The channel is open to anyone with a reasonable concern — Directors, the Investment Manager and its personnel, service providers, current and prospective investors, counterparties, and members of the public.
You are not required to be certain that wrongdoing has occurred before raising a concern. You are only required to act in good faith, on the basis of information you reasonably believe to be accurate.
Concerns the channel exists to receive.
| Financial crime | Suspected money laundering, terrorist financing, sanctions evasion, fraud, bribery, or corruption. |
| Regulatory breaches | Suspected breaches of SIBA, the Private Investment Funds Regulations 2019, the AML / CFT Code of Practice, the Beneficial Ownership Secure Search System Act, FATCA & CRS, the Data Protection Act 2021, or the TCI Insurance Ordinance. |
| Conflicts of interest | Undisclosed related-party transactions, undisclosed outside interests, or other conflicts that have not been managed in accordance with the Conflict of Interest Policy. |
| Misuse of assets | Suspected misuse of Fund assets, escrow funds, investor data, or service-provider data. |
| Workplace conduct | Discrimination, harassment, retaliation, or other conduct in breach of the Code of Conduct. |
| Cyber and operational | Suspected cyber incidents, data breaches, or material control failures. |
| Health, safety & environment | Risks to the safety of personnel, investors, or counterparties. |
| Anything else of concern | If you are unsure whether a concern is in scope, raise it. The Compliance Officer will assess scope and route. |
Three independent channels.
You may raise a concern through any of the channels below. You may use more than one. You may remain anonymous in any of them.
External whistleblowing portal
Independently hosted and operated by [external whistleblowing provider]. Submissions are received by the provider, encrypted at rest, and forwarded to the Compliance Officer with no IP or identity metadata unless you choose to disclose it.
Portal: [external whistleblowing portal URL]
Dedicated email
A dedicated mailbox monitored only by the Compliance Officer and the Director with operational and compliance responsibility. Encryption keys are held only by these two persons.
Email: [[email protected]]
Postal address
A signed letter, sent in a sealed envelope, marked confidential. The envelope is opened only by the Compliance Officer.
Address: The Compliance Officer, c/o Quijano & Associates (BVI) Limited, Mandar House, 3rd Floor, Suite 301, P.O. Box 3159, Road Town, Tortola, British Virgin Islands.
Confidentiality. Non-retaliation. Investigation.
| Confidentiality | Your identity will be treated as confidential to the maximum extent permitted by law. Disclosure will be made only to those persons strictly required to investigate the concern, or where compelled by law or regulator. |
| Anonymity | You may raise a concern anonymously. The channel is configured so that submissions can be received without any identifying information. Anonymous reports are investigated to the same standard as named ones, subject to the practical limits of investigation without the ability to seek follow-up information. |
| Non-retaliation | The Group prohibits any form of retaliation against a person who raises a concern in good faith. Suspected retaliation is itself reportable to this channel and will be investigated as a separate matter. |
| Acknowledgement | Where contact details are provided, the Compliance Officer acknowledges receipt within seven (7) calendar days, and provides a status update within thirty (30) days, subject to legal and investigative constraints. |
| Investigation | Concerns are triaged by the Compliance Officer, escalated to the Director (Operations / Compliance), and — where material — to the full Board, the Auditor, the Responsible Person, and the relevant regulator. |
| External authorities | You may at any time, in addition to or instead of the internal channel, report concerns directly to the BVI Financial Services Commission, the BVI Financial Investigation Agency, the BVI International Tax Authority, or the TCI Financial Services Commission, as applicable. |
From a first message to a written outcome.
Receipt & triage
Compliance Officer receives the report. Concern is logged in the SAR / STR Register where appropriate. Director (Operations / Compliance) is notified.Investigation
Internal investigation, supported where required by external counsel, the Auditor, or specialist forensic resources. Conflicted persons are recused.Outcome & reporting
Written outcome to the Board. Where required, notification to the BVI FSC, the BVI Financial Investigation Agency, or another competent authority. Reporter informed where contact details are available.Speaking up is encouraged. It is also protected.
The full Whistleblowing Policy (with detailed definitions, process, and timelines) is available in the Investor Data Room and is reviewed annually at the Q4 Board cycle. Any change to the channels or contact details on this page is communicated through the regulatory band of every page on this website and through the Quarterly Investor Report.