Whistleblowing

Report Misconduct / Whistleblowing

Quintet wishes to create and foster a corporate culture marked by honesty, transparency and openness. Quintet wants to encourage everyone to report financial criminal activities and breaches of any legal, regulatory, external or internal requirements linked to Quintet.

Employees as well as non-employees[1] who are in contact with Quintet Private Bank Group in the context of their work-related activities (e.g. contractors and suppliers), should all have the opportunity to report potential wrongdoing at the earliest possible stage.

Employees are encouraged to speak up any specific concerns with line management first, before raising concerns through other escalation channels.

[1] “Non-employees” include any person whose employment contract hast not started or has ended, self-employed persons, volunteers and trainees, contractors, subcontractors, suppliers and facilitators.

Our communication channels

Quintet Employees are encouraged to reach out to the point of contacts set out in the List of Designated Contacts for Whistleblowers, available in Quintet Intranet.
If non-employees wish to report any misconduct, they can do so by submitting their report to the following email-address: whistle.blowing@quintet.com

We value open communication and would like to encourage also non-employees to submit their report using their name. This will help us to communicate with them and if necessary, request further information we may need. Such report will always be handled strictly confidential and Quintet will respect the legitimate interests of all parties involved up to the extent possible by law.

The whistleblower may report anonymously, although as a general matter, the whistleblower should, if possible, identify himself/herself and Quintet will protect his/her identity. Any anonymous reporting can be submitted by mail to the Compliance Department of one of the below mentioned Quintet entities. Non-Employees located in Denmark are invited to submit their whistleblowing report to the Compliance Department in Luxembourg.

Quintet Private Bank (Europe) S.A. @Whistleblowing Compliance	43 boulevard Royal, L-2449 Luxemburg
Puilaetco, A Quintet Private Bank @Whistleblowing Compliance	Bd du Souverain 25 Vorstlaan, bte/bus 14, BRUXELLES 1170 BRUSSEL
MERCK FINCK, A QUINTET PRIVATE BANK (EUROPE) S.A. branch @Whistleblowing Compliance	Pacellistraβe 16, 80333 München
InsingerGilissen, A Quintet Private Bank @Whistleblowing Compliance	Herengracht 537, 1017 BV Amsterdam.

Reporting to local and EU regulators: As per European Union rules, whistleblowers have the possibility to directly report their suspicions of potential or actual breaches to the local or European regulators. Local regulators’ websites provide additional information regarding their own whistleblowing procedures. Such external reporting channels are listed at the bottom of this document.

The CSSF supervising Quintet together with the ECB, has established a whistleblowing line via its website and published an user guide ‘Reporting Breaches of Breaches of financial sector regulations to CSSF’ .

This Q&A states that the CSSF’s whistleblowing procedure is to be used by those who have “reasonable grounds for believing that the report will show breaches of applicable regulation by entities or persons of the financial sector which fall under the supervision of the CSSF”.

It also clarifies that “The whistleblowing procedure should however not be used for breaches which are clearly of a criminal nature”.

Finally, the CSSF is clear in that “before contacting the CSSF, employees of entities of the financial sector are requested to first use the whistleblowing procedures in their workplace, if there are any”.

Whistleblowing topics

The reportable matters covered by the whistleblower scheme cover, in particular:

Any reasonable suspicion that another staff member might be guilty of fraud, gross malpractice, gross negligence or any other behaviour likely to harm the Bank’s reputation or financial well-being.
Infringements of external rules, including any breach of applicable regulations or laws.
Any legitimate concern about internal governance, including material breaches of policies or procedures.
Any violations (acts or omissions) that are unlawful or defeat the object or purpose of the applicable provisions of national or European law.

This applies to any regulatory offences, not just financial crime offences.

For any complaint, please contact the BRM department, which is intended specifically to support you.

Reportable matters also include any so-called protected disclosures made in the public interest under the Employment Rights Act 1996 (ERA) in the UK as well as disclosures made according to the Allgemeine Gleichbehandlungsgesetz (AGG) in Germany.

Processing of alerts

Whistleblowers concerns are treated in confidence by a dedicated investigator.

The investigator is subject to strict ethical rules and ensures that each reported allegation is treated confidentially, objectively and fairly. Any investigation that is being carried out due to a reported concern will be answered within a reasonable time provided the report was not made anonymously.

Where appropriate, e.g. when there is a possible conflict of interest, the seniority or position of the subject of the report requires it, or the independence of an internal or local investigator might be otherwise compromised), recourse may be made to an external party to conduct the investigation.

Reported concerns are recorded in a Whistleblowing register held by Quintet Group Compliance with restricted access and subject to strict recordkeeping and data governance rules.

External reporting channels:

Quintet entity	Local regulator	Phone number	Website
Quintet Private Bank, Luxembourg External whistleblowing reporting channel	Commission de Surveillance du Secteur Financier 283, route d’Arlon, L-2991 Luxembourg	+352 26 25 1 - 1	WHISTLEBLOWING (cssf.lu)
Quintet Danmark Private Bank, Danmark External whistleblowing reporting channel	Financial Supervisory Authority Finanstilsynet, Strandgade 29 1401 København K		Whistleblower (dfsa.dk)
Puilaetco, Belgium External whistleblowing reporting channel	FSMA – External whistleblowers’ point of contact	N/A	https://www.fsma.be/en/whistleblowing
Merck Finck, Germany External whistleblowing reporting channel	Bundesanstalt für Finanzaufsicht (BaFin) Hinweisgeberstelle Graurheindorfer Straße 108, Bonn 53117	+49 0228 4108 2355	Hinweisgeberstelle der BaFin
InsingerGilissen,Netherlands External whistleblowing reporting channel	the Netherlands Authority for Consumers and Markets (ACM), the Netherlands Authority for the Financial Markets (AFM), the Netherlands Data Protection Authority (AP), the Dutch Central Bank (DNB), the House for Whistleblowers, the Inspectorate for Health and Youth Care (IGJ), the Dutch Healthcare Authority (NZa).