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Whistleblowing Policy

1. Operation guidelines on reporting regulatory breaches

Arma Partner LLP’s regulations require the establishment of an internal channel for reporting possible violations of the rules governing its activities.

Arma Partner LLP (the “Firm”) has therefore drawn up a Whistleblowing Policy (the “Policy”) that enables the people listed in the following paragraph to report violations that they know about or suspect are taking place.

Reports will be dealt with in accordance with the Policy, as summarised below.

2.  Who may report

The internal and external reporting channels are available to anyone who falls into one of the following categories:

  • staff member of the Firm (regardless of the type of contract and including temporary staff, consultants and representatives of Arma);
  • suppliers of the Firm;
  • shareholders of the Firm; and
  • members of the Firm’s corporate bodies.

The channels are also available to people who do not yet fall into one of the above categories (if the violation occurred during the selection process) and to people who no longer have a relationship with the Firm (if the violation occurred during the relationship).

Where practicable and in accordance with the principle of proportionality, Arma will deal with reports made by people other than those listed above in accordance with the principles set out in this notice.

3.  What may be reported

Violations of the external and internal rules applying to Arma may be reported through the whistleblowing channels, in particular with regard to:

  • a criminal offence;
  • a failure to comply with any applicable legal obligation;
  • a miscarriage of justice;
  • endangering the health and safety of any individual in general;
  • damage to the environment;
  • breaches of regulations on: financial services, products, and markets; anti-money laundering and counter-terrorist financing; protection of personal data and respect of privacy; security of networks and IT systems;
  • breaches of rules on competition and corporate tax; and
  • deliberate concealment relating to any of the above.

Complaints relating to a personal interest linked to the reporting person’s personal employment are not covered by the whistleblowing channels. Reports relating to human resources issues (e.g. harassment, bullying, equal opportunities) will be dealt with in accordance with the relevant internal regulations, which are in any case consistent with the whistleblowing measures, in accordance with the principle of proportionality.

4.   How to make an internal report

 It is possible to make an internal report through one of the following channels:

  • through the Arma Whistleblowing Portal;
  • by traditional post (Arma Partners LLP, The Shard, 32 London Bridge St, London SE1 9SG – for the attention of the Chief Compliance Officer).

It is also possible to request a direct meeting with the Chief Compliance Officer to make the report; a notetaker may also be present at this meeting. In this case, with the consent of the reporting person, a minute of the meeting will be drawn up in order to deal with the report.

The report should include information regarding the name(s) of the person(s) allegedly responsible for the violations and a description of the alleged violation, including the circumstances of when and where it occurred, as well as any third parties involved (e.g. facilitators, other people who may have knowledge of the facts or who may have been harmed) and description of their involvement. To facilitate the handling of the report, any available supporting documentation should be attached.

The reporting person should specify their involvement (if any) to ensure appropriate actions are taken in accordance with applicable regulations.

Personal data should not be included in the report, except where strictly necessary for the analysis and follow-up of the report.

It is possible to make a report anonymously. However, in this case, the Firm’s ability to investigate will be limited as it will not be able to establish a direct relationship with the reporting person. Therefore, such reports should be as clear and detailed as possible, to facilitate further analysis.

If the report concerns the Chief Compliance Officer, a member of the Compliance team or a Partner other than the General Counsel, the report should be addressed to the General Counsel, either by filling in the relevant field on the platform or by traditional post (Arma Partners LLP, Level 27 The Shard, 32 London Bridge St, London SE1 9SG– for the attention of the General Counsel).

5.  Arma’s whistleblowing portal

The platform enables the creation of a report through a step-by-step process, ensuring the reporting person’s identity remains confidential or completely anonymous, if preferred. It also safeguards the security, integrity, and confidentiality of the submitted data, using encryption tools for protection.

The report can be submitted in writing through the portal or orally using the portal’s recording feature.

When the report is submitted through the portal, the platform generates an identification code, known only by the reporting person which allows them to access their report in order to (i) monitor its progress; (ii) contact the Champion (as defined below) directly; and/or (iii) answer any further questions.

It will therefore be up to the reporting person to check their report regularly to see its progress and/or whether there are any messages from the Champion.

Reports received outside the platform can also be processed within the platform. In this case, the Champion will provide the reporting person (if not anonymous) with the identification code generated to allow them to access the report and follow its progress.

6. How the Firm handles Internal reports

The Firm has designated the Chief Compliance Officer as the person responsible for the whistle- blowing internal channel (the “Champion”).

Once a report has been made, the reporting person will receive an acknowledgment of receipt within seven days. In the case of report sent through traditional post, the Champion will be able to provide such notification if the report is not anonymous.

The Champion may contact the reporting person during the internal investigation if additional information is required. It may make the investigation more difficult for the Champion if the reporting person does not provide such reasonably requested information.

The internal investigation and the handling of reports may involve people other than the Champion who are authorised to process the personal data of the reporting person and other people involved in the report. In any case, no one named in the report will be involved in these activities.

In all cases, the Champion will update the reporting person, where the reporting person is known, within three months of the notification of receipt of the report (or, if no notification could be made, within three months of the seventh day after the report was made). This update will concern the outcome of the investigation and any action taken. If the investigation is not completed within three months, the Champion will provide further feedback to the reporting person at the conclusion of it.

7. How the Firm protects the confidentiality of the reporting person

Any member of staff making a disclosure about wrongdoing is protected from discrimination resulting from such disclosure by the Public Interest Disclosure Act, as long as the disclosure is made in good faith.

Arma has procedures in place to protect the confidentiality of the identity of the reporting person and of the other people involved in the report, of the contents of the report and of the relevant documents until the end of the proceedings initiated on the basis of the report. However, in the case of reports made to authorities, the confidentiality of the identity of the people involved or mentioned in the report may not be capable of being maintained by the Firm, as this process will be subject to the conditions provided for by applicable legislation. The identity of the reporting individual and any information that could reveal their identity must not be disclosed to anyone other than those specifically designated to receive and manage reports and authorised to process such data, except with the express consent of the reporting person, when it is mandatory or legitimate under applicable law, or when the disclosure of the reporting person’s identity is required (e.g. in the context of an investigation by the authorities or legal proceedings). In this case, the reporting person will be informed by the Firm of the reasons justifying the disclosure.

For information on the personal data processed by the Firm when receiving and handling reports, please refer to the information notice on the processing of personal data in accordance with the UK GDPR and applicable national data protection regulations.

8.  How the Firm protects the reporting person against retaliation

Arma is committed to supporting the reporting person, as well as any individual involved in the report, from any form of retaliation related to whistleblowing. In addition, the people involved in the report are protected against any negative consequences within the workplace other than disciplinary measures taken as a result of the investigation of a substantiated report.

Facilitators, family and friends of the reporting person, as well as companies associated with the reporting person, will also be protected from retaliation.

Anyone who acts in a retaliatory, discriminatory and unfair manner against the reporting person and others involved in the report may be subject to disciplinary action, where appropriate.

9.  How to make an external report

If a staff member, having made a disclosure through the appropriate channel(s), considers that:

  • the matter has not been dealt with appropriately;
  • there are reasonable grounds to believe that an internal report would not be effectively followed up or it could lead to a risk of retaliation against the reporting person; and/or
  • there are reasonable grounds to believe that the violation may constitute an imminent or manifest danger to the public interest,

then, where the subject matter of the disclosure is relevant to the FCA, the staff member may contact the FCA whistleblowing hotline:

As far as possible, Arma undertakes to protect the confidentiality of the reporting person and to protect them against retaliation, even in the case of an external report.

10.   Data Protection Information Notice

 Arma considers data protection a fundamental principle to be guaranteed in the provision of its services.

Arma is committed to safeguarding the protection and confidentiality of personal data, designing and implementing privacy procedures and standards in compliance with the principles set out by the retained EU law version of the General Data Protection Regulation ((EU) (2016/679) as defined in the Data Protection Act 2018 (the “GDPR Provisions”).

For further information regarding the protection of personal data processed by Arma, you may refer to the Privacy Notice.

In accordance with the GDPR Provisions, Arma has appointed a Data Protection Officer.

The Data Protection Officer may be reached at the following email address:

Compliance@armapartners.com.