Whistleblowing Policy.

Effective Date: 1 June 2025Lamal Partners Limited is committed to maintaining the highest standards of integrity, transparency, and accountability. We encourage all employees, contractors, and business partners to report any concerns about wrongdoing, unethical conduct, or breaches of legal or regulatory obligations.

 

1.     Purpose

This policy aims to provide a safe, confidential, and accessible mechanism for raising concerns without fear of retaliation or victimization.

2.     Scope

This policy applies to all employees, contractors, consultants, and third parties working with Lamal Partners Limited.

 

3.     What to Report

Concerns that should be reported include, but are not limited to:

  • Fraud, bribery, or corruption

  • Legal or regulatory breaches

  • Unsafe or unethical behavior

  • Misuse of company assets or resources

  • Conflicts of interest

  • Any attempt to suppress whistleblowing or retaliate against reporters

 

4.     Reporting Process

  • Concerns can be raised confidentially and securely with the Chief Compliance Officer at compliance@lamalpartners.com.

  • Reports can be made in writing or verbally.

  • Anonymous reports are accepted, but providing contact details is encouraged to facilitate investigation.

 

5.     Protection and Non-Retaliation

  • Lamal prohibits retaliation against any individual who raises a concern in good faith.

  • Retaliation includes dismissal, demotion, harassment, or any adverse treatment.

  • Any retaliation will result in disciplinary action up to and including termination.

 

6.     Investigation and Outcomes 

  • All reports will be acknowledged within 5 business days.

  • An impartial investigation will be conducted, maintaining confidentiality where possible.

  • Outcomes may include corrective action, disciplinary measures, or referral to regulatory authorities.

 

7.     Record-Keeping

  • All whistleblowing reports and related documents will be securely stored for at least 6 years.

  

8.     Integration

This Whistleblowing Policy is incorporated within Lamal Partners Limited’s broader Policies & Procedures Manual.

On behalf of the board of directors,

Lamal Partners Limited.