Information regarding the Whistleblowing Channel of Minerva Insights Group
With the aim of strengthening a genuine culture of compliance and acting consistently with its values and principles, Minerva Insights Group has implemented a common Whistleblowing Channel for all group companies. The channel has been designed in accordance with Directive (EU) 2019/1937 on the protection of persons who report breaches of Union law, and with the national legislation implementing it in each of the countries in which the group operates. The receipt of reports has been entrusted to an independent external manager.
Each report will be handled in accordance with the legislation of the country in which the group company concerned is established. Certain aspects, such as the scope of protection, data retention periods or the competent external authorities, may therefore vary from country to country.
Through this channel, any person who works or has worked for any of the group companies, or who has or has had a professional relationship with them, may report securely and confidentially, including anonymously:
The channel also accepts reports on:
All reports will be handled with the same confidentiality guarantees. However, only reports concerning breaches within the scope of the applicable legislation, and made by persons with an employment or professional relationship with the group, will benefit from the legal whistleblower protection regime.
Reporting through this channel is the preferred route. In some countries, the law requires the internal channel to be used first, except in certain cases. In others, the reporting person may go directly to the competent authorities. Information on external channels is provided in the frequently asked questions section.
Principles of the Whistleblowing Channel
The Whistleblowing Channel has been designed in accordance with the following characteristics and general operating principles:
Members of the group companies who become aware of possible breaches or non-compliance must report them through this Whistleblowing Channel, without prejudice to their right to use external channels under the terms provided for by the applicable legislation. This cooperation is essential for the proper functioning of the group's compliance model.
Who can use the Whistleblowing Channel?
Any person who has obtained information about breaches in a work-related or professional context with any of the group companies. This includes current or former staff, job applicants, interns, volunteers, shareholders, members of the management body, self-employed persons, suppliers, contractors and subcontractors.
Which law applies to my report?
The law of the country in which the group company to which the report relates is established. It is therefore important that you select the correct company in the form.
I am a customer. Can I use the channel?
Yes. Your report will be handled with the same confidentiality guarantees. However, the legal protection against retaliation generally applies only to those who report in a work-related or professional context.
Which reports are not legally protected?
In general, reports concerning interpersonal conflicts or personal grievances, information already publicly available, mere rumours, and facts that do not constitute a breach within the scope of the applicable legislation.
Can I report a harassment situation through this channel?
Yes. Your report will be forwarded to the competent body to be handled in accordance with the applicable internal protocol or procedure, with guarantees of confidentiality and protection of the person concerned.
Can I report anonymously?
Yes. The system does not record any data that could identify you, and you can follow up on your report with the tracking code. If you are later identified, you will retain legal protection.
How can I submit a report?
In writing using this form or, if you request it, orally at an in-person meeting to be held within a reasonable period.
What happens after I submit it?
You will receive an acknowledgement of receipt within a maximum of seven days. The report will be assessed for admission and, where appropriate, investigated. You will be informed of the measures planned or taken within a maximum of three months, subject to any extensions permitted by the applicable legislation.
Who has access to my report?
Only the persons responsible for receiving and handling reports, including the external manager, and, where strictly necessary, those responsible for adopting the appropriate measures. All of them are bound by a duty of confidentiality.
What protection do I have?
Any retaliation is prohibited, such as dismissal, sanctions, changes to working conditions, negative assessments, harassment, blacklisting or reputational damage. Retaliation may be sanctioned in accordance with the applicable legislation.
Can I go directly to an external authority?
Yes, under the terms established by the legislation of the country of the company concerned. In some countries, such as Portugal, the law requires the internal channel to be used first, except in certain cases, such as a risk of retaliation or failure to respond within the time limit. The main authorities are:
What rights does the person concerned by the report have?
The presumption of innocence, the right of defence, the right to be heard and the confidentiality of their identity during the investigation.
What happens if I report something that turns out to be untrue?
If you had reasonable grounds to believe it, you retain your protection. Reporting information knowing it to be false may give rise to disciplinary, civil or criminal liability.
I have lost my tracking code. What should I do?
For confidentiality reasons it cannot be recovered. You may submit a new report referring to the previous one.
