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10 August 2023

Complaints, Grievances and Reporting Misconduct

XSML's Commitment
XSML Capital maintains a zero-tolerance approach towards fraud, corruption, bribery, collusion, coercion, money laundering, retaliation against whistleblowers, unethical conduct and other prohibited practices.

We are committed to conducting our activities with integrity, transparency, and accountability. 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 or international standards. 

Prohibited Practices
XSML is committed to conducting all activities in compliance with applicable laws, regulations, contractual obligations, and internationally recognised standards of ethical business conduct. XSML expects all directors, officers, employees, consultants, contractors, suppliers, portfolio companies and other parties acting on its behalf to conduct themselves with integrity, transparency, accountability and professionalism and not to engage in any illegal, unethical or improper conduct. 

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, GBVH and 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 relate to: 

  • Fraud, corruption or bribery;
  • Financial misconduct or misuse of funds; 

  • Money laundering or terrorist financing;

  • Violations of laws, regulations or governance requirements;

  • Conflicts of interest;

  • Environmental or social harm;

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

  • Breaches of the XSML Code of Conduct;

  • Retaliation against whistleblowers or complainants;

  • Other unethical, improper, or prohibited conduct. 

These matters are addressed through XSML's Whistleblowing and Complaints Mechanism.

Who Can Submit a Complaint
The mechanism is available to:

  • Employees; Employees of portfolio companies;
  • Suppliers and contractors;
  • Consultants and advisers;
  • Clients and investors;
  • Communities affected by XSML-financed activities;
  • Any other stakeholders. 

Complaints may be submitted anonymously, and confidential treatment may be requested. 

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, using alternative reporting channels established for specific investments or projects.

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; 

  • Review of admissibility; 

  • Investigation where appropriate; 

  • Periodic updates to the complainant; 

  • Communication of findings and outcomes; 

  • 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 Committee is supported by the Head of Compliance, who maintains the complaints register and monitors the operation of the complaint's 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 Safeguards
XSML has established safeguards designed to promote objective and fair complaint handling. 

  • 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; 

  • 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 following policies form part of XSML's integrity, accountability and governance framework: 

  • Code of Conduct 

  • Statement on Prohibited Practices 

  • Anti-Bribery and Corruption Policy 

  • Anti-Financial Crime Policy 

  • Whistleblowing and Complaints Policy 

  • ESG Policy 

  • Information Disclosure Procedure for GCF-Financed Activities 

Complaints form