Whistleblowing Policy
Purpose
RC Brown Capital is committed to promoting the highest standards of integrity and accountability in all operations. This Whistleblowing Policy provides a mechanism for reporting and addressing concerns regarding unethical or unlawful conduct.
Scope
Applicable to:
• Employees
• Directors
• Contractors
• Partners
• Stakeholders
• Service providers
Reportable Matters
Examples of Reportable Wrongdoing:
• Fraud or financial misconduct
• Breach of securities laws and regulations
• Violations of internal policies
• Conflicts of interest
• Breach of data privacy
• Money laundering activities
• Bribery or corruption
• Unsafe work practices
• Environmental violations
• Misleading shareholders or regulators
Reporting Channels
Confidential Reporting:
Reports may be submitted via:
• Internal compliance hotline
• Email to compliance@rcbrowncapital.com
• Direct report to HR or management
• Anonymous reporting through third-party platforms
• Written submissions to the Ethics Committee
Protection of Whistleblowing
Non-Retaliation: The Company strictly prohibits retaliation against whistleblowers acting in good faith.
Investigation Process
Review:
Reports will be reviewed by the Compliance Officer and assessed for severity and materiality.
Investigation:
Where required, material breaches will be reported to:
• Securities and Exchange Commission
• Relevant regulatory authorities
• Internal Audit and Risk Committee
• External legal counsel (where necessary)
Regulatory Disclosure
Where regulatory requirements require, breaches may be disclosed to relevant authorities to ensure regulatory compliance and market integrity.