Complaints, Grievances and Reporting Misconduct 

XSML's Commitment
XSML Capital is committed to conducting its activities with integrity, transparency, and accountability. We have zero-tolerance for illegal, unethical or improper conduct and expect the same standards from those who work with or on behalf of XSML.  

We encourage employees, portfolio companies, suppliers, contractors, consultants, clients, investors, affected communities and other stakeholders to raise concerns whenever they believe conduct may be inconsistent with our policies, applicable laws, contractual obligations or internationally recognized standards.

Prohibited Practices
Examples of prohibited practices include, but are not limited to 

• Fraud;

• Corruption and bribery;

• Collusion and anti-competitive conduct;

• Coercion, intimidation and retaliation;

• Money laundering and terrorist financing;

• Misuse of assets or funds;

• Undisclosed or unmanaged conflicts of interest;

• Harassment, discrimination, Gender-Based Violence and Harassment (GBVH), and Sexual Exploitation, Abuse and Harassment (SEAH);

• Retaliation against whistleblowers and witnesses

• Obstruction  

Violations may result in disciplinary action, termination of employment or contractual relationships, withdrawal of financing, referral to regulatory or law-enforcement authorities, legal action, or other corrective measures as appropriate. 

What Can Be Reported?
Reports and complaints may be submitted where a stakeholder has a concern that XSML, a portfolio company, or another party acting in connection with XSML-financed activities may have engaged in conduct that is inconsistent with XSML's policies, applicable laws, contractual obligations or internationally recognised standards. 

The mechanism also covers concerns relating to environmental or social impacts, breaches of the XSML Code of Conduct, or other conduct that may cause harm or otherwise undermine XSML's commitments and standards. 

You do not need to be certain that a violation has occurred to raise a concern. Reports may be based on a good-faith concern or reasonable suspicion. These matters are addressed through XSML's Whistleblowing and Complaints Mechanism. 

Who Can Submit a Complaint?
The mechanism is available to: 

• XSLM employees and employees of portfolio companies;

• Suppliers and contractors;

• Consultants and advisers;

• Clients and investors;

• Communities affected by XSML-financed activities; and

• Any other stakeholders. 

Complaints may be submitted anonymously, and complainants may request confidential treatment. 

How to Submit a Complaint?
A complaint or disclosure may be submitted: 

• Through the "Blow a Whistle" reporting form on the XSML website;

• By email to complaints@xsmlcapital.com; 

• Where appropriate, through alternative reporting channels, established for specific investments or projects, (i.e. official-language channels, telephone or in-person reporting options)  

How Complaints Are Handled?
All complaints are recorded in a central complaints register and reviewed in accordance with XSML's Whistleblowing and Complaints Policy. 

The process generally includes: 

• Acknowledgement of receipt within five working days; 

• Assessment of admissibility; 

• Investigation, where appropriate; 

• Periodic updates to the complainant; 

• Communication of findings and outcomes; and 

• An opportunity to request reconsideration and, where appropriate, an independent second-stage review. 

Who Reviews Complaints?
Complaints are managed by XSML's Whistleblower and Complaints Committee (WCC), which is responsible for assessing admissibility, overseeing investigations, and determining appropriate follow-up actions. 

The WCC is supported by the Head of Compliance, who maintains the complaints register and monitors the operation of the complaints mechanism. For external complaints, the WCC may engage the Compliance Officer appointed by the Fund Administrator to provide additional compliance oversight. 

Independence and Conflict of Interest
XSML has established safeguards to promote objective and fair handling of complaints. 

• Committee members with a conflict of interest are excluded from the review and decision-making process; 

• Complainants may request reconsideration and, where applicable, an independent second-stage review by a person or body not involved in the original determination; 

• External legal, technical or other specialist experts may be engaged where appropriate; and 

• Retaliation against complainants or whistleblowers is strictly prohibited. 

Confidentiality and Protection
XSML treats complaints confidentially and seeks to protect complainants and whistleblowers from retaliation, intimidation, coercion or victimisation. Anonymous submissions are accepted, although providing contact information may assist with investigation and follow-up. 

Related Policies
The Complaints Mechanism forms part of  XSML's broader integrity, accountability and governance framework, which includes: 

• Code of Conduct 

• Anti-Bribery and Corruption Policy 

• Anti-Financial Crime Policy 

• Whistleblowing and Complaints Policy 

• ESG Policy 

• Information Disclosure Procedure for GCF-Financed Activities