STOKR Whistleblowing

STOKR operates a designated reporting channel for anyone who becomes aware of unlawful conduct through their work with us. Reports are handled confidentially by our whistleblowing function, and the law protects those who use the channel.

Who can report

You can use this channel if you qualify as:

• Employee or former employee
• Self-employed contractor or consultant
• Shareholder, Authorised Management or Board members, including non-executive
• Trainee, paid or unpaid
• Staff of our contractors, subcontractors and suppliers
• Candidate in a recruitment process

Protection also covers anyone who assists a reporter, colleagues or relatives who could face retaliation, and connected legal entities.

What can be reported

Any act or omission that is unlawful or defeats the purpose of Luxembourg or EU law, including attempts to conceal one. You do not need proof: a reasonable suspicion is enough, as is something that has not happened yet but is very likely to.

• money laundering or terrorist financing
• breaches of financial services or market conduct rules
• fraud, bribery, corruption, falsified documents or records
• data protection breaches
• discrimination, harassment, or health and safety failures
• accounting, auditing or competition law breaches
• material breaches of our Code of Conduct

What this channel is not for

• Day-to-day personnel matters, routine employment questions and interpersonal conflicts, raise these with your manager, HR or Legal.
• Client complaints: see our Complaints Handling Policy.

How to report

What happens next

The three-month deadline is for feedback, not for closing the matter.

Confidentiality

Your identity, and anything from which it could be deduced, is not disclosed beyond the authorised persons handling the report without your express consent.

Disclosure is possible only where the law requires it in an authority investigation or judicial proceedings, including to safeguard the rights of defence of the person concerned. You will be told in writing beforehand, with reasons, unless that would jeopardise the proceedings.

Protection from retaliation

We will not tolerate retaliation against anyone who reports in good faith or assists an investigation, including any reprimand, reprisal, change in work duties, employment amenities or reporting requirements, damage to career prospects or reputation, threats to do any of these, or deliberate omissions that may cause harm.

Reporting anonymously does not remove your protection if you are later identified.

Reporting outside STOKR

You are not required to use this channel first and do not lose protection by going directly to an authority. We encourage reporting directly to STOKR where the breach can be effectively addressed internally and you see no risk of retaliation.

CSSF: financial sector matters: https://whistleblowing.apps.cssf.lu/index.html

Office des signalements: information and confidential advice on the competent authority: 13, rue Erasme, L-1468 Luxembourg · +352 247-88564 · [email protected]

The Law of 16 May 2023 designates twenty-two competent authorities. Reports may also be made to the competent EU institutions and bodies.