According to the General Regime for Corruption Prevention (RGPC), all "legal entities headquartered in Portugal employing 50 or more workers" must implement corruption prevention measures.
The RGPC, approved by Decree-Law No. 109-E/2021 of December 9th, stipulates that all covered entities, both in the public and private sectors, must have the following anti-corruption tools:
Corruption Risk Prevention and Related Offenses Plan
Code of Conduct on Corruption Prevention and Related Offenses
Corruption Reporting Channel
Regulations on Reporting Offenses