Whistleblowing Policy

UPDATED AUGUST 2025

Our Commitment to Integrity

MANTRA Finance is committed to conducting its business with the highest standards of integrity, transparency, and accountability. We foster a culture where our employees, partners, and stakeholders are encouraged to speak up about any serious concerns they may have about potential misconduct. This policy outlines the framework for reporting such concerns without fear of retaliation.

What to Report

A reportable concern involves any suspected misconduct, malpractice, or unethical behavior that could harm MANTRA Finance, our clients, our employees, or the public. This includes, but is not limited to:

  • Financial Misconduct: Such as fraud, theft, bribery, or money laundering.

  • Regulatory Breaches: Any violation of financial services laws, regulations, or VARA rules.

  • Unethical Behavior: Including conflicts of interest, harassment, or a breach of our internal code of conduct.

  • Health and Safety Dangers: Any action that endangers the health or safety of our employees or the community.

  • Concealment: Any attempt to cover up any of the above-mentioned activities.

This policy is not intended for general customer service complaints or inquiries about business operations.

How to Make a Report

We encourage you to raise your concerns through the appropriate channels. Reports should be made in good faith and with as much specific detail as possible to facilitate a thorough investigation.

Concerns can be reported directly to our Chief Compliance Officer (CCO) via the following secure and confidential email address:

Email: [email protected]

Confidentiality and Protection Against Retaliation

MANTRA Finance is committed to protecting whistleblowers.

  • Confidentiality: All reports will be treated with the strictest confidence. Your identity will be protected to the fullest extent possible, consistent with the need to conduct a fair and thorough investigation.

  • No Retaliation: We have a zero-tolerance policy for any form of retaliation, harassment, or victimization of anyone who raises a concern in good faith under this policy. Any employee found to have engaged in such conduct will face disciplinary action.

Our Process

Upon receiving a report, the Chief Compliance Officer will:

Acknowledge: Acknowledge receipt of the report within five business days.

  1. Assess: Conduct an initial assessment to determine the credibility and seriousness of the concern.

  2. Investigate: If warranted, an independent and objective investigation will be initiated.

  3. Conclude: Upon completion of the investigation, appropriate action will be taken, which may include reporting to relevant authorities. While we may not be able to disclose the specific outcome due to confidentiality constraints, we will inform you when the matter is concluded.