Whistleblowing Channel

I. Introduction

Dunas Douradas Beach Club, Aldeamento Turístico, SA, henceforth DDBC, SA, is part of an international group guided by fundamental principles such as the responsible performance of its activities, throughout the strict compliance with laws, regulations and internal rules, as well as in accordance with the highest ethical standards set out in the Code of Conduct applicable to the whole group. As a reference company in the tourism and hospitality market, DDBC, SA assumes, before its customers, stakeholders and society in general, the commitment to carry out its activity in a reliable and transparent manner. According to the provisions of Law nº 93/2021, from the 20th of December, which establishes the general system of protection for whistleblowers, the company has created and runs a whistleblowing channel to be aware of and follow up possible violations of laws, regulatory standards or any other rules applicable to its activity, in order to adopt the necessary procedures and avoid eventual negative consequences for customers, employees or partners in general. By running this this channel, DDBC, SA takes the compromise to investigate all complaints received through it, in an impartial and objective way, ensuring confidentiality and protection to the whistleblowers and particularly not admitting any retaliation against those who, in good faith, present a complaint.

II. Whistleblowers

According to the provisions of the Law nº 93/2021, from the 20th of December, a whistleblower is an individual person who denounces or publicly discloses an infringement based on information obtained

(i) in the context of his/her professional activity, no mattering the nature of this activity and the sector in which it is carried out,

(ii) during a professional relationship even already terminated

(iii) ) during the recruitment process or

(iv) during another phase of pre-contractual negotiations for the establishment of a professional relationship even if it is not formalised.


The whistleblowing channel can be used by any of the following people:

a) Employees and former employees of the company;

b) Trainees or volunteers; c) Service providers;

d) Contractors or subcontractors;

f) Suppliers; and

g) In general, any person acting under the supervision and instructions of the company.


III. Subject of the complaint

The communications to be made through the whistleblowing channel may focus on any of the matters described followingly; it can be an infraction that has already occurred, that is still occurring or that it´s reasonably foreseeable that will occur:

i) Public contracts;

ii) Financial services, products and markets, prevention of money laundering and terrorist financing;

iii) Product safety and compliance;

iv) Transport security;

v) Protection of the environment;

vi) Radiation and nuclear safety;

vii) Food and feed safety, animal health and animal welfare;

viii) Public health;

ix) Consumer protection;

x) Protection of privacy and personal data and security of the network and information systems;

xi) Internal market, competition rules and Government aid, as well as corporate taxation;

xii) Violent, especially violent and highly organized crime;

xiii) Economic-financial crime covered by Law nº 5/2002, of 11 January, which provides measures to combat organized and economic-financial crime.


IV. Channels

The communication channels are the following, to where the complaints should be sent, anonymously or with identification of the complainant: By post mail to the following address: Dunas Douradas Beach Club, Aldeamento Turístico, SA, Sítio do Garrão, 8135-170 Almancil; By e-mail: integridade@ddbc.pt In a presential meeting whose appointment must be requested via the e-mail mentioned above.


V. Protection of whistleblowers

Are able to benefit from the protection provided by Law nº 93/2021, from the 20th of December, the whistleblowers:
– Who are in good faith and their complaint corresponds to one of the matters identified above; and – Have serious reasons to believe that the matter of the complaint is true.


VI. Proceedings

Dunas Douradas Beach Club, SA has organized a team in charge of the procedural follow-up of the complaint, ensuring that all claims submitted are analysed and, whenever justified, the correspondent internal investigation is open. Additionally, the facts will be communicated to the competent authorities whenever the analysis team concludes that a criminal or administrative offense may be involved. If the whistleblower protection regime applies, and the whistleblower identifies himself/herself, Dunas Douradas Beach Club, SA will notify him/her about the receipt of participation within 7 days and will inform about the requirements, competent authorities and possibilities to use an external way to complain. Within a maximum period of 3 months from the date of receipt of the communication, the complainant will be informed about the measures planned or already adopted. The whistleblower may also request to be informed about the result of the investigation within 15 days after the conclusion of it.


VII. Personal Data

The data contained in the complaints received through the whistleblowing channels are treated in accordance with the legal regulations in force, namely Regulation (EU)
2016/679 of the European Parliament and Council, of 27 April 2016 and Law nº 58/2019, of 8 August.


VIII. Other information

For any other information regarding this matter please contact DunasDouradas Beach Club, SA through the following e-mail: integridade@ddbc.pt