Law 93/2021


Vieira & Lopes, Lda. promotes a climate of dialogue that allows everyone to freely express and share their concerns. As such, it has implemented a procedure reserved for reporting irregularities, the aim of which is for the company’s competent bodies to respond to reports of irregularities. The system is open to all company employees and third parties.

Through this procedure it is possible to confidentially report any specific type of error or serious violation of the law which could constitute a criminal or civil offence and, in general terms, to report any unethical behaviour.

Scope of Application and Definition of Irregularity

A) Irregularities for the purposes of the Whistleblowing Policy and Procedures are facts that seriously violate or harm:

  • The fulfilment of legal, regulatory and ethical principles by the members of the administration and employees of Vieira & Lopes, Lda. in the exercise of their professional positions;
  • The assets of Vieira & Lopes, Lda. and its Ocramclima brand, as well as the assets of customers, suppliers and business partners, or of any company it names;
  • The good management practices, image and reputation of Vieira & Lopes, Lda. or any company it names.

B) For the purposes of the Whistleblowing Policy, irregularities also include acts or omissions by employees, clients, suppliers or business partners that could give rise to civil or criminal liability.

C) Complaints regarding the quality of products or services provided by Vieira & Lopes, Lda. or any company it names, or any fact that goes beyond the provisions of A. and B. above, shall not be considered irregularities for the purposes set out above.

Procedure for Reporting Irregularities

Any communication of facts that may constitute irregularities under the terms of A. and B. of the previous point should be made using the form below or sent to the following email address: denuncias@vieiralopes.pt – the complaint will be sent to the Ethics Officer of Vieira & Lopes, Lda. Alternatively, it should be sent to:

Head of Etics at Vieira & Lopes, Lda.
Lugar do Faial – Rua 1, 157
Vila de Prado
4730-460 Vila Verde

b) The communication of irregularities must contain a description of the facts that support it, be labelled as confidential and whenever possible be included in a format, material or digital, that guarantees its inviolability until it is received by the ethics officer.

c) The author of the irregularity report must state in their report whether they wish to keep their identity confidential. All communications whose sender is not clearly identified may be investigated provided that sufficient information is provided for the complaint to proceed.

Confidential Treatment

A) The identity of the whistleblower, as well as information that directly or indirectly allows their identity to be inferred, is confidential and restricted to the ethics officer of Vieira & Lopes, Lda., except in situations arising from legal obligation or judicial decision.

B) Without prejudice to other legal provisions, the disclosure of information is preceded by written communication to the whistleblower indicating the reasons for disclosing the confidential data concerned, except if providing this information would compromise investigations or related judicial processes.

C) The confidentiality of the whistleblower’s identity shall not prevent the ethics officer from contacting them to gather other information that may be necessary to investigate the reported facts.

Investigation of Irregularities

A) The ethics officer will investigate all facts susceptible to integration into the current irregularities communication policy, having access to the necessary and appropriate tools to investigate the reported facts.

B) As a guarantee of accuracy and impartiality in the investigation of facts, mentioned in the preceding paragraph, any person who may have a conflict of interest with the outcome of the investigation process or the subject matter under investigation, even indirectly, shall be automatically excluded from the investigation process.

Irregularities Handling Process

A) The Ethics Officer of Vieira & Lopes, Lda. shall ensure that, in assessing the irregularities reported to them, in accordance with the Irregularities Communication Policy, swift treatment will be provided to ensure the effective implementation of any applicable corrective measures.

B) The Ethics Officer shall inform the whistleblower of the outcome of the investigation process and of any measures (if any) that have been taken as a result of the investigation of the reported irregularity.

C) Compliance with the obligation of the Ethics Officer provided in the preceding paragraph shall not be required for anonymous reports falling within the scope of this Irregularities Communication Policy.

Conclusions of the Evaluation Process and Corrective Measures

A) Upon completion of the investigation process, subsequently and whenever advisable or necessary, the Ethics Officer shall propose to the bodies of Vieira & Lopes, Lda. or any other company named by it, the adoption of measures deemed necessary to address the reported and proven irregularity.

B) Reports are archived without further action when the Ethics Officer, by simple decision, considers that:

I. The reported violation is of minor, insignificant, or manifestly irrelevant gravity;

II. The report is repetitive and does not contain new factual or legal elements justifying a different course of action from that taken regarding the initial report; or

III. The report is anonymous and does not provide indications of a violation.

Prohibition of Retaliation

A) Vieira & Lopes, Lda. undertakes, towards any whistleblower, not to allow, as a result of such reporting, dismissal, harassment, or suspension or withholding of payments that are due.

B) The exclusion referred to in the preceding paragraph shall not apply to any whistleblower’s potential involvement in the commission of any reported irregularity or to the demonstration of the whistleblower’s bad faith in making a report they knew to be unfounded.