Whistle-Blowing Policy

Speak up with confidence.

Blue Marina Asset Management Limited provides a structured way to report suspected unethical, illegal or improper conduct. The policy supports transparency, accountability and good corporate governance.

Reporting channels

Choose the channel that works for you

A report may be made anonymously or openly through any of the approved channels below.

Physical drop box

A physical whistle-blowing drop box is available at the Head Office reception.

All reports will be treated with confidentiality and seriousness.
What can be reported

Reportable concerns

Concerns may include, but are not limited to, the following.

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Fraud, bribery or corruption

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Insider trading or market manipulation

✓

Breach of SEC regulations or internal policies

✓

Money laundering or terrorism financing

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Harassment, discrimination or abuse

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Environmental, health or safety violations

✓

Attempts to conceal any of the above

Protection

Protection for whistle-blowers

  • Whistle-blowers acting in good faith are protected from retaliation, harassment or disadvantage.
  • Confidentiality will be maintained to the fullest extent possible.
  • Anonymous reports will be considered where they are credible and actionable.
  • A whistle-blower who is complicit in the reported misconduct is not entitled to protection under the policy.
Fair process

Rights of accused persons

  • Individuals named in a report will be informed of the allegations.
  • They will be given an opportunity to respond.
  • This may be delayed where informing the individual would compromise the investigation.
Governance

Oversight and accountability

Roles and responsibilities

Board of Directors Oversight and enforcement of the policy.
Chief Compliance Officer Administration and periodic review of the policy.
Internal Audit Investigation of reports and recommendation of corrective actions.
Whistle-Blower Responsible reporting in good faith.

Policy review

  • Every three years
  • Upon significant regulatory changes
  • As directed by the Board Audit, Risk & Compliance Committee
Policy date: September 2025

Have a concern you need to report?

You may report openly or anonymously. Use the dedicated whistle-blowing email channel to submit your concern.

Report a concern →