If you are aware of facts, evidence or
information about infringements that have already been practiced or that carry a
high probability of being practiced, or are being executed, due to the breach
of the rules set out in the Securities Code and its regulations, the breach of
the duties via other national or EU laws on market abuse, you may communicate said
to the CMVM.
Reporting made to the CMVM shall contain,
whenever possible or applicable, a detailed explanation of the possible
infraction, including information on dates, identification of the persons and
entities involved. It should also be supported, if possible, by documentation.
This area is aimed, in particular, for individuals
with specific knowledge about how reported entities function internally, for
example, because they are employees of the entity or have some type of
contractual relationship with the entity (framework envisaged under articles
368/A to 368/E of the Portuguese Securities Code).
Channels
for presenting information and evidence
In Lisboa, Rua Laura Alves, n.º 4, between 09h30 and 17h00, provided that it has been previously scheduled with the Investigation Department (via telephone +351 213 177 000, with the express indication that the intent is to contact the
Investigation Department and that the contact is CONFIDENTIAL).
CMVM – Investigation
Department (envelope should be marked ‘CONFIDENTIAL’)
Rua Laura Alves, n.º 4
P.O. BOX 14258
1064-003 Lisbon
Portugal
E-mail:
whistleblowing@cmvm.pt
Protection of identity and confidentiality
You may
provide information, evidence and facts regarding possible infringements
relating to the market abuse framework, on an anonymous basis or by identifying
yourself.
The CMVM encourages participants to provide at
least one means whereby they can be contacted at a later date if this proves
necessary in the course of the investigations, notwithstanding the possibility
of submitting anonymous reports.
Depending on the content of each complaint, the
CMVM may request additional elements and information from the complainant in
order to obtain clear and complete knowledge of the exposed situation.
If you wish to remain anonymous, you should not
submit any personal information or other information that allows for any type of identification.
Employee Protection
The CMVM ensures the confidentiality of the
identity of the complainant at any time or until such time as this information
is required in order to safeguard the right of defence of those targeted by the
complaint, in the context of the investigations to which it gives rise or of the
subsequent legal proceedings.
Persons who provide information under this framework
concerning issues relating to market abuse, are not considered to be infringing
any restriction on the transmission of information imposed by contract or by
any legislative, regulatory or administrative provision and should thus not be
liable for said reporting. (i.e. disciplinary liability).
Procedures
for receiving information, evidence and complaints
The CMVM gives you written notice of the
receipt of information, evidence or complaints, in electronic format or by
letter, if you have provided a contact for said purpose, except in situations
where you have expressly stated otherwise or it is foreseeable that such
communication may hinder your anonymity.
All complaints must be made in good faith and
with reasonable grounds.
Without prejudice to possible criminal
liability, reporting information, facts or sending evidence to the CMVM that is
false, constitutes a very serious administrative infraction.
If the facts, evidence or information disclosed
concern infractions within the possible jurisdiction of other entities, the
CMVM informs you of this - whenever possible - and you will then be responsible
for sending the information to the competent authority. If this is not
possible, the CMVM may send the information communicated to any other entity
with whom it has legal relations of collaboration or cooperation.
