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Whistleblower Policy

Effective Date: 14/02/2025

1. Purpose

ZenithWave Capital Limited ("Company") is committed to the highest standards of integrity, ethics, and accountability in its operations. This Whistleblower Policy provides a confidential and secure process for employees, contractors, students, and other stakeholders to report any unethical, illegal, or improper conduct without fear of retaliation.

2. Scope

This policy applies to:

  • All employees (full-time, part-time, and contract-based).
  • Students enrolled in training programs.
  • Investors, suppliers, and other business associates.

3. Reportable Concerns

Whistleblowers may report concerns related to, but not limited to:

  • Financial fraud, misrepresentation, or insider trading.
  • Corruption, bribery, or unethical business practices.
  • Breaches of regulatory compliance, including GDPR and AML policies.
  • Discrimination, harassment, or workplace misconduct.
  • Data breaches or cybersecurity threats.
  • Any other serious legal or ethical violations.

4. Reporting Mechanism

Reports can be made through the following channels:

  • Email: majorsingh@zenithwavecapital.com
  • Anonymous Online Form: [Company's Secure Portal]
  • Whistleblower Hotline
  • Direct Reporting to the Compliance Officer at: Southbridge House, Southbridge Place, Croydon (CR0 4HA)

Reports may be made anonymously. However, providing contact details can assist in a thorough investigation.

5. Investigation Process

  • Upon receiving a report, the Compliance Officer will acknowledge receipt within 2 business days.
  • A preliminary review will determine if a full investigation is required.
  • Investigations will be conducted impartially, maintaining confidentiality.
  • Findings will be reviewed by senior management, and corrective action will be taken if necessary.

6. Protection Against Retaliation

Whistleblowers are protected from termination, demotion, harassment, or any form of retaliation. Any retaliation against a whistleblower will result in disciplinary action, up to and including termination.

7. False or Malicious Complaints

Reports should be made in good faith with reasonable belief in their validity. Knowingly making false or malicious allegations may result in disciplinary action.

8. Compliance & Review

This policy will be reviewed annually to ensure compliance with legal and regulatory changes. Employees and stakeholders are encouraged to familiarize themselves with this policy.

Contact

For any questions regarding this policy, please contact: compliance@zenithwavecapital.com