Last updated: September 2025
Scope of whistleblowing
- Covers suspected fraud, market abuse, bribery and corruption, breaches of law or regulation, serious breaches of internal policy, and any conduct that may harm clients, the firm, or the integrity of financial markets.
- Applies to all Metra employees, directors, contractors, consultants, and, where appropriate, external stakeholders such as vendors and partners.
Reporting channels
- Primary reporting channel: the Compliance Officer via [email protected] or other dedicated channel specified by Metra.
- Alternative channels may include escalation to senior management or, where permitted by law, directly to VARA or other relevant regulator.
- Reports may be made on a named or anonymous basis, subject to local law.
Confidentiality and non-retaliation
- Metra treats whistleblowing reports as confidential to the fullest extent practicable and in line with legal and regulatory requirements.
- Retaliation against any person who raises a concern in good faith is strictly prohibited and may itself be treated as a disciplinary offence.
Assessment, investigation and outcome
- Reports will be acknowledged, logged, and subject to an initial assessment to determine appropriate next steps.
- Where warranted, an impartial investigation will be carried out, which may involve Compliance, Legal, HR, and other relevant functions.
- Outcomes may include remediation, disciplinary action, process improvements, or escalation to regulators or law enforcement where required.