Speak Up and Whistleblowing Policy

TD & Partners Global encourages everyone to speak up about wrongdoing. We want to know about concerns so we can address them, and we protect those who raise concerns in good faith from retaliation.

This policy applies to our partners, employees, contractors, and others acting on our behalf. We also provide routes for clients, suppliers and others to raise concerns.

You should report any suspected wrongdoing, including breaches of our Code of Conduct, bribery and corruption, fraud, conflicts of interest, unsafe practices, harm to people, or other unethical or unlawful conduct.

You can raise concerns with your manager, a senior leader, or through the channels set out in our LegalConfiguration record. We provide a route to raise concerns confidentially, and where reasonably practicable, anonymously. We treat reports sensitively.

We investigate reports promptly, fairly and as confidentially as practicable. We inform the person who raised the concern of progress where appropriate, and we act on findings.

We do not tolerate retaliation against anyone who raises a concern in good faith. Raising a concern in good faith means you honestly believe what you report, even if it turns out to be mistaken. Deliberately false reports are not protected.

We protect the identity of those who raise concerns where reasonably practicable, and we limit information sharing to those who need it to investigate. We ask those raising concerns to help maintain confidentiality.

Nothing in this policy prevents anyone from reporting concerns to a competent authority where the law permits or requires it. We support the right to do so.

We review this policy regularly. The effective date and version are shown on the policy page.