— Whistleblowing

The Navro Group is committed to the highest standards of compliance with its legal obligations. To this end we welcomes any form of information or report from internal and external parties which may be indicative of any regulatory or legal breach.

Such disclosures, known as whistleblowing, are protected by law and Navro must handle these in accordance with its internal Whistleblowing policy. This includes providing you with protection from any legal recriminations or any form of discrimination or reprisal by Navro or its employees where you make a disclosure.

The term whistleblowing and the protections covered under this policy are not universal and you  should be careful not to confuse whistleblowing with HR or other issues. At the present time, whistleblowing protections relate to disclosures relating to (As an example):

• A criminal offence, e.g., fraud, bribery corruption or misrepresentation, being carried out by either the company, an employee or one of our brokers,
• Someone’s health and safety is in danger, including employees, visitors, partners, or any other individual who uses our office space,
• A miscarriage of justice, such as where a new junior employee is being blamed for the action of their superior,
• The company is breaking the law, e.g., it does not have the right insurance or is offering products or services which it is not licensed to do, or
• You believe someone is covering up wrongdoing, for example employees are colluding to hide prior criminal activities.

It should be noted that the protections provided to a whistle-blower are not available in relation to the following areas:

• Personal Grievances, such as Bullying, Harassment or Discrimination, and
• Issues relating to pay, employment or personal issues.

In those circumstances applicable HR policies and processes should be followed.

Reports can be made anonymously and will be investigated and reviewed and investigated by the firms Compliance team. A record of all such reports, and the outcome of any investigations will be included as part of the firms quarterly board statistics, and where relevant may be made available to regulatory and supervisory bodies.

If you believe you have information which constitutes a whistle blowing event, please email us at:

Compliance@Navro.com