Internal channel

This is the means provided by the organisation to receive and follow up reports. It may be operated internally or with external support, provided the model respects legal requirements, independence, confidentiality and the defined procedure.

External channel

This is provided by competent authorities. Portuguese Law 93/2021 identifies entities receiving external reports within their responsibilities and establishes conditions for using that route.

The two routes are not equivalent pages

The internal channel is integrated into the organisation. The external channel sends a report to a competent authority. Reporting people should receive clear information on the applicable options.

What the organisation should publish

  • Who may use the internal channel.
  • Which matters may be reported.
  • How to submit a written or verbal report, where applicable.
  • How confidentiality or anonymity is protected.
  • How to follow up and receive communication.
  • Information on relevant external channels.

Internal operation or external service

Contracting a platform or external provider does not automatically transfer every responsibility. The organisation still needs to define ownership, procedure, access, decisions and accountability.

Official sources: Portuguese Law 93/2021 — Diário da República and MENAC whistleblower-protection FAQ. This content does not replace legal advice.