Whistleblower Policy
Purpose
Telvo's Whistleblower Policy provides confidential reporting channels for personnel, vendors, LPs, and counterparties to raise concerns about suspected violations of law, regulation, or Telvo policy without fear of retaliation.
Reporting Channels
Concerns may be reported directly to the Chief Compliance Officer, to the Conflicts Committee, or through the confidential external whistleblower channel maintained by Telvo's independent legal counsel.
Non-Retaliation
Telvo prohibits retaliation against any person who reports a concern in good faith. Retaliation is a separate violation of the Code of Ethics and may result in disciplinary action.
Investigation
All reported concerns are investigated promptly, confidentially, and independently. Findings are reported to the Conflicts Committee and, where material, to the LP Advisory Committee of any affected fund vehicle.
Documentation
Whistleblower reports, investigations, and outcomes are documented and retained in accordance with Telvo's recordkeeping obligations.