Whistleblowing channels

Your problems 

  • Your organization is covered by Law n.º 93/2021, from 20 December, related to the General Regime for the Protection of Whistleblowers (“GRPW”) and needs to assure that it is in compliance with this Law.
  • You want to follow the guidelines related to the implementation of the reporting channels, according with the Notice n.º 3/2020 from the Bank of Portugal (government systems and internal control) or in the Law n.º 83/2017 (anti money laundering and counter terrorism financing) or other applicable sectorial and specific legislation.
  • You intend to assure, even voluntarily, that your organization’s workflow to receive and manage complaints is in compliance with all the applicable regulations and practices recommended and allows a consistent and efficient treatment ​of the complaints received.
  • Your organization does not have available human and/or technical resources to assure the desired level of independence in managing the complaints received and/or to make the investigation or legal/labor analysis on the reported matters.

How can we help

An effective whistleblowing management system is not only related to the creation of a complaint channel. It is also necessary that this system is communicated effectively to guarantee an adequate use of these channels. On the other hand, it is also necessary to define the procedures related to the treatment that will be given to the complaints received, assure the protection of the whistleblowers, and establish consequences of any misuse of this kind of channels.


We provide support in five big areas:

Policies, processes, and procedures

We elaborate/revise your policies, processes and procedures related to this kind of matters, such as:

  • Code of ethics and conduct;
  • Whistleblowing policy;
  • Manual of internal procedures for the management of complaints;
  • Manual of legal procedures with the description of the legal treatment to consider for each kind of reported complaint*.

* The legal and labor analysis are made by CCR – Sociedade de Advogados, SP, RL, which is an independent entity and member of the PwC network and dedicated to legal practices 

Implementation of whistleblowing channels

We implement whistleblowing channels in your organization, considering the context and the different stakeholders that interact with it. The whistleblowing channels that we may implement are the following:

  • Technological platform (Whistleblowing and Ethics Hub) – see more detail about our platform here;
  • Phone channel;
  • E-mail channel;
  • Mailbox channel.

Training, communication and awareness

We support in the elaboration of communication and awareness plans about this topic considering all the organization.

Additionally, we develop training contents adapted to the context of our clients and we conduct training sessions about these themes for their employees.

Operation of whistleblowing channels

Our team has a wide experience in receiving complaints involving themes generally sensitive, which includes the obtention of relevant information that might be useful to a potential investigation.

This team will receive, register and make a summary of the reported elements and finally will forward the complaint for the responsible people for these matters in our clients.

Investigation of reported complaints

Our team may support in one-off investigations of certain complaints upon our client’s request. 

The investigations are focused on economic-financial, accounting and processual subjects or on legal and labor subjects*.

See in more detail the scope of the investigations that we can perform here.

* The legal and labor analysis are made by CCR – Sociedade de Advogados, SP, RL, which is an independent entity, member pf the PwC network and dedicated to legal practices 

Contact us

Carolina Costa

Carolina Costa

Director, PwC Portugal

Gonçalo Almeida

Gonçalo Almeida

Senior Manager, PwC Portugal

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