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 all employees 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, it includes job applicants.

If individuals as noted above have reasonable grounds to suspect that Misconduct has occurred or is occurring and believe the information in relation to the Misconduct being disclosed is true, they are encouraged to Speak Up, by reporting to the Group Whistleblowing Protection Officer or another person authorised to receive such reports through the channels mentioned below.

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.

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 April 2025.