Franchising

1. Object

This Policy establishes an internal and voluntary mechanism for reporting irregularities, promoting legality, transparency and compliance with legal obligations, namely in terms of the prevention of money laundering and terrorist financing, under the terms of Law No. 83/2017 and IMPIC guidelineselement.

2. Scope

This policy applies to:

• Employees

• Service providers

• Partners

• Clients or third parties who are aware of relevant facts related to the activity of Central Imobiliária

3. Situations that can be reported

The following situations may be reported, among others:

Money laundering and terrorist financing

• Suspicious transactions

• Use of funds of illicit origin

• Attempts to conceal the identity of the customer or beneficial owner

• Unjustified refusal to provide mandatory documentation (KYC)

Other infractions

• Fraud

• Corruption or attempted bribery

• Conflicts of interest

• Failure to comply with legal or regulatory obligations

• Violation of ethical or professional duties

4. Whistleblowing channel

Complaints must be made through the following means:

denuncias.centralimobiliaria@yahoo.com

The complaint may be submitted in writing and, where possible, must contain:

• Clear description of the facts

• Date or period in which they occurred

• Identification of the persons involved (if known)

• Documents or supporting elements (if any)

5. Confidentiality and whistleblower protection

• The identity of the whistleblower will be treated confidentially

• Retaliation or reprisals against whistleblowers acting in good faith are not permitted

• Identity may only be disclosed when legally required

6. Handling of complaints

• The complaint will be analyzed impartially and diligently

• Where applicable, additional clarifications may be requested

• If the facts justify it, corrective measures will be adopted or communicated to the competent authorities (e.g. FIU/DCIAP, where applicable in the field of money laundering)

7. Retention of information

• Reports and their records will be kept securely

• Access is limited to those who are strictly necessary

• The information will be kept for the legally appropriate period, in accordance with the GDPR

8. Protection of personal data

The processing of personal data within the scope of this policy complies with the General Data Protection Regulation (GDPR) and is used exclusively for the analysis and handling of complaints.

9. Good faith

Central Imobiliária values complaints made in good faith.
False, intentionally misleading or bad faith reports can give rise to legal liability.

10. Entry into force

This Policy enters into force on the date of its approval and is available for consultation whenever requested.