Our Commitment to Ethical Conduct
Guarant Reinsurance Limited, a wholly-owned subsidiary of Amberstone Capital Group SPC (regulated by the BVI Financial Services Commission), is committed to maintaining the highest standards of integrity, transparency, and ethical conduct in all aspects of its business operations. We recognise that employees, contractors, business partners, and other stakeholders may become aware of activities that raise serious concerns about wrongdoing, regulatory non-compliance, or unethical behaviour within the organisation.
This Whistleblowing Policy provides a confidential, secure, and clearly defined mechanism for reporting such concerns without fear of retaliation, victimisation, or adverse consequences. The policy aligns with applicable Turks & Caicos Islands legislation, international best practice frameworks, and the regulatory expectations of the TCI Financial Services Commission (TCIFSC).
Who Can Report
This policy applies to all individuals who have a legitimate concern about suspected wrongdoing within or connected to GUARANT's operations. Eligible reporters include:
Employees & Officers
All current employees, directors, officers, and members of senior management, regardless of position, tenure, or employment status (permanent, temporary, or probationary).
Contractors & Consultants
External service providers, consultants, auditors, legal advisors, and technology partners who perform work for or on behalf of GUARANT in any capacity.
Business Partners
Cedents, brokers, reinsurance intermediaries, counterparties, and other business partners who become aware of concerns related to GUARANT's operations or conduct.
What Can Be Reported
Whistleblowing reports should concern serious matters that affect the integrity of GUARANT's operations, the safety of individuals, or compliance with applicable laws and regulations. Reportable concerns include, but are not limited to:
Financial & Regulatory
- Fraud, embezzlement, or misappropriation of assets
- Deliberate misstatement of financial records or accounts
- Breaches of insurance or reinsurance regulations
- Non-compliance with TCIFSC directives or conditions
- Money laundering or terrorist financing
- Tax evasion or sanctions violations
Conduct & Safety
- Bribery, corruption, or improper inducements
- Conflicts of interest not properly disclosed
- Harassment, discrimination, or workplace bullying
- Threats to health and safety
- Environmental damage or negligence
- Deliberate concealment of any of the above
How to Report
GUARANT provides multiple confidential reporting channels to ensure accessibility and discretion. Reporters may choose the channel that best suits their circumstances.
Designated Email
compliance@guarantre.com
Reports submitted to this dedicated email address are received directly by the Compliance Officer and are treated as strictly confidential. Use a clear subject line such as "Whistleblowing Report - Confidential" to ensure proper handling and priority classification.
Written Report
Compliance Officer, Guarant Reinsurance Limited
Written reports may be submitted by post, marked "Private & Confidential — Whistleblowing Report" on the envelope. Reports should include as much factual detail as possible: dates, names, locations, documents, and any evidence supporting the concern.
Board-Level Escalation
Chair of the Audit Committee or Board of Directors
Where the concern involves the Compliance Officer or senior management, reports may be directed to the Chair of the Audit Committee or the Chair of the Board of Directors. Contact details for escalation are available upon request from any board member.
External Regulatory Channel
TCI Financial Services Commission (TCIFSC)
If the reporter believes that internal channels are compromised, inadequate, or that the matter has not been appropriately addressed, they may report directly to the TCIFSC as the primary regulatory authority overseeing GUARANT's operations.
Protections for Whistleblowers
GUARANT takes the protection of whistleblowers seriously. The following safeguards apply to all individuals who make a report in good faith:
Confidentiality
The identity of the reporter is treated as strictly confidential and will not be disclosed without the reporter's express consent, except where required by law or regulatory obligation. All records related to whistleblowing reports are stored securely with restricted access.
Non-Retaliation
No individual who makes a report in good faith will be subjected to retaliation, victimisation, disciplinary action, dismissal, demotion, or any other adverse treatment as a consequence of raising a concern. Any person found to have retaliated against a whistleblower will face disciplinary proceedings.
Anonymous Reporting
GUARANT accepts anonymous reports, although providing contact information enables a more thorough investigation and allows feedback to be communicated. Anonymous reports will be investigated to the extent possible based on the information provided.
Fair Process
All reports are assessed objectively, thoroughly, and impartially. Individuals who are the subject of a report are afforded due process and a fair opportunity to respond before any conclusions are drawn or actions taken.
Investigation Process
Receipt & Acknowledgment
Reports are acknowledged within 5 business days. The Compliance Officer conducts a preliminary review to determine whether the matter falls within the scope of this policy.
Assessment
The nature and severity of the concern is assessed to determine the appropriate investigation approach, resources required, and whether external expertise or regulatory notification is warranted.
Investigation
A thorough, impartial investigation is conducted by qualified personnel. The investigation may involve document review, interviews, forensic analysis, and consultation with legal counsel or external specialists.
Resolution & Reporting
Findings are documented and appropriate remedial action is taken. The reporter receives feedback on the outcome to the extent permitted by confidentiality obligations. The Board is informed of all substantiated findings.
Governance & Oversight
The Whistleblowing Policy is owned by the Compliance Officer and overseen by the Audit Committee of the Board of Directors. The Audit Committee receives regular reports on whistleblowing activity, investigation outcomes, and any systemic issues identified through the reporting process.
The policy is reviewed annually and updated as necessary to reflect changes in applicable legislation, regulatory guidance, and organisational best practice. All employees receive training on the policy during onboarding and through periodic refresher programmes.
Key Principles
- Good faith reporting is always encouraged
- No tolerance for retaliation in any form
- Proportionate and impartial investigation
- Confidentiality preserved at every stage
- Board-level oversight and accountability
- Alignment with TCIFSC regulatory expectations
- Regular review and continuous improvement