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1) Who can make a report?

This Reporting Channel can be used by ANA employees, regardless of their contractual relationship, as well as by all natural persons who, in the scope of their professional activity, in some way, have a relationship with the Company (example: workers of suppliers, service providers, contractors and subcontractors, public entities,...), including persons belonging to administrative or management bodies or tax or supervisory bodies, volunteers and trainees, paid or unpaid, candidates in the recruitment process and competitors in acquisition processes.


2) How can I make a report?

The report can only be filled in writing, and the reporter may choose to make it anonymously or by identifying himself, on the ANA website, Ethics and Conduct area, ((www.ana.pt): Institutional | menu ANA | Ethics and Conduct – Reporting Channel).


3) What should I report on this channel?

You may report, in good faith and with serious grounds to believe that the information is, at the time of the reporting, true, infringements committed, which are being committed or whose commission can reasonably be expected, as well as attempts to conceal such infringements from which you were personally aware and which, from your point of view, constitute a serious violation of the rules on which the principles of Business Ethics are based, namely, respect for legality, for people and the fight against corruption, framed in the following categories:


4) I want to make a complaint. Can I do it on this channel?

Any type of complaint is excluded from the scope of this reporting channel, there being, for this purpose, its own channel dedicated to Suggestions and Complaints, which can be accessed through the website of each airport, in the “Tell us” section.


Any complaint received in this way will not be followed up and will be returned with due justification.


5) Why should I file a report?

Because, in this way, we can help the Company to adopt the necessary measures to remedy the situation, as well as to prevent the same, or another similar situation, from happening again.


6) What happens after submitting a report?

All reports are received by the Ethics and Vigilance Committee, which will proceed to its analysis, in order to decide on its admissibility, being able to take measures, depending on the respective evaluation, in the sense of opening an internal investigation and/or through the communication to the competent authorities to investigate the infringement.


After the submission of the report, the author will be:

• informed about the good reception and admissibility of the report;

• informed of the follow-up that will be given;

• contacted if additional information is required;

• informed of all planned or adopted measures to follow up on the report and the reasons for it. 


7) How is my anonymity guaranteed?

When submitting your report, using the option of the form “Report anonymously”, your communication will be kept anonymous and, at no time during the communication process, will you be asked for personal information, so you should not mention any data that may facilitate the recognition of your identity.


Anonymity will be guaranteed through the encryption of messages and other security routines ensured by the system and all communications are carried out exclusively via the Reporting Channel, being accessible by clicking on the “Follow up on existing report” button.


8) How is confidentiality guaranteed?

The identity of the reporter, as well as the information that, directly or indirectly, makes it possible to deduce his identity, as well as the identity of third parties mentioned in the report, are confidential and its access is restricted to the Ethics and Vigilance Committee.


The obligation of confidentiality extends to anyone who has received information about reports.


The identity of the reporter is only disclosed as a result of legal obligation or court decision.


The disclosure of information is preceded by a written communication to the reporter indicating the reasons for disclosing the confidential data in question, unless the provision of this information jeopardizes the investigations or related legal proceedings.


9) Can I trust that my report will be treated fairly?

The reception and follow-up of reports is carried out by the Ethics and Vigilance Committee, in an impartial and independent manner, with safeguard procedures being ensured in the event of a possible situation of conflict of interest.


10) One of the members of the Ethics and Vigilance Committee is targeted in my report. How should I proceed?

You may exclude the member targeted in the report, when filling out the respective form, which will automatically be denied access to the report and its intervention at any stage of the process will be excluded. However, if the remaining members of the Committee find that the excluded member is not the subject of the report, they will restore his access.


If the member targeted in the report has not been excluded, as suggested above, after receipt the report by the Committee, access to the following stages of the process will be denied to the member concerned by the remaining members.


11) What is the deadline for answering to my report?

You will be:

• Informed within a maximum period of 7 days, of the receipt of the report, with information on the requirements, competent authorities and form of admissibility of the external report;

• Notified within a maximum period of 3 months of the measures planned or adopted to follow up on the report and the respective grounds for it;

• Informed of the result of the report analysis, if required, within a maximum period of 15 days, after the respective conclusion.


12) How can I access my report?

As soon as you submit a report, you will receive a reference to the process created automatically, and you will be asked to save the password.


Attention: These personal and confidential references are the only way to access and monitor your reporting process (if lost or forgotten, they cannot be reset).


Through the button “Follow up on existing report” you have access to the messages exchanged, allowing you to follow the progress of the process, ask questions, complete your communication, dialogue directly with the participants in the Reporting Channel protecting the confidentiality of communications.


13) How am I, as a reporter, protected from retaliations?

This Reporting Channel, in its entirety, is implemented in accordance with the requirements set out in Law No. 93/2021 of December 20th which establishes the general reporter regime protection of infringements, whereby ANA guarantees to the reporter the same level of protection in any of the areas reported, namely ensuring that he will not be the target of acts of retaliation and employing the necessary and appropriate means to put an end to any act of this nature that he finds, or that he becomes aware, that is being practiced against him.


14) How is the personal data included in my report protected?

All personal data are protected in accordance with the Company's Privacy Policy, which you can consult in the Guides and Documents area.


The record of reports received will be kept at least for a period of five years and, irrespective of that period, during the pendency of judicial or administrative proceedings relating to the report.


Personal data that are clearly not relevant to the handling of reports will not be kept and will be immediately deleted.


15) In addition to this ANA channel, is it possible to use VINCI Group reporting channels?

Yes, it is also possible to use the VINCI Group channels, which includes the Integrity Line Platform, from VINCI Concessions, as a way of complementing, if necessary, the ANA channel, therefore, all channels are available to the whistleblower.