Whistleblowing Policy

Scope of reportable concerns

The following categories of concern may be reported under this policy:

• Breaches or potential breaches of applicable laws and regulations, including financial services legislation, anti-money laundering requirements, and data protection obligations.
• Suspected fraud, financial irregularities, or misappropriation of assets.
• Market manipulation, insider dealing, or other violations of market integrity requirements.
• Bribery, corruption, or conflicts of interest that have not been properly disclosed or managed.
• Breaches of internal policies, codes of conduct, or professional standards.
• Actions or omissions that create a risk of harm to clients, counterparties, or the broader financial system.

How to make a report

Concerns may be reported through the following channels. Internal reporting: reports may be submitted directly to the Compliance Officer or to the designated Whistleblowing Officer at StoneX Luxembourg. Written reports may be submitted by post to our registered office at Bâtiment Espace Strassen, 5, rue des Primeurs, L-2361 Luxembourg, marked strictly confidential and addressed to the Compliance Department. External reporting: where a reporter does not wish to report internally, or where internal reporting is not considered appropriate, concerns may be reported directly to the relevant Luxembourg supervisory or regulatory authority, or to the applicable European supervisory authority. Reports may be submitted anonymously where the reporter prefers. StoneX Luxembourg will investigate all reports submitted in good faith thoroughly, promptly, and with full confidentiality.

Protection of whistleblowers

StoneX Luxembourg strictly prohibits any form of retaliation, victimization, or detrimental treatment against any person who reports a concern in good faith under this policy, whether or not the concern ultimately proves to be substantiated. Any confirmed act of retaliation against a whistleblower will be treated as a serious disciplinary matter and may result in termination of employment or other appropriate sanctions. The identity of any reporter will be protected to the fullest extent possible under applicable law and will be disclosed only where required by law or judicial order, or with the explicit consent of the reporter.

Investigation and follow-up

All reports received will be assessed promptly by the designated Whistleblowing Officer, who will determine the appropriate investigation procedure based on the nature and severity of the concern raised. Where a formal investigation is initiated, the reporter will be kept informed of the progress and outcome of that investigation to the extent consistent with legal, regulatory, and confidentiality obligations.