Whistleblower statement

Speaking up

The First Sentier Group (“Group”) is committed to maintaining high standards of corporate governance, ethics and behaviour in all of its activities, as part of which the Group requires that its employees display the highest levels of professionalism in all aspects of their work to facilitate compliance with its Code of Conduct and all applicable laws.

The Group is also committed to maintaining a culture where people feel empowered to report misconduct and to feel protected from retaliation when doing so.

The Group encourages all current or past employees, as well as others with a connection to the Group, such as current or past suppliers or service providers and their employees or a relative or dependant or a spouse of any of these individuals, who suspect misconduct to Speak Up. In Ireland, Germany and Luxembourg if a job applicant suspects misconduct they are also encouraged to Speak Up.

If you have reasonable grounds to suspect that misconduct has occurred or is occurring in relation to the Group or an employee of the Group, and believe the information in relation to the misconduct being disclosed is true, you are encouraged to Speak Up by reporting to the Group Whistleblowing Protection Officer or to another person authorised to receive such reports through the channels mentioned below.

We are committed to making sure that you are treated fairly and do not suffer detriment because you Speak Up. The practical protections offered will depend on things such as the misconduct and people involved, however examples may include providing counselling or support services, different work arrangements or granting leave for the duration of the investigation.

We will not victimise you or someone else, because you decide to Speak Up or we believe you may Speak Up.

Any employee who is found to have victimised you will be subject to disciplinary action, including but not limited to termination of employment or engagement. In some circumstances, this may also be a criminal offence. Any person that has victimised someone else may be referred to law enforcement authorities.

Examples of misconduct

Misconduct as mentioned above includes:

• conduct that breaches any law, regulation, regulatory licence or code that applies to the Group (e.g. criminal activity, fraud, corruption, bribery, facilitating tax evasion)
• miscarriages of justice
• unethical behaviour
• violation of human rights
• inappropriate accounting, control or audit activity, including the irregular use of Group or client monies
• a breach of policies or procedures
• behaviour that harms or is likely to harm the reputation or financial well-being of the Group
• conduct likely to endanger the public or financial systems
• danger to health and safety
• damage to the environment, and
• the deliberate concealment of any of the above matters.

Please note these requirements do not apply to portfolio companies where an employee is a director on the board of the portfolio company. For example, a portfolio company held by an Igneo Infrastructure Partners fund.

How to report a potential misconduct

Your report will be treated with confidentiality unless you consent to us disclosing personal information about you or others, on a need-to-know basis or where we are legally required to.

Your report can be made through the following external channels:

In the US, your report can be made through the MUFG Americas Integrity Line hotline:

This Whistleblower statement was updated in March 2026.