or judicial decision.

Disclosure of the information is preceded by written communication to the whistleblower indicating the reasons for the disclosure of the confidential data in question, unless the provision of such information compromises investigations or related legal proceedings.

9) Can I trust that my complaint will be handled with exemption?

The receipt and follow-up of complaints is carried out by the Independent Manager of the Reporting Channel, in an impartial and independent manner, and safeguard procedures are ensured in case of any situation of conflict of interest.

10) The Independent Reporting Channel Manager is targeted in my complaint. How am I supposed to do it?

You can exclude the member concerned in the complaint, when filling out the respective form, which will be automatically with the access sealed to it and excluded its intervention from any stage of the process. The process will be assigned to another Independent Manager.

However, if that second Manager finds that the excluded member is not targeted in the complaint, they will refund access to him.

11) What is the deadline for responding to my complaint?

Be:
• Informed within a maximum of 7 days of receipt of the complaint, on the requirements, competent authorities and form of admissibility of the external complaint;
• Informed within a maximum of 3 months of the measures envisaged or adopted to follow up the complaint and its reasons for it;
• Informed of the result of the complaint analysis, if you require it, within a maximum of 15 days, after its completion.

12) How can I access my report?

Once you submit a report, you receive a reference to the automatically created process, and you are prompted to store a password.

Please note: These personal and confidential references are the only means to access and track your complaint process (in case of loss or forgetfulness, they cannot be reset).

Through the “Follow up existing complaint” button you have access to the messages exchanged, allowing you to monitor the evolution of the process, ask questions, complete your communication, dialogue directly with the actors in the Reporting Channel protecting the confidentiality of communications.

13) How am I, as a whistleblower, protected from retaliation?

This Reporting Channel, in its entirety, is implemented in accordance with the requirements of Law No. 93/2021 of December 20, which establishes the general regime for the protection of whistleblowers of infractions, so Nosco Couture guarantees the whistleblower the same level of protection in any of the areas reported, in particular by ensuring that it will not be the target of acts of retaliation and employing the necessary and appropriate means to cease any such act that it is aware of, or that it is being committed against it.

14) How is the personal data that is part of my report protected?

All personal data is protected in accordance with the Company’s Privacy Policy, which you can consult in the Guides and Documents area.

The record of complaints received shall be kept for at least five years and, irrespective of such period, for as long as legal or administrative proceedings relating to the complaint are pending.

Personal data that are clearly not relevant to the handling of complaints will not be kept and shall be deleted immediately.