PRIVATE LUXURY COLLECTION (Centelha D’Exito Uni.Lda)

Effective Date: 18th June 2022

Purpose of the Policy

Private Luxury Collection is committed to upholding the highest standards of ethics, integrity, and compliance with legal requirements. In accordance with Portugal’s whistleblowing law (Law no. 93/2021), this policy provides a clear and secure channel for reporting concerns related to legal violations, unethical behaviour, and other issues that may compromise our commitment to ethical practices. This policy applies to all employees, contractors, clients, and other third parties associated with our agency.

Scope of Reportable Concerns

Whistleblowers are encouraged to report any known or suspected violations in the following areas:

• Legal Violations: Breaches of any local or national laws applicable to our industry or operations.
• Ethical Misconduct: Unethical conduct such as fraud, embezzlement, or misrepresentation of our services.
• Discrimination and Harassment: Any discriminatory or harassing behaviour that violates employee and client rights.
• Health and Safety Violations: Actions or situations that compromise the health, safety, or security of employees, clients, or contractors.
• Other Concerns: Any behaviour contrary to our company policies, procedures, or regulatory requirements.

If you have witnessed or are aware of any actions that fall under these categories, we strongly encourage you to report them through the designated channels.

Who Can Report

Reports may be submitted by:

• Employees (current and former)