Responsible Disclosure of Information

This disclosure procedure is supplemental to any agreements, terms of business or other documentation you may have in place with any Hidden Road entity (including, but not limited to Hidden Road Partners CIV UK Ltd, Hidden Road Partners CIV (BVI) Limited, Hidden Road Partners CIV NL B.V., Hidden Road Partners CIV SG Pte. Ltd. Hidden Road Partners CIV US OTC LLC, and Hidden Road Partners CIV US LLC (collectively “Hidden Road”, “us”)) and may be amended or supplemented by additional disclosures from time to time and are intended for use by professional clients and eligible counterparties. Defined terms used but not defined herein have the meanings ascribed to them in the Terms of Business which are provided to you before we provide any service to you. 

Hidden Road recognizes the importance of our conduct as well as compliance with all relevant rules and regulations relevant to our entities and business. We value any information or documentation perceived as adverse that pertains to any of our entities, operations, employees, or other business practices. Hidden Road has therefore developed a Responsible Disclosure of Information process (“RDI”) outlining how individuals can disclose information and/or documentation to Hidden Road. This process is commonly referred to as “whistle blowing” and is available to use by everyone inclined to do so.

Contacting Us

Should you wish to disclose any information or documentation for the purpose of responsible disclosure you can make use of the following methods: 

Email

• responsibledisclosure@hiddenroad.com

Telephone

• Hidden Road New York: +1.646.854.3064

When making use of telephone, please make sure to request to speak directly to the Whistleblowing Officer. When you reach a voicemail, explicitly mention that you would like to speak to the Whistleblowing Officer, and leave a phone number or email address.

Our process

Hidden Road has appointed a global Whistleblowing Officer that oversees the Responsible Disclosure of Information process and is responsible for the handling of information disclosed to Hidden Road under this process. 

Upon receipt of the disclosed information, the Whistleblowing Officer of Hidden Road will handle the obtained information in accordance with our policies and procedures. 

Please note the following important points when making use of the opportunity for responsible disclosure of information: 

• You do not have an obligation to disclose your identity when disclosing information to us.
• As part of this process, your identity will not be disclosed, unless with your explicit consent or unless Hidden Road is legally required to do so.
• You will not be the subject of retaliation or litigation as a result of your disclosure of information.
• Your information and any subsequent actions that stem from the information will be treated confidentially.
• Hidden Road does not have any obligation to disclose the usage and/or outcome of any information provided to us under the RDI process unless explicitly instructed to do so by relevant competent authorities.
• Hidden Road will not provide feedback on any information provided to us as part of the RDI process.