1. What you can report
You can use the channels below to report breaches concerning Bondstone Ventures, SCR, S.A. (“Bondstone Ventures”) or any alternative investment fund it manages. You can report breaches that have been committed, are being committed or can reasonably be expected to be committed, as well as attempts to conceal them. This includes breaches of the rules on financial services, products and markets and on the prevention of money laundering and terrorist financing, and the other matters listed in Article 2 of Law No. 93/2021 of 20 December.
Anyone who has obtained the information in a professional context may report. This includes employees, service providers, suppliers, shareholders, members of corporate bodies, trainees, volunteers and job applicants, even if the professional relationship has ended or has not yet begun.
These channels are only for reporting breaches. For general enquiries, please contact ventures@bondstone.com.
2. How to report
Reports must be made in writing, using the channel that matches the subject of your report.
Money laundering and terrorist financing. Reports of irregularities concerning money laundering or terrorist financing, including breaches of Law No. 83/2017 of 18 August, of its implementing regulations or of Bondstone Ventures’ internal policies and procedures in this area, should be sent:
- by email to denuncias.bcft.bv@bondstone.com; or
- by letter marked “Confidential – AML/CFT” to the address below.
All other breaches. All other reports should be sent:
- by email to denuncias.bv@bondstone.com; or
- by letter marked “Confidential” to the address below.
Letters should be addressed to: Bondstone Ventures, SCR, S.A., for the attention of the Compliance Officer, Rua Castilho, 39, 10C, 1250-068 Lisboa, Portugal.
Only the persons designated by Bondstone Ventures to receive and follow up on reports have access to these channels. If you send a report to the wrong channel, it will be forwarded internally to the correct one, with the same confidentiality.
3. Anonymity and confidentiality
You may report anonymously: for example, by unsigned letter or from an email address that does not identify you. If you give no contact details, we will not be able to acknowledge your report or keep you informed.
If you identify yourself, your identity, and any information from which it could be deduced, will be kept confidential. It will be disclosed only where required by law or by a court decision. The identity of persons mentioned in the report is also kept confidential.
4. What happens next
We will acknowledge receipt within seven days and tell you how you can report to the competent authorities. Within three months of receipt, we will inform you of the measures planned or taken in response to your report, and the reasons for them. You may ask at any time to be told the outcome of our analysis, which we will then provide within 15 days of its conclusion.
5. Reporting to the authorities
In the cases set out in Article 7(2) of Law No. 93/2021, you may also report to the competent authorities, such as the Comissão do Mercado de Valores Mobiliários (CMVM, www.cmvm.pt) or the Public Prosecutor’s Office (Ministério Público). These cases include, for example, where the breach constitutes a crime or an administrative offence punishable by a fine above €50,000, or where you have reasonable grounds to believe it cannot be effectively addressed internally or that there is a risk of retaliation.
6. Protection
Retaliation is prohibited against anyone who reports in good faith, with serious grounds to believe the information is true at the time of reporting. This protection also covers anyone who helps the whistleblower and third parties connected with them, such as colleagues or relatives. A report made in accordance with the law does not, in itself, give rise to disciplinary, civil, administrative or criminal liability for the whistleblower. Reporting false information is not protected and may be sanctioned under the law.
7. Personal data
Bondstone Ventures is the controller of the personal data contained in reports. It processes that data to receive, assess and follow up on reports, in compliance with its legal obligations under Article 6(1)(c) GDPR, Law No. 93/2021 and Law No. 83/2017.
Personal data that is clearly not relevant to the report is deleted immediately. Reports are kept for at least five years, or longer where required by law, and in any event for as long as any related judicial or administrative proceedings are pending.
You can exercise your data protection rights through the channels above or as described in Sections 8 and 9 of our Privacy Policy. You can also lodge a complaint with the CNPD, as explained in Section 13 of our Privacy Policy. An access request will not reveal the identity of the whistleblower or of other persons mentioned in a report, except where required by law.