Disclaimer

The contents of this website are for information purposes only. The information on this website does not constitute an offer or solicitation to invest. Additionally, no information constitutes a concrete investment recommendation or service. Access to the products and funds mentioned on this website shall not be granted to persons who are nationals of, or domiciled in, countries where local law or regulations forbid access to such information. The same shall apply to the prospectuses of these products. The information contained in this document is protected by intellectual property rights that are owned by Insitor Management PTE Ltd and any associated or affiliated company.

External Complaints and Reports Policy

Reporting

​Insitor strives to ensure that safe, appropriate, and accessible means of reporting safeguarding concerns as well as other general complaints are made available to staff, the communities that our portfolio companies work with and the general public/other parties.

Any staff or external sources reporting concerns or complaints through formal grievance mechanism/whistleblowing channels will be protected by our Fund's Whistleblowing Policy (above).

Complaints and reports can be made in writing by emailing: whistleblower@insitormanagement.com

Please ensure that your report or complaint includes the following information:

  1. Your name and contact details

  2. Identification of our Funds' investee company to which the report or complaint relates

  3. Information regarding the misconduct or malpractice

  4. Information regarding any harm caused by the alleged misconduct or malpractice, provided in as much detail as possible

  5. Information on any steps taken prior to this report or complaint to address the alleged misconduct, malpractice or harm

  6. Whether your identity should be kept confidential

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Response

​Insitor will follow up complaints/safeguarding reports and concerns according to policy and procedure, and legal and statutory obligations. Insitor will offer support to survivors of harm caused by staff or associated personnel, regardless of whether a formal internal response is carried out (such as an internal investigation).

Involved parties will be informed about the nature of the complaint as well as response (and may be involved in formulating the response).

Confidentiality

Grievance processes will be dealt with in confidence and no person will be victimised and/or discriminated against for utilising the grievance procedure, ensuring confidentiality at all stages of the process. Information relating to the concern and subsequent case management will be shared on a need-to-know basis only, and kept secure at all times.

Bribery and Corruption Policy

The Insitor Impact Asia Fund (IIAF) and Insitor Impact Asia Fund II (IIAF II) are committed to complying with all applicable laws and best corporate governance practices, wherever we operate. It is a core aspect of our mission to act with integrity in all of our operations. The Board of Directors of IIAF/IIAF II and the Manager of IIAF/IIAF II expect all employees & Staff to comply with both the letter and spirit of the law and governance codes.

  • IIAF/IIAF II and their Manager affirm that they will not pay or procure the payment of a bribe or unlawful fee to encourage the proper performance of a task or one which is intended or likely to compromise the integrity of another. We will not accept any payment, gift or inducement from a third party, which is intended to compromise our own integrity.

  • IIAF/IIAF II and their Manager have communicated this policy to all its employees, to ensure that its commitment to integrity and legal compliance is followed.

  • When contracting with a third party, including companies in whom we are considering an investment, we will insist that they acknowledge our commitment to good and adopt appropriate anti-bribery policies.

  • Any person who believes that IIAF, IIAF II, their Manager, or any of its staff are involved in bribery and corruption is encouraged to report their concerns to whistleblower@insitormanagement .com

Insitor Whistleblower Policy

The Principles

  • ​IIAF/IIAF II welcomes whistleblower reports and encourages staff to draw to its attention instances of corporate wrong-doing within the Insitor group of companies [as defined below a “Protected Disclosure”];
    IIAF/IIAF II will require that every business in which the capital of IIAF/IIAF II is invested adopt and implement whistleblower policies in accordance with local laws and international best practices.
    IIAF/IIAF II regards attempts to victimize or discriminate against a whistleblower as potentially gross misconduct.

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Raising a Concern

Individuals may raise a Protected Disclosures (as defined below) in writing to the responsible officer with the issues clearly and unambiguously set out. The whistleblower should identify themselves in the disclosure. 


“Protected Disclosure” is defined as a reasonably held concern that:

  • A criminal offence has been committed, is being committed or is likely to be committed;

  • A person has failed, is failing or is likely to fail to comply with any legal obligation to which he or she is subject;

  • A miscarriage of justice has occurred, is occurring or is likely to occur;

  • The health and safety of any individual has been, or is being or is likely to be endangered;

  • The environment has been, is being or is likely to be damaged;

  • Information tending to show any matter falling within any one of the preceding paragraphs has been, is being or is likely to be deliberately concealed; and

  • A concern raised in good faith that discloses or demonstrates information that may evidence serious unethical or improper activity within IIAF/IIAF II (or a company in its group) and its and their business practices.

  • All whistleblowing disclosures made to the IIAF/IIAF II Compliance Officer will be treated as confidential. The whistleblower should make it clear that they are making their disclosure within the terms of the firm’s Whistleblowing Policy. This will ensure the recipient of the Protected Disclosure realizes this and takes the necessary action to investigate the disclosure and to protect the whistleblower’s identity. 

  • IIAF/IIAF II welcomes third-party whistleblower reports. These may concern the conduct of its own staff or a portfolio company. All third-party whistleblower reports should be addressed to: whistleblower@insitormanagement.com.

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Protection

IIAF/IIAF II condemns any kind of discrimination, harassment or victimization of a whistleblower. IIAF/IIAF II will ensure that:

  • The identity of a whistleblower is kept confidential and only disclosed on a need to know basis;

  • Papers relating to a Protected Disclosure or a third-party whistleblower report are filed carefully away;

  • Instances of victimization of a person making a Protected Disclosure are treated as a serious matter which may give rise to disciplinary action by IIAF/IIAF II against any person(s) causing or allowing such victimization.