01 — Purpose
Purpose
This page provides confidential channels for reporting suspected misconduct at or in connection with GUARANT Limited and sets out the protections and procedures that apply to reports made under this policy.
02 — Who May Report
Who May Report
Any employee, director, contractor, consultant, secondee, cedant, broker, supplier or other person who has information about suspected misconduct may make a report.
03 — Reportable Matters
What May Be Reported
Fraud, corruption or bribery.
Breach of law or regulation, including AML/CFT and sanctions requirements.
Breach of Company policies, including the Conflicts of Interest Policy and the Related Party Transactions Policy.
Conduct endangering health, safety or the environment.
Mistreatment, harassment or discrimination.
Suppression or concealment of any of the above.
04 — Reporting Channels
Reporting Channels
01
Internal Email
Send an email to confidential@guarantre.com. This channel is monitored by the Compliance Officer.
confidential@guarantre.com02
Written Report
Address a written report to the Compliance Officer at the Company’s registered office. The envelope should be sealed and marked “Strictly Confidential — Whistleblowing”.
03
Board-Level Escalation
Reports concerning the Compliance Officer or a member of the executive team should be directed to the Chair of the Audit Committee via boardconfidential@guarantre.com.
boardconfidential@guarantre.com04
External Counsel
An external legal counsel has been appointed to receive reports where the reporter does not wish to use an internal channel. Details of the appointed counsel are available on request from compliance@guarantre.com.
compliance@guarantre.comExternal Regulatory Escalation
05The Anjouan Offshore Finance Authority (AOFA) may be contacted directly by any person wishing to report a regulatory concern.
05 — Protections
Protections
Good Faith Protection
The Company is committed to protecting individuals who report concerns in good faith. No person who makes a report in good faith shall be subject to retaliation, dismissal, demotion, suspension, threat, harassment or any other form of detrimental treatment as a consequence of having made a report. Statutory whistleblower protections are applied where available under applicable law.
06 — Process
Process
1
Receipt and acknowledgement
Reports are acknowledged within five working days of receipt.
2
Preliminary assessment
The Compliance Officer (or the Chair of the Audit Committee, where applicable) conducts a preliminary assessment to determine whether an investigation is warranted.
3
Investigation
Where warranted, an independent investigation is conducted. Investigators may include internal compliance staff, internal audit or external counsel, depending on the nature and severity of the matter.
4
Findings
Findings are communicated to the reporter to the extent permitted by law, confidentiality obligations and the rights of any persons who are the subject of the report.
5
Remedial action
Appropriate remedial action is taken where the investigation substantiates the reported concern.