Whistleblowing Policy
1. Introduction
This Whistleblower Protection Policy applies to LAS GROUP, comprising three corporate entities: Louro Aeronaves e Serviços, Las., Lda., SLOT – Empresa de Trabalho Temporário, Lda. and LASFORMAÇÃO – Prestação de Serviços de Formação, Unipessoal, Lda.
Portuguese Law No. 93/2021 of 20 December established the General Framework for the Protection of Whistleblowers (Regime Geral de Proteção de Denunciantes de Infrações – RGPDI), transposing Directive (EU) 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law.
This framework entered into force on 18 June 2022 and aims to protect any individual who reports or publicly discloses information concerning:
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A breach that has occurred;
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A breach that is ongoing;
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A breach that can reasonably be expected to occur.
2. What should be reported?
Whistleblowers may report information obtained in a professional context relating to suspected irregularities or actual or potential breaches concerning:
a) Corruption and conflicts of interest;
b) Ethics and good practices;
c) Disclosure of information to clients or suppliers;
d) Situations that may compromise the proper functioning of the organisation.
3. Who can report a concern?
Any individual who reports a breach through the designated reporting channel, based on information obtained in the context of their professional activities, regardless of the nature of those activities or the sector in which they are carried out, may be considered a whistleblower, provided that the matter is directly or indirectly related to their professional activities.
Whistleblowers may include, in particular:
a) Employees in the private, social or public sectors;
b) Service providers, contractors, subcontractors and suppliers, as well as any persons working under their supervision and direction;
c) Shareholders and persons belonging to the administrative, management, supervisory or governing bodies of legal entities, including non-executive members;
d) Volunteers and trainees, whether paid or unpaid.
An individual may also be considered a whistleblower where the information on which the report is based was obtained during a professional relationship that has since ended, during a recruitment process or during any other stage of pre-contractual negotiations, regardless of whether the professional relationship was ultimately established.
4. How can you submit a report?
Reports may be submitted in writing by email to the reporting address applicable to LAS Group:
5. What happens after a report is submitted?
Reports received through this channel are forwarded to the person responsible for handling them, who ensures that each report is dealt with promptly, fairly and in accordance with the law.
All concerns are treated confidentially, and whistleblowers are protected against retaliation in accordance with the applicable legal requirements.
Individuals who are the subject of an investigation will be informed in accordance with the applicable legal requirements and will be given the opportunity to respond to the allegations and, where applicable, challenge any adverse findings.
Where a reported breach is substantiated, appropriate action will be taken without undue delay.
6. Protection of Personal Data
LAS Group, as data controller, processes the information collected for the purposes of investigating reported concerns, making any communications necessary for the handling of the case and complying with applicable legal obligations.
Personal data is processed on the applicable lawful grounds and in accordance with the LAS Group Privacy Policy and applicable data protection legislation.