Reporting Channel Regulation

Purpose
1.1. CARM – Casa Agrícola Roboredo Madeira S.A. (hereinafter “CARM”) rejects any violations of applicable legal and regulatory standards. In this regard, and in compliance with the law, CARM has established an internal reporting channel and a set of rules and procedures for the receipt, handling, and recording of reports of misconduct, as set out in this Regulation.

1.2. Reports submitted under this Regulation shall be processed through a secure, impartial, effective, and appropriate internal system for their receipt, investigation, and resolution, and shall be treated with confidentiality and discretion. Any retaliation against the reporting person is strictly prohibited.

Scope of application; Definitions
2.1. This Regulation establishes the rules for the receipt, processing, and recording of reports of misconduct under Law No. 93/2021 of 20 December.

 2.2. For the purposes of this Regulation:
a) Misconduct – acts or omissions, whether intentional or negligent, as defined in Article 2(1) of Law No. 93/2021 of 20 December and Article 3 of Decree-Law No. 109-E/2021 of 9 December, namely in the following areas:
• Public procurement
• Financial services, products, and markets, and prevention of money laundering and terrorist financing
• Corruption
• Product safety and compliance
• Transport safety
• Environmental protection
• Radiation protection and nuclear safety
• Food and feed safety, animal health, and animal welfare
• Public health
• Consumer protection
• Protection of privacy and personal data, and security of network and information systems
• Prevention of corruption and related offences
b) Reporting person – a natural person who reports misconduct based on information obtained in the course of their professional activity, regardless of its nature or sector. Reporting persons may include, in particular: (i) employees, (ii) service providers, contractors, subcontractors and suppliers, as well as persons acting under their direction or supervision, (iii) shareholders, members of management and supervisory bodies, and (iv) volunteers and trainees (paid or unpaid).
c) Reported person – the person identified in the report as the alleged perpetrator or otherwise associated with the misconduct.

Priority of internal reporting channels and public disclosure
3.1. Given the existence of an internal reporting channel, the reporting person may not use external reporting channels or publicly disclose misconduct, without prejudice to the exceptions provided by law, namely Article 7 of Law No. 93/2021 of 20 December.

3.2. A reporting person who, outside legally permitted cases, publicly discloses misconduct or communicates it to the media shall not benefit from the protections granted by law.

Receipt, processing, and recording of reports of misconduct
4.1. Reports under this Regulation shall be submitted through the Internal Reporting Channel, in writing, using one of the following methods:

a) by sealed letter marked “confidential”, with proof of receipt, sent to:
CARM Reporting Channel
Rua de Calábria S/N
5150-021 Almendra
Portugal
b) by email to info@carm.pt, with the subject line “Confidential – CARM Reporting Channel”.
4.2. The reporting person shall be notified within 7 (seven) days of receipt of the report by CARM.
4.3. Following receipt of the report:
4.3.1. CARM shall take appropriate internal measures to verify the allegations contained therein and, where applicable, to bring the reported misconduct to an end, including opening an internal investigation or notifying the competent authority for investigation.
4.3.2. If contact details have been provided, CARM shall communicate to the reporting person the measures planned or adopted and the respective justification within 3 (three) months from the date of receipt of the report.

Confidentiality
5.1. The receipt and follow-up of reports shall be carried out by persons or services specifically designated for this purpose.

5.2. The identity of the reporting person, the reported person, and persons associated with them, as well as the information contained in the report, are confidential and restricted to those responsible for receiving or following up on reports, without prejudice to legal obligations or court decisions. 

Personal data processing
For the purposes of receiving, following up, recording, and retaining reports, the personal data collected by CARM in this context shall be processed in accordance with Regulation (EU) 2016/679 of 27 April and Law No. 58/2019 of 8 August. 

Recording and retention of reports
CARM shall keep a record of all reports received and retain them for at least 5 (five) years, and regardless of this period, for as long as judicial or administrative proceedings related to the report are ongoing.

Prohibition of retaliation
8.1. Any acts of retaliation against the reporting person are prohibited.

8.2. Retaliation means any act or omission, directly or indirectly occurring in a professional context and motivated by a report, which causes or may cause unjustified harm to the reporting person, whether material or non-material.

Amendments
This Regulation may be amended at any time by CARM.