The external whistleblowing channels are the ones available before the competent authorities and entities (Public District Attorney, police departments, supervision entities amongst others listed below).
To be granted the protection provided under the whistleblowing law (Law no 93/2021, of December 20) one should file a report at the internal whistleblowing channels before submitting it at the external reporting channels, except when:
(a) You have reasonable motives to believe that the reported situation cannot be effectively known or handled internally.
(b) There is retaliation risk.
(c) You have already presented an internal report and you haven’t been notified of: (i) the measures anticipated or adopted following the report, within 3 months from the date of presentation of the report or (ii) upon your express request you haven’t been notified of the result of the analysis to the report within 15 days after its conclusion.
(d) You are reporting a crime or an administrative offence sanctionable with a fine of € 50,000 or more.
External reports should be filled before the competent authorities that, pursuant its powers and responsibilities should or may handle the report, notably:
(a) Public District Attorney.
(b) Police departments.
(c) Bank of Portugal.
(d) Independent administrative authorities.
(e) Public institutes.
(f) General inspection entities and similar entities and other central services of the direct State administration with administrative autonomy.
(g) Municipalities; and
(h) Public associations.
If the competent authority to handle the report does not exist or when the report aims the competent authority, the report should be submitted before the Anticorruption National Mechanism and, if the report concerns the Anticorruption National Mechanism, at the Public District Attorney.
The external reports can always be filled before external report channels of the Public District Attorney or of the police departments, if the report concerns a crime and of the competent administrative authorities or of the police or supervisory authorities, if the report concerns an administrative offense.
External reporting channels allow written or oral, anonymous or non-anonymous reports.