Portugal. Risk & Compliance Management

Raquel Cardoso Nunes, Adriano Squilacce.

The growing criminal and administrative liability of legal persons and, in some cases, the personal liability of directors for acts committed within the company led to a change of direction in internal organisations in Portugal, taking advantage of the signs that courts initially gave in other jurisdictions. Since 2021, every company in Portugal that employs 50 or more individuals has been required by law to implement:

  • a compliance program targeting the potential criminal risks related to the company’s activity (Plan of Risk Prevention), in particular in what concerns preventing corruption and related activities;
  • a code of conduct;
  • a training programme; and
  • a whistleblowing channel.

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