1. Concept
In accordance with Law No. 93/2021 of December 20 – General Regime for the Protection of Whistleblowers (RGPDI), which implements Directive (EU) 2019/1937 of the European Parliament and Council of October 23, 2019, and Decree-Law No. 109-E/2021 of December 9, Work Squad has established an internal whistleblower reporting channel. This ensures that employees and relevant stakeholders can report misconduct, violations, and offenses while being protected under the law.
2. Scope of Application
Under the applicable legal frameworks, all companies with 50 or more employees are required to maintain an internal whistleblowing system to detect and prevent risks, report violations, and follow up on allegations of corruption and other related offenses.
According to Article 2(1) of Law No. 93/2021, whistleblowers may report intentional or negligent acts that constitute a crime or administrative offense, including but not limited to:
- Public procurement violations
- Corruption and financial misconduct
- Fraud, bribery, money laundering, and terrorist financing
- Privacy, data protection, and cybersecurity breaches
- Product safety and compliance violations
- Transportation security issues
- Environmental protection violations
- Radiation protection and nuclear safety breaches
- Public health violations
- EU financial interests, as per Article 325 of the Treaty on the Functioning of the European Union
- Internal market regulations under Article 26(2) of the Treaty on the Functioning of the European Union
3. Who Can Submit a Whistleblower Report?
Under Article 5 of Law No. 93/2021, a whistleblower is defined as any natural person who, in the course of their professional activity, reports or discloses an offense. This includes:
✔ Current and former employees of Work Squad
✔ Managers and executives
✔ Service providers, contractors, subcontractors, and suppliers working with Work Squad
✔ Volunteers and trainees
✔ Individuals involved in recruitment or pre-contractual negotiations with Work Squad
To qualify for whistleblower protection under Article 6 of Law No. 93/2021, reports must be made in good faith, based on a reasonable belief that the reported information is true at the time of submission. Retaliation against whistleblowers is strictly prohibited under Article 21 of Law No. 93/2021.
4. How to File a Complaint?
Work Squad provides an internal whistleblowing platform that allows employees and stakeholders to submit reports in writing or verbally, either anonymously or with identification. Reports can be made via:
📌 Online Platform – Available on the Work Squad website
📌 Email Submission – [Insert Email Address]
📌 In-Person Reporting – Directly to HR or Compliance Department
A whistleblower report must include:
📅 Date or time period of the offense
📌 Identification of individuals or entities involved
📄 Supporting documents or evidence (where available)
📖 Detailed description of the incident
5. Complaint Investigation Procedure
🔹 Step 1: Work Squad’s compliance team reviews the complaint.
🔹 Step 2: The whistleblower is notified within 7 days of submission.
🔹 Step 3: The compliance team verifies the validity of the complaint and, if needed, requests additional information from the whistleblower.
🔹 Step 4: If applicable, the report may be forwarded to regulatory authorities for investigation.
🔹 Step 5: Work Squad informs the whistleblower of the outcome within 3 months, as per Article 11(3) of Law No. 93/2021.
6. Data Protection and Confidentiality
The processing of personal data contained in reports is handled in compliance with Regulation (EU) No. 679/2016 (GDPR) and Work Squad’s Privacy Policy. Reports will be treated with full confidentiality, and whistleblower identities will remain protected unless legally required otherwise.
7. Whistleblower Rights
Under Articles 21 and 22 of Law No. 93/2021, whistleblowers have the right to:
✔ Legal protection from retaliation
✔ Anonymity and confidentiality of their identity
✔ Follow-up updates on their complaint
✔ Protection under witness laws in criminal proceedings
8. Complaint Closure
A complaint will be closed, and no further action will be taken if:
❌ The reported offense is insignificant or legally irrelevant.
❌ The same complaint was previously filed without new evidence.
❌ The complaint is anonymous and lacks supporting evidence.
❌ The report does not meet the legal definition of an offense.
❌ The report lacks necessary details, and the whistleblower fails to provide further clarification when requested.
All closure decisions will be documented and communicated to the complainant.
