Whistleblowing Policy

This Whistleblowing Policy sets out how employees, contractors, service providers and other stakeholders of METRA can safely and confidentially raise concerns about suspected misconduct, regulatory breaches or unethical behaviour.

Scope of Whistleblowing

• Covers suspected fraud, market abuse, bribery and corruption, breaches of law or regulation, serious breaches of internal policy, and any conduct that may harm clients, the firm or the integrity of financial markets.
• Applies to all METRA employees, directors, contractors, consultants and, where appropriate, external stakeholders such as vendors and partners.

Reporting Channels

• Primary reporting channel: the Compliance Officer or designated whistleblowing officer via secure email or other dedicated channel specified by METRA.
• Alternative channels may include escalation to senior management or, where permitted by law, directly to the relevant regulator.
• Reports may be made on a named or anonymous basis, subject to local law.

Confidentiality and Non-Retaliation

• METRA treats whistleblowing reports as confidential to the fullest extent practicable and in line with legal and regulatory requirements.
• Retaliation against any person who raises a concern in good faith is strictly prohibited and may itself be treated as a disciplinary offence.
• Information will be shared only with those who need to know in order to assess and address the concern.

Assessment, Investigation and Outcome

• Whistleblowing reports will be acknowledged, logged and subject to an initial assessment to determine appropriate next steps.
• Where warranted, an impartial investigation will be carried out, which may involve Compliance, Legal, HR and other relevant functions.
• Outcomes may include remediation, disciplinary action, process improvements or escalation to regulators or law enforcement where required.