Updated: June 2023
At FundsDLT, we are guided by our company values. These values are the foundation of how we conduct ourselves and interact with each other, our clients, members, suppliers, shareholders and other stakeholders. The Company is committed to ensuring corporate compliance and promoting ethical corporate culture by observing the highest standards of fair dealing, honesty and integrity in our business activities.
The Company encourages the reporting of any instances of misconduct involving the Company’s business and provides protection and measures to individuals who make a disclosure in relation to such conduct without fear of victimisation or reprisal.
The Company relies on its employees maintaining a culture of honest and ethical behaviour.
By fostering a culture of accountability and transparency, we can ensure that all individuals associated with FundsDLT uphold the highest standards of conduct and contribute to a safe and ethical working environment. The purpose of this policy is to provide channels for employees and third parties associated with FundsDLT to report various types of irregularities. The following categories of misconduct or inappropriate behaviour should be reported:
Examples of irregularities that should be reported include, but are not limited to:
By adhering to these guidelines, you can contribute to the integrity and compliance of FundsDLT. Your reports are crucial in ensuring a transparent and accountable environment for all stakeholders. Accordingly, if you become aware of any Reportable Conduct, it is expected that you will make a disclosure.
There are several ways in which you may report or disclose any issue or behaviour which you consider to be Reportable Conduct or as per the examples above.
Internal Parties Reporting
You may disclose any reportable conduct to the Whistleblower Protection Officer listed below:
Human Resource Director
Chief Executive Officer
Head of Compliance
External Parties Reporting
Where you do not feel comfortable making an internal report, or where you have made an internal report, but no action has been taken within a reasonable time, you may disclose any Reportable Conduct to the Company’s external auditor/Company’s Chairman of the Board who will prepare a report which details the concerns raised by you to a Whistleblower Protection Officer.
Any information contained in the report will be kept confidential, except as required by law or where disclosure is necessary to regulatory authorities, law enforcement agencies or professional advisors to the Company.
FundsDLT Chairman of the Board of Directors
FundsDLT External Audit Partner
In addition to the opportunity to report a breach of law through those two channels above, a whistleblower may also make a report via a public disclosure to one of the 22 competent authorities. Please refer to the article 18 of the law of 16 May 2023, we only list hereafter the relevant public disclosure for our business: