Complaint Handling Policy




The Sharing - Complaints Channel, welcomes the reporting of bad practices and / or dubious practices on matters provided for in the legislation approved by Law No. 93/2021, of December 20.

All employees, customers, suppliers or other interested parties can use this channel.

At Grupo Bacalhôa we want everyone to feel safe in communicating, in a conscious and considered way, any conduct or situations of which they are aware and which may constitute irregularities or be ethically objectionable.

We believe that acting ethically and respecting the rules is the only way to better serve our customers and, to support this mission, we have made available a new channel for reporting irregularities, the Sharing Complaints Channel.

This policy aims to describe the communication of irregularities and applies to all companies and employees of the Bacalhôa Group.



DESCRIPTION (Methods, Criteria and Responsibilities)


The Sharing Channel is a secure and confidential channel for questions, concerns or to report violations under the Code of Ethics and Conduct of the Bacalhôa Group.

Identifying and reporting possible violations of the law or the Code of Ethics and Conduct is crucial for the Bacalhôa Group.

Communications made through the Sharing Channel may address any matter specified in the Code of Ethics and Conduct, including possible human rights violations, such as harassment or discrimination, or acts of fraud and corruption.


Complaints in the Sharing Channel are received on behalf of the Bacalhôa Group, by the Sharing Channel Manager, who will ensure their treatment in a professional and confidential manner.

Thus, if there is knowledge of any situation, which is not ethical or non-compliant with legal or internal norms, it should be reported/shared.

Note: This channel is not intended for complaints or customer support questions.



Communication and Handling of Complaints



1. How to use Sharing – Reporting Channel:

There are 2 means available:


By Email, to the address


By Post, to the following postal address:

Bacalhôa Group

Attn: Sharing Manager - Bacalhôa Group's Complaint Channel

EN 10 – Section: 54

2925-901 Vila Nogueira de Azeitão, Setubal



Complaints and internal complaints should be drafted in a clear, objective and concise manner, describing the facts that motivate the complaint.

It is important to provide as much information as possible regarding the concern / complaint and contain the necessary data to be able to carry out the analysis of the reported facts. Therefore, the communications received should include the following information:


-Clear and detailed statement of the facts;

-Clear and detailed identification of the area or department in which the reported facts took place;

-Identification of the people involved in the reported behavior or with knowledge of it;

-Time at which the event occurred or still occurs;

-Quantification, whenever possible, of the impact of the reported event on society, area or department.

-Attach, whenever possible, documents, files or other information that is deemed relevant to the evaluation and resolution of the complaint.




The Sharing Channel should not be used for the submission of requests for information or other messages that do not fall within the reporting categories.

Before the law, are considered infractions, acts or omissions of matters that concern:


-Public procurement;

-Services, products and financial markets;

-Safety and compliance of products;

-Transport safety;

-Food or feed safety;

-Human or animal health and welfare;

-Protection of the environment;

-Public health;

-Consumer protection;

-Protection of privacy and personal data;

-Security of network and information systems;

-Prevention of money laundering;

-Financing of terrorism.


In addition, any institutional attitude of a violent, abusive nature, or related to organized economic and financial crime also falls under the list of transgressions that can be reported.

The Whistleblowing Channel does not replace the obligation to report in cases and under the terms that the criminal law and criminal procedure determine.

Any communication can be made anonymously or identified, always being treated confidentially, being in compliance with the General Regime of Protection of Whistleblowers of Infractions and with the Privacy and Protection of Personal Data Policy of the Bacalhôa Group.



2. Response to Complaints

The reports received will be recorded and, after analysis and treatment, kept on file, being assigned a reference to each report, to create the respective process. This reference will be used in all replies related to the original communication (complaint).



 3. Methodology for Handling Complaints

The Sharing Manager – Bacalhôa Group's Complaints Channel is responsible for receiving and processing communications made through the respective channel.

Any communication made through the Sharing Whistleblowing Channel is treated confidentially and your Manager is obliged to keep the content confidential.


After becoming aware of any complaint, the Sharing Manager – Bacalhôa Group's Complaints Channel will investigate, treat and communicate to the complainant the measures planned or adopted to follow up on the complaint and the respective justification.

The Bacalhôa Group will not tolerate acts of retaliation against any person who, in good faith, has reported facts considered to be in violation of the Code. It is the duty of all employees, particularly leaders, to ensure the daily fulfillment of this commitment to whistleblowers.

Any act or threat of retaliation will be considered a violation of the Code of Ethics and Conduct, and the person responsible will be subject to appropriate punitive and corrective measures.

Only the Sharing Manager – Whistleblowing Channel has access to the mailbox and postal mail sent to the Channel and is obliged to maintain the confidentiality of the content.



 4. Deadlines for Handling Complaints

If the whistleblower identifies himself/herself, he/she will be given a response in writing or through a meeting (where requested) within the following time limits:


Within 7 days – notification of receipt of the complaint;


Within 3 months from the date of receipt of the complaint – communication to the reporting person of the measures planned or adopted to follow up on the complaint, accompanied by the reasons therefor;


If the reporting person requests that the result of the review be communicated to him or her (which he or she can do at any time), it must be carried out within 15 days of the completion of the review.





The interpretation and application of this policy are the responsibility of the Sharing Manager – Complaints Channel of the Bacalhôa Group, and it is up to him to propose changes, for approval of the Administration, whenever this is justified.