APA, S.A. ensures compliance with the General Regime for the Protection of Whistleblowers, under the provisions of Law 93/2021, of 20 December, guaranteeing, amongst other things, the confidentiality of the identity of the whistleblower, only disclosing it when required by law or court order, also ensuring the possibility of anonymous whistleblowing.

Under the terms and for the purposes of the aforementioned Law, the whistleblower who, in good faith and having serious grounds to believe that the information is true at the time of the report or public disclosure, reports or publicly discloses an infraction, is protected.

Acts of retaliation against the whistleblower are strictly forbidden, and this is understood to mean any act or omission that, directly or indirectly, occurring in a professional context and motivated by an internal or external whistleblower or public disclosure, causes or may cause the whistleblower, unjustifiably, to suffer material or non-material damage. It is also emphasized that attempts and threats of these acts are also prohibited by law.

Whistleblowers are generally entitled to legal protection and also generally benefit from witness protection measures in criminal proceedings.

The Directorate-General for Justice Policy also provides information on the protection of whistleblowers on the Justice Portal, without prejudice to the mechanisms for accessing the law and the courts.

For further information, please consult Law 93/2021 of 20 December and the "Frequently Asked Questions" section available here.