COMPLIANCE COMMITMENT

Palmetal is a company integrated in prominent international groups and assumes its social responsibility. Our sustainable economic success is based on our innovative strength, technological know-how, quality and customer focus.

Our responsible conduct is defined by strict compliance with all applicable rules and laws. Compliance therefore has the highest priority.

For us, Compliance is a matter of attitude: values such as reliability, honesty, credibility and integrity permeate our corporate DNA, further strengthening the trust of customers, suppliers, shareholders and society in Palmetal.

Code of Conduct tk/Palmetal

DATA PROTECTION NOTICE FOR BUSINESS PARTNERS

All information on the processing of personal data within the scope of the business relationship can be found in the link below.

Data Protection Notice

WHISTLEBLOWING CHANNEL

At Palmetal Armazenagem e Serviços S.A., integrity, compliance with the law and internal regulations are of highest priority. To ensure that these values are upheld and potential risks arising from violations are avoided or minimized, it is crucial that misconduct is identified, clarified, and remedied at an early stage. Every indication of a potential misconduct is treated seriously and leads to an investigation following an objective and transparent process without any bias. Palmetal – Armazenagem e Serviços, SA. therefore makes available to whistleblowers in compliance and under protection of the Law No. 93/2021 of December 20, 2021, which transposed the Directive (EU) 2019/1937 of the European Parliament and of the Council of October 23, 2019 on the protection of persons who report breaches of EU laws as well as criminal and serious or very serious administrative offenses under Portuguese law, an internal information system that enables whistleblowers to submit reports.

A detailed description of the Palmetal – Armazenagem e Serviços, SA. whistleblowing rules of procedure can be found at: tk wb rules of procedure Portugal

1. Who can inform about a violation?

The whistleblower is any natural person who submits a report or makes a public disclosure of information on violations acquired in the context of his or her work. This includes but is not limited to:

  • staff with an employment relationship;
  • self-employed workers;
  • freelancers and consultants, suppliers, customers;
  • volunteers and trainees;
  • shareholders or owners of company shares persons with administrative, management, supervisory or representative functions, including non-executive members;
  • any person working for or under the supervision and direction of contractors, subcontractors and suppliers;
  • any person whose work-based relationship is yet to begin in cases where information on breaches has been acquired during the recruitment process or other pre-contractual negotiations.

2. What can be reported?

Any conduct that may constitute criminal, administrative, civil or disciplinary offenses, as well as all acts or omissions, whether intentional or negligent, that are contrary to the rules in the following areas, are considered offenses and can, therefore, be reported:

  • Public procurement;
  • Financial services, products and markets and prevention of money laundering and terrorist financing;
  • Product safety and compliance;
  • Transport safety;
  • Environmental protection;
  • Protection against radiation and nuclear safety;
  • Food and feed safety, animal health and animal welfare;
  • Public health;
  • Consumer protection;
  • Protection of privacy and personal data and network and information systems security;
  • An act or omission contrary to and detrimental to the financial interests of the European Union referred to in Article 325 of the Treaty on the Functioning of the European Union (TFEU), as specified in the applicable European Union measures;
  • An act or omission contrary to the internal market rules referred to in Article 26(2) of the TFEU, including competition and state aid rules, as well as corporate tax rules;
  • An act or omission that contradicts the purpose of the rules or standards covered by any of the above;
  • Violent, especially violent and highly organized crime, as well as the crimes provided for in Article 1(1) of Law no. 5/2002, of January 11, which establishes measures to combat organized and economic-financial crime;
  • Crimes of unduly offering an advantage;
  • Crimes of fraud in obtaining a subsidy or grant.

In addition, irregularities relating to violations of internal policies can also be reported. The report may concern to offenses that have been committed; that are being committed or can reasonably be expected to be committed; as well as any attempts to hide such offenses. Therefore, in this document “violations” will refer to both actual and potential violations.

3. Who is responsible for dealing with reports?

3.1. Local whistleblowing channel

The Board of Directors has appointed its Compliance Manager of Palmetal – Armazenagem e Serviços, SA. as the responsible for the local internal whistleblowing system and procedure. The Compliance Manager safeguards that all requirements of Law 93/2021 regarding the operation of the reporting channel, the protection of the whistleblower and the conduction of the investigation are fulfilled.

The Compliance Manager will be supported by the central thyssenkrupp AG Compliance Investigations department (CO/L&C-INV) in order to conduct investigations, unless the whistleblower objects.

The Compliance Manager entrusted with the management of the local internal whistleblowing system offers a guarantee of impartiality, is independent, is not bound by instructions and is sworn to secrecy. Incoming reports, that can also be submitted anonymously, are treated confidentially and whistleblowers are protected by all appropriate means against any disadvantages resulting from a report.

Whistleblowers may submit a report through the local internal reporting channel described below. The Compliance Manager will agree in cooperation with the CO/L&C-INV on adequate investigation procedures according to the scope of the whistleblower report and acquire adequate measures at the Palmetal – Armazenagem e Serviços, SA. if necessary.

3.3. Global whistleblowing channels

The responsible department for the thyssenkrupp group's global channels is CO/L&C-INV.

CO/L&C-INV, entrusted with the management of the global whistleblower system, offers a guarantee of impartiality, is independent, is not bound by instructions and is sworn to secrecy. Incoming reports, that can also be submitted anonymously, are treated confidentially and whistleblowers are protected by all appropriate means against any disadvantages resulting from a report.

Whistleblowers may submit a report through various global reporting channels described below.

4. How can I submit a report?

An open communication culture is an essential component of well-functioning compliance. Employees must be able to address potential violations openly, anonymously and, above all, at an early stage.

For this purpose, Palmetal – Armazenagem e Serviços, SA. offers a local internal whistleblowing channel and thyssenkrupp group's offers a number of global whistleblowing channels which are set out below:

A. Local whistleblowing channel

The whistleblower can submit a report to PALMETAL’s Compliance Manager directly via the following e-mail address: compliance@palmetal.pt

B. Global whistleblowing channels

Thyssenkrupp group's offers the following global whistleblowing channels.

1. thyssenkrupp Electronic Whistleblowing System (BKMS)

If the whistleblower prefers to report violations via the electronic Compliance Whistleblowing System, or is interested in detailed information, information can be found here:
www.palmetal.pt/compliance

The electronic Compliance Whistleblowing System can be directly access by this link:
www.bkms-system.net/bkwebanon/report
Respectively the QR code below:

In addition to the possibility of a written report, the reporting can be submitted orally via voice intake.

Oral reporting made via voice intake is documented, with the consent of the whistleblower, through a recording of the conversation in a durable and retrievable format.

In addition to the electronic Compliance Whistleblowing System, violations regarding the International Framework Agreement (thyssenkrupp internal HR violations) can also be reported to representatives on the International Committee and the Labor Relations department at thyssenkrupp AG under
www.bkms-system.net/frameworkagreement

2. Telephone Hotline

If the whistleblower prefers to report via phone, the reporting can be submitted via the following telephone number selecting Portuguese language (automated telephone dialog):
Phone: +39 02 81480081 or +55 61 35507564
Access PIN: 4541

Oral reporting made via phone is documented, with the consent of the whistleblower, through a recording of the conversation in a durable and retrievable format.

Postal address

The whistleblower can contact alternatively thyssenkrupp Headquarters via following postal address:

thyssenkrupp AG,
Compliance, Department Investigations
thyssenkrupp Allee 1,
45143 Essen
Germany

More information on the submission of reports can be found here:
Submitting a report (thyssenkrupp.com)

3. Face to face meetings

If a face-to-face meeting is requested, it will be organized within 7 days. If the report is submitted orally, with prior consent of the whistleblower, the report is documented by the Global System Manager in a secure, durable and accessible format, or by a transcript of the conversation. The whistleblower may be given the opportunity to verify, rectify and confirm the minutes of the meeting by signing them.

4. External Reporting Channels

We encourage whistleblowers to use our internal reporting channels. Whistleblowers also have the option to submit their report to external reporting channels.

In the case of criminal offences, the facts may be reported to the Public Prosecutor's Office (at correiopgr@pgr.pt) or criminal police.

In the case of misdemeanor and administrative offence, depending on the matter of offence reported the facts may be reported to the following competent authorities: a) the Bank of Portugal; b) Independent administrative authorities; c) Public institutes; d) General inspectorates and similar entities and other central services of the state's direct administration with administrative autonomy; e) Local authorities; and f) Public associations.

5. Data Protection

While carrying out internal investigations, it will be ensured that the applicable data protection laws are complied with.

The confidentiality of the identity of the whistleblower, the content of the report and the documentation transmitted during the course of the investigation is guaranteed.

Detailed information on the subject can be found here: Data Protection Notice

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