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Whistle-blower policy

Principle statement

We are committed to act lawfully, ethically, and with integrity, in accordance with the values of our organizations. Anyone noticing a violation of our values or applicable Code of Ethics is encouraged to report such concerns so that we can address and correct them.

Definitions

Whistle-blowing: This term refers to the disclosure or reporting of information that relates to potential violations of the Constanter values and the applicable Code of Ethics, such as: financial mismanagement, bribery or corruption, discrimination or harassment, non-compliance with policies, procedures or controls, improper use of assets, or potential violations of applicable law, including fraud.

Whistle-blower: We mean any individual who reports any suspected violation, as listed above. Whistle-blowers provide information based on a reasonably held suspicion that a violation or wrongdoing has occurred or is at risk.

Retaliation: This means any direct or indirect adverse action that is threatened, recommended, or taken against the whistle-blower because he or she reported a suspicion of wrongdoing.

Key Principles

  • Anyone noticing behaviour or actions of our stakeholders that seem to be in violation of our Constanter values or applicable Code of Ethics, may discuss the matter directly with that stakeholder to uncover the reason for that behaviour or action.

  • If the above is not possible, or when one wants to report the matter anonymously, it can also be reported directly to whistleblower@constanter.com, which can be accessed only by the Head of Risk & Assurance and the Head of Legal.

  • Ideally, violations should be reported in writing, and where possible, within six months of the event. The report should be factual, containing specific information for us to assess the nature, extent and urgency of the matter.

  • All reports of suspected or actual violations must be made in good faith. The whistle-blower must have reasonable grounds for believing that the information disclosed constitutes a potential violation.

  • Reports of suspected violations will be kept confidential to the maximum extent possible, consistent with the need to conduct a proper investigation.

  • The whistle-blower's identity will be kept confidential (to the extent permissible by local law) and they will be protected from any retaliation.

  • Every reported violation will be recorded (anonymously) in a central incident register. Depending on the nature of violation, an investigation team may be appointed.

  • A formal investigation report of all whistle-blower incidents will be prepared by the Head of Risk and shared with the appropriate levels of leadership on need-basis.

  • The whistle-blowing report (e.g. those received via email) will be acknowledged within five business days, and the whistle-blower can follow-up on the internal investigation within three months of the date of report.