Following the approval of the National Anti-Corruption Strategy 2020-2024, Decree-Law no. 109-E/2021 was published in
the Official Journal on December 9, 2021, creating the National Anti-Corruption Mechanism ("MENAC") and approving the
General Regime for the Prevention of Corruption ("RGPC").
With the aim of preventing, detecting and sanctioning acts of corruption and related violations, the RGPC establishes
the obligation for public and private entities to adopt and implement a Regulatory Compliance Program, which must
include at least the following elements
(i) a plan to prevent risks of corruption and related infractions (PPR);
(ii) a code of conduct;
(iii) a whistleblowing channel; and
(iv) a training program.
Additionally, the execution of the PPR is subject to control, carried out in the following terms:
a) Preparation, in the month of October, of an interim assessment report of situations of high or maximum risk identified;
b) Preparation, in the month of April of the year following execution, of an annual assessment report, containing namely
the quantification of the degree of implementation of the preventive and corrective measures identified, as well as
the forecast of their full implementation.