We recognize that it takes courage to raise a concern. We have an Integrity Hotline to allow our stakeholders to confidentially raise any concern they have relating to unethical, illegal, discriminatory, or irresponsible acts that will prevent us from fulfilling our vision of delivering positive impact to the world.

Raising concerns helps us to deal with issues before they become more serious, ensuring Palladium is a safe, inclusive environment for all.

We have zero tolerance for retaliation against a reporter who has raised a concern. If you believe you have been subjected to retaliation, you should report it immediately.

We treat all concerns in a confidential, respectful way, always considering the welfare and safety of the reporter.

You have several options to make a Report, and you should do so as promptly as possible. You may use any of the following methods that you are most comfortable with:

• Your manager or supervisor.
• Project, Corporate or Senior Leadership
• Chief Diversity Officer (Global Equity, Diversity & Inclusion/Safeguarding Lead)
• Human Resources representative
• Legal & Risk Management Team
• Here on the Palladium Integrity Hotline (web or telephone)
• By post: 1331 Pennsylvania Ave., NW, Suite 600, Washington DC 20004 United States of America Marked: ‘Private and Confidential, Attn: General Counsel’.

This does not prohibit anyone from reporting concerns to, filing a charge or complaint with, or participating in an investigation with any government agency charged with the enforcement of any law.

Please note that if you report a concern anonymously, you will have to check back using the report key provided through the Integrity Hotline to answer follow up questions to help with the investigation. You can also use the report key to receive follow-up information about your concern.

Non-Retaliation

Palladium prohibits retaliation in any form and will not tolerate retaliation against any employee who:

• comes forward to raise, in good faith, a concern about a violation of any law, our Code of Conduct or any Palladium policy, or
• assists us, or a law enforcement authority, by providing information to address a concern.
• refuses to participate in improper or unlawful conduct.

If you prefer, you may raise your concern anonymously. Your concern will be kept confidential to the extent permitted by law and consistent with the need to investigate and resolve the matter. Palladium takes all reports of retaliation very seriously. If you believe you have been subjected to retaliation, you should report it immediately.