Whistleblowing Policy

Introduction

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This Whistleblowing Policy applies to the LAS Group, comprising the following corporate entities:

• Louro Aeronaves e Serviços, Lda.;

• SLOT – Empresa de Trabalho Temporário, Lda.;

• LASFORMAÇÃO – Prestação de Serviços de Formação, Unipessoal, Lda.

Law No. 93/2021 of 20 December established the General Regime for the Protection of Whistleblowers (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.

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This legislation entered into force on 18 June 2022 and aims to protect any natural person who reports or publicly discloses:

• A breach that has been committed;

• A breach that is being committed;

• Other breaches that can reasonably be anticipated.

What should be reported?

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Whistleblowers may report information obtained in the course of their professional activities concerning suspected or actual breaches relating to:

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a) Corruption and conflicts of interest;

b) Ethics and good business practices;

c) Unauthorised disclosure of information relating to clients or suppliers;

d) Situations that may compromise the proper functioning of the organisation.

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Who can make a report?

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Any natural person who reports a breach through the designated reporting channel, based on information obtained in the course of their professional activities, regardless of the nature of those activities or the sector in which they are carried out, provided they are directly or indirectly related to the organisation's activities, shall be considered a whistleblower.

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This includes, but is not limited to:

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a) Employees in the private, public or social sectors;

b) Service providers, contractors, subcontractors and suppliers, as well as any persons acting under their supervision or direction;

c) Shareholders and members of the administrative, management, supervisory or governing bodies of legal entities, including non-executive members;

d) Volunteers and trainees, whether paid or unpaid.

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A person shall also be considered a whistleblower where the reported information was obtained during a professional relationship that has since ended, or during a recruitment process or any other stage of pre-contractual negotiations, irrespective of whether a professional relationship was ultimately established.

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How can you submit a report?

Reports may be submitted by email to: denuncia@las.pt using the reporting channel corresponding to the relevant LAS Group company or brand concerned by the report.

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What happens after a report is submitted?

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Reports received through this channel are forwarded to the designated person responsible for handling whistleblowing reports, who ensures that every report is managed promptly, fairly and in accordance with applicable legislation.

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All reports are handled in strict confidence, and whistleblowers are protected against any form of retaliation.

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Persons who are the subject of an investigation will be informed of the allegations against them, given the opportunity to respond and, where applicable, to appeal any adverse findings.

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Where a report is substantiated, appropriate corrective measures will be implemented without delay.

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Personal Data Protection

LAS Group, acting as the data controller, processes the information collected in order to investigate reports, communicate with the whistleblower where necessary and comply with its legal obligations.

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The legal basis for processing personal data is the whistleblower's consent and compliance with applicable legal obligations, as set out in our current Privacy Policy.