First Sentier Investors / FSSA Investment Managers / Igneo/ RQI/ Stewart Investors (“we”, “us”, “Group”) is committed to maintaining high standards of corporate governance, ethics and behaviour in all of our activities, as part of which we require that our employees display the highest levels of professionalism in all aspects of their work to facilitate compliance with its Code of Conduct and all applicable laws.
We are also committed to maintaining a culture where all people feel empowered to report misconduct and to feel protected from retaliation when doing so.
We encourage all current or past employees, as well as others with a connection to us, such as current or past suppliers or service providers and their employees or a relative or dependant or a spouse of any of these individuals who suspect misconduct to Speak Up. In Ireland, Germany and Luxembourg, if a job applicant suspects misconduct they are also encouraged to Speak Up.
If individuals as noted above, (referred to as “you”) have reasonable grounds to suspect that misconduct has occurred or is occurring in relation to the Group or an employee of the Group and believe the information in relation to the misconduct being disclosed is true, you are encouraged to Speak Up, by reporting it to our Whistleblower Protection Officer through the whistleblower telephone hotline or website or another person authorised to receive such reports in your location.
The hotline and website are hosted by a third party hotline provider, EthicsPoint. The information you provide will be sent to us by EthicsPoint and will be treated with confidentiality unless you consent to us disclosing personal information about you or others, on a need to know basis, or where we are legally required to. You can also choose to remain anonymous.
We are committed to making sure that you are treated fairly and do not suffer detriment because you Speak Up. The practical protections offered will depend on things such as the misconduct and people involved, however examples may include providing medical, counselling or support services, different work arrangements or granting leave for the duration of the investigation.
We will not victimise you or someone else, because you decide to Speak Up or we believe you may Speak Up.
Any person who has been found to have victimised you will be subject to disciplinary action, including but not limited to termination of employment or engagement. In some circumstances, this may also be a criminal offence. Any person that has victimised someone else may be referred to law enforcement authorities.
Please note these requirements do not apply to portfolio companies where an employee is a director on the board of the portfolio company. For example, a portfolio company held by an Igneo Infrastructure Partners fund.
We treat personal information in accordance with the Company’s global Privacy Notice and any specific privacy notice relevant to your location.
Also see the EthicsPoint FAQs and Privacy Statement for more information on the service and how personal information is processed by EthicsPoint.