Compliance Program

BOLDINT, S.A.

BOLDINT, S.A. Compliance Program

At Devoteam Portugal, we are committed to fostering an ethical, transparent, and legally compliant work environment.

As part of Devoteam Portugal, BOLDINT, S.A. has adopted the following key compliance instruments to ensure compliance and promote ethical behavior across all levels of the organization.

Key Compliance Instruments:

🔗Code of Conduct: Establishes the ethical guidelines and behavioral expectations for all employees and stakeholders at BOLDINT, S.A.
🔗Compliance Policy (RGPC): A Policy for the Prevention of Corruption and Related Offenses & Management of Conflicts of Interest. Defines preventive measures to ensure compliance with anti-corruption laws and effectively manage potential conflicts of interest within the organization.
🔗Plan for the Prevention of Corruption Risks and Related Offenses: Identifies and mitigates risks related to corruption, fraud, and unethical practices, ensuring that the organization maintains high standards of integrity.
🔗Internal and External Whistleblowing Channel: A secure mechanism available to all employees and third parties to report misconduct or unethical behavior.

These compliance measures are fully aligned with the 🔗Devoteam Group's Code of Conduct and Anti-Corruption Charter, ensuring a unified and cohesive approach to ethical governance and compliance across all Devoteam operations.

🔊BOLDINT, S.A. Whistleblowing Channel

The Whistleblowing Channel enables both internal and external stakeholders to report any irregularities, including suspected fraud, corruption, related offenses, or violations of our Code of Conduct.

Legal Compliance & Protection Framework

The Whistleblowing Channel complies with key legal frameworks, ensuring protection and confidentiality for all reports:

🔗National Anti-Corruption Strategy 2020-2024, aproved by Resolution No. 37/2021 of the Council of Ministers.
🔗General Regime for Corruption Prevention (RGPC), approved by Decree-Law No. 109-E/2021, of December 9.
🔗General Regime for the Protection of Whistleblowers (RGPDI), approved by Law No. 93/2021, of December 20, which aligns with 🔗EU Directive (EU) 2019/1937 on the protection of whistleblowers.

These regulations ensure that whistleblowers are protected and that organizations implement secure and confidential reporting channels that guarantee:

Protection of the whistleblower’s identity and that of the accused.
Confidentiality of reports, with the option for anonymous submissions.
Strict prohibition of retaliation against whistleblowers.
Security and proper handling of reported data.

How to Report an Irregularity

We encourage all employees, former employees, job applicants, service providers, and other stakeholders to report any concerns securely and anonymously via 🔗BOLDINT, S.A. Speak-Up Line. Reports should be submitted if there are reasonable grounds to believe the information is accurate and truthful.

The system allows for the reporting of:

Ethical misconduct or inappropriate behavior.
Legal or regulatory violations.
Breaches of Devoteam Portugal's or the Devoteam Group's internal policies.

All reports will be handled confidentially, impartially, and with strict protection against retaliation.

Please note: Whistleblowing reports related to corruption, fraud, or other serious misconduct may lead to criminal or disciplinary liability.

🔊BOLDINT, S.A. Whistleblowing Channel:

Report Here

E-mail

This page contains important compliance-related information for Devoteam Portugal Employees and Contractors. All content is intended for internal use and must be adhered to in accordance with Devoteam's corporate standards and policies.
Last updated: 11/02/2025Author: Rute Reizinho, Compliance Director & DPO at Devoteam Portugal