Whistleblowing Protection



The purpose of this Policy is to regulate the use of the Whistleblowing Channel, through which any employee of the company under a labor or service contract, volunteer or trainee, paid or unpaid, Shareholders, Board of Directors of Onitelecom – Infocomunicações, S.A. or third parties outside the company, namely suppliers, customers and/or business partners (hereinafter “Whistleblowers”), who know or suspect of a legal or regulatory violation on the following subjects:

(i) Public procurement;
(ii) Prevention of money laundering and terrorist financing;
(iii) Environment protection;
(iv) Public health;
(v) Consumer protection;
(vi) Protection of privacy and personal data, network, and information systems security;
(vii) Code of Conduct and other internal policies established by ONI.

may inform ONI, thus complying with the requirements of Directive (EU) 2019/1937 and national law (Lei n.º 93/2021 | DRE) governing the protection of Whistleblowers.


The protection of rights set out in this Policy, are applied to those who:

(i) have reasonable grounds to believe that, at the time of the communication, the information they report to ONI, as well as the information mentioned at number one (Scope of application), are within the enforcement of this Policy.
(ii) Communicate through the channel provided by ONI for this purpose.


ONI has a Whistleblowing Channel, accessible through its website oni.pt or intranet oniverso.pt, which allows the secure submission and follow-up of complaints. To access the Whistleblowing Channel click here.

If a report arises, an internal investigation will be initiated with the corresponding investigation, and if necessary, ONI may use external consultants for this purpose.

If the investigation confirms that a violation has occurred, ONI will promptly take appropriate corrective measures towards the people involved, including disciplinary measures, labor contract termination and, under certain circumstances, may also inform public authorities who can investigate and open a civil or criminal proceeding.

Any person, who knowingly and willfully submits a false report, provides false or deliberately misleading information in the context of an investigation of a report, or fails to cooperate in an investigation of a report, may face disciplinary actions, including labor contract termination or a lawsuit.


ONI is committed to ensure that the identity of the Whistleblower will not be revealed, through the Whistleblower Channel, unless the person gives its express consent to do so. This confidentiality obligation, if necessary, will also apply to external advisers that support the investigation of the report.

This obligation of confidentiality implies that, except the employees specifically authorized to receive the report, during the follow up or until the end of the investigations regarding a report, no one at ONI may know the identity of the Whistleblower or any other information that may be deducted directly or indirectly from the identity of the Whistleblower.

The Whistleblower identity can only be revealed in case of a legal obligation or under a court order.

If the identity is revealed according with one of the above reasons, ONI will inform the Whistleblower in advance, unless such information could compromise the investigation or the court ation. Likewise, when competent authorities inform the Whistleblower that his/her identity will be revealed, they must justify the reasons underlying the disclosure.

Finally, ONI guarantees that the processing of personal data carried out under this Policy, including the exchange or transmission of personal data with competent authorities, will be carried out in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and Law No. 58/2019 of 8 August.

Equally, personal data which relevance is not evident for handling a specific report will not be taken, and if taken by accident, will be deleted without undue delay.


ONI will keep a registry of all the communications and inquiries received through the Whistleblower Channel, always respecting the established confidentiality requirements for the time strictly necessary and proportionate to meet the legal and regulatory requirements according with the European Union Law.


ONI will take the necessary measures to preventt all possible forms of retaliation against people who report infractions, including threats of retaliation and attempts to retaliate.


ONI will provide the following support measures:

(i) Exhaustive independent information and counselling about the procedures and available solutions regarding terms of regulatory compliance, protection against retaliation, and rights as affected persons, will be given.
(ii) Effective assistance in case of retaliation.

ONI will take the necessary steps to ensure that whistleblowers are protected from retaliation, including:

(i) Whistleblowers will not be considered to have committed a violation of any restrictions on sharing confidential information and will not incur in any liability concerning the communication made, if there are reasonable grounds to believe that the sharing of such information was necessary to disclose a legal or regulatory violation.

(ii) Whistleblowers will not face any responsibility concerning access to the information they report, if such access does not, by itself, constitute a crime. In case that access does constitute a crime, ONI will notify the competent authorities.


ONI will ensure that those who are involved in the report (i.e., the alleged wrongdoers) will be heard as part of the internal investigation.

Likewise, the identity of the person involved in the report will be protected and treated confidentially, as well as the identity of the Whistleblower, always within the limits and with the exceptions that ensure the proper conclusion of the investigation, or a possible communication to the competent authorities.


ONI, in compliance with the correspondent labor laws and regulations, will establish effective, proportionate, and dissuasive sanctions applicable to employees of the company, who:

a. Prevent or attempt to prevent reports of infractions;
b. Take retaliatory action against whistleblowers;
c. Fail in their duty to maintain the confidentiality of the identity of the whistleblower or those involved in the report.

No ONI employee or third party may renounce to the rights foreseen in applicable Law by any agreement, policy, form of employment or employment condition, including any arbitration clauses.