VOICE YOUR CONCERNS

At Bridgehaven Europe Specialty DAC (“The Company” or “Bridgehaven”), we are stronger together. We lean on our strong values and principles. We treat each other with respect, we act with integrity, are transparent and tell the truth.

We give the highest priority to compliance with legal requirements and internal regulations. Bridgehaven encourages the reporting of suspected wrongdoings at the earliest opportunity so that concerns can be appropriately assessed, investigated and addressed. Early detection of wrongdoing helps protect customers, employees, business partners and the Company itself.

You are protected by law where you report certain matters, including but not limited to;

  • Criminal offences (including fraud)
  • Breaches of Company policies where they may constitute wrongdoing
  • Risks to the health and safety of individuals
  • Damage or risks of damage to the environment
  • A miscarriage of justice
  • The company is breaking the law
  • Abuse of authority or serious misconduct
  • Failure to comply with legal regulatory obligations
  • Unethical conduct that could adversely affect customers, employees, business partners or the Company
  • Attempts to conceal any of the above wrongdoings

If you are unsure whether something should be raised, contact the Head of Compliance.

If you have information about an act of wrongdoing or violation of rules at Bridgehaven, you can report your concern via the following channels verbally or in writing: –

  1. Your manager
  2. By email: [email protected]
  3. By writing to the Head of  Compliance, Bridgehaven Europe Specialty DAC, Merrion Hall, Strand Road, Sandymount, Dublin 4
  4. The Central Bank of Ireland (CBI) for concerns relating to breaches of financial services legislation or regulatory requirements
  • Email: [email protected]
  • Phone: 1800 130 014 during office hours
  • Write to: Protected Disclosure Desk, Central Bank of Ireland, PO Box 559, Dublin 1
  1. The Garda Síochána for disclosures relating to suspected criminal conduct

Under the Individual Accountability Regime and the Conduct Standards thereunder, staff of the Company who perform a CF or PCF role have an obligation to promptly disclose to management any information relevant to, or giving rise to a suspicion of, the commission of an offence.

A copy of the Company’s whistleblowing policy is available on request from the Head of Compliance.

Bridgehaven is committed to handling all protected disclosures in a confidential and sensitive manner. The identity of the reporting person and any individuals referred to in a disclosure will be protected to the fullest extent possible and information will only be shared with those who need to know in order to assess, investigate or address the matter.

To enable an effective assessment and investigation, individuals should provide as much information as possible when making a disclosure. However, the absence of detailed information should not deter an individual from raising a concern.

The Company will confirm receipt of a disclosure within seven days.

Reports may be submitted on a named or anonymous basis. While individuals are encouraged to provide contact details to facilitate follow-up enquiries and feedback, anonymous disclosures will also be considered and investigated where sufficient information is available.

The investigation may need to be carried out under terms of strict confidentiality, i.e. by not informing the subject of the complaint until (or if) it becomes necessary to do so.

Depending on the nature of the disclosure, the matters raised may:

  • be investigated by management, internal audit, compliance or through the disciplinary/grievance process
  • be referred to the Garda Síochána

The amount of contact between you and the person considering the issues will depend on the nature of the matters raised, the potential difficulties involved and the clarity of your information. The person making the disclosure may be contacted for further information where necessary to fully understand and investigate the disclosure.

Bridgehaven will take reasonable steps to support individuals who raise concerns and to minimise any difficulties arising from making a protected disclosure. For instance, if you are asked to give evidence in criminal or disciplinary proceedings, Bridgehaven will arrange for you to receive appropriate advice and support.

The Company will ensure that all disclosures are appropriately addressed. Unless there are any legal reasons why this cannot be done, you will be kept informed of the progress and outcome of any investigation.

The Company prohibits any form of penalisation, retaliation or detrimental treatment against an individual who makes a protected disclosure in accordance with this Policy. This remains the case even in cases where an investigation does not confirm the allegations made.