Compliance

Which breaches can be reported?

Although the scope of the Whistleblower Directive and the national legislation transposing it only covers breaches of certain laws, Golding Capital Partners explicitly welcomes any report of misconduct, such as the suspicion of money-laundering, breaches of supervisory obligations or unethical and illegal behaviour concerning the company, its employees or business partners.

Before a report is made there should be a reasonable suspicion, knowledge of actual or potential breaches that have already occurred or are very likely to occur, or attempts to conceal such breaches. The reporting system may not be used to make false accusations. Knowingly reporting false information is explicitly forbidden and may have legal consequences for the person reporting.

How can a report be made?

Reports can be made to Golding Capital Partners at any time. There are no formal requirements for doing so. Golding Capital Partners has set up an internal reporting channel at its offices in Germany and Luxembourg, which can be reached as follows:

Golding Capital Partners GmbH · Reporting channel for whistleblowers
Einsteinstraße 172 · D-81677 Munich
E-mail: whistleblower@goldingcapital.com

and

Golding Capital Partners (Luxembourg) S.A, · Reporting channel for whistleblowers
6, avenue Marie-Thérèse· L-2132 Luxembourg
E-mail: whistleblower_lux@goldingcapital.com

Reports should include a full, precise description of the matter, all relevant documents that substantiate the plausibility and credibility of the report, and a brief explanation of the legal provisions that have been breached, as well as the name and contact details of the whistleblower, unless the report is being made anonymously.

What happens once the report has been made?

Unless the report was made anonymously, the whistleblower receives written or electronic confirmation of receipt soon after the report has been made, showing the name and contact details of the person responsible for handling the information. The whistleblower can contact the person mentioned at any time during the follow-up process. Golding Capital Partners aims to follow up reports within three months. We must point out that feedback can only be given to the extent that this does not affect internal investigations or infringe the rights of individuals who are affected by or mentioned in the report.

Is there a risk for the whistleblower?

All reports are treated in strict confidence. In addition, Golding Capital Partners guarantees that the company will not retaliate against the whistleblower or threaten any such retaliation, even if it turns out that there was no breach of the law; on condition that the whistleblower had reasonable grounds for assuming that the information reported was correct at the time the report was made.

What other reporting channels are there?

Reports can also be made to the external reporting channels set up by the Member States, particularly if the whistleblower has not received any (satisfactory) feedback from the company. Further information is available from the websites of the supervisory authorities, particularly

the German financial supervisory authority

the Luxembourg financial supervisory authority

What happens to my personal data?

Personal data are only collected if you provide them voluntarily in the context of your report. In this case the data consists in particular of your name and address, telephone number, email address and all the information you provide voluntarily in the report.

Processing of your personal data in the course of the reporting procedure is necessary to meet legal obligations. The personal data is stored for at least six years in accordance with statutory retention periods and then generally erased.