Whistleblower Policy
Last Updated: 10 November 2025
PAA Capital Group (“PAA Capital”, “we”, “us”) is committed to conducting business with integrity, transparency, and accountability.
We encourage employees, contractors, suppliers, clients, and partners to report concerns in good faith — safely and without fear of retaliation.
This Whistleblower Policy describes how you can report a concern confidentially or anonymously, how your report will be handled, and what protections you have under applicable law.
1. What You Can Report
You may report concerns relating to:
Financial integrity
Fraud
Accounting irregularities
Misuse of company assets
AML/CFT breaches
Sanctions violations
Corruption & conflicts
Bribery or improper gifts
Conflicts of interest
Abuse of authority
Data protection & cybersecurity
Data breaches
Improper handling of personal data
Information-security incidents
Regulatory or legal violations
Serious breaches of EU law
Violations of internal compliance policies
Misconduct involving suppliers or partners
Health, safety, and environment
Unsafe practices
Environmental risks or violations
If you are unsure whether something qualifies, we encourage you to report it anyway. Good-faith reports are always protected.
2. How to Report a Concern (Preferred Method)
✅ Encrypted Whistleblowing Portal
Fully encrypted and hosted independently
Anonymous reporting supported
No IP logging
You will receive a case code to follow up on your report
We acknowledge reports within 48 hours
We aim to provide an initial update within 7 days
This is the safest and most confidential way to report concerns.
3. Alternative Internal Reporting Channels
If you prefer not to use the encrypted portal, you can also report through:
Email (identified reporting):
privacy[@]paacapital.com
(Only the internal Compliance function has access.)
Support Ticket (secure submission):
https://support.paacapital.com/help/3551397395
Postal Mail
PAA CAPITAL GROUP
Ludwigsplatz 5
67547 Worms, Germany
or
PAA CAPITAL (PTY) LTD
Western Commercial Road, The Hub, i-Towers
Gaborone CBD, Botswana
Please mark correspondence clearly as “Confidential — Whistleblower Report”.
4. Confidentiality & Data Protection
We treat all reports with strict confidentiality.
Your identity (if provided) is protected and only disclosed when legally required or with your consent.
Access to reports is restricted to designated Compliance personnel.
Personal data is processed in line with GDPR and other applicable regulations.
Anonymous reporting is fully supported and respected.
5. Protection Against Retaliation
PAA Capital strictly prohibits any form of retaliation against whistleblowers.
This includes:
Dismissal or demotion
Discrimination or unfair treatment
Threats, intimidation, or harassment
Negative changes in duties or benefits
Retaliation will result in disciplinary measures, up to and including termination of employment or contract.
If you experience retaliation, report it immediately via the whistleblowing channels.
6. External Reporting Options
You may also report directly to a competent authority in your EU Member State or home jurisdiction, especially if:
Internal reporting is not appropriate
You believe evidence may be concealed
You fear retaliation
Your report was not handled properly
You are protected whether you choose internal or external reporting.
7. Good-Faith Reporting
You are protected when reporting in good faith, even if the concern later proves unfounded.
Knowingly submitting false or malicious reports is prohibited and may lead to disciplinary action.