Whistleblowing
We are committed to conducting our business with honesty and integrity, and we expect everyone at Andreas Capital to maintain high standards in line with our policies and procedures. Every organisation faces the risk of things going wrong, from unethical behaviour to illegal conduct. If you come across such behaviour, we want you to feel safe to raise it.
Whistleblowing is the disclosure of information about suspected wrongdoing.
What you can report
You can report actual or suspected breaches, and attempts to conceal them. This includes the following areas.
- Breaches of financial sector rules, including MiFID, conduct of business, conflicts of interest and client assets
- Money laundering, terrorist financing or sanctions breaches
- Market abuse, meaning insider dealing or market manipulation
- Fraud, bribery and corruption
- Tax offences
- Data protection or IT security breaches
- Breaches of internal policies, weaknesses in internal governance and any other breach of Luxembourg or EU law
How to report
Please report your concern in writing to our Whistleblowing Officer, by email or by post. If you write by email, we recommend putting “strictly confidential” in the subject line.
- By email to whistleblowing@andreas-capital.com
- By post to Andreas Capital S.A., for the attention of the CCO only, 25B, Boulevard Royal, L-2449 Luxembourg
You can also report directly to the CSSF through its whistleblowing portal, for example if you believe your concern has not been properly addressed.
What to include in your report
Everything below is optional, and anonymous reports are accepted.
- Your name and contact details, or “anonymous” with a way to reach you if possible
- Your relationship to the firm, for example employee, contractor or client
- What happened, a description of the suspected breach
- When and where it happened, and whether it is still going on
- Who is involved, by name or function
- How you became aware of it
- Any evidence, such as documents, emails or names of witnesses
- Whether you have reported this elsewhere, and to whom
- Whether you are concerned about retaliation
How we handle your report
Report
You send your report in writing.
Acknowledgement
Within 7 days you receive written confirmation that we have received it.
Investigation
We assess the report and, if it falls within scope, investigate it.
Feedback
Within 3 months of the acknowledgement, we tell you what action has been taken or is planned, and why.
Confidentiality
Your identity is known only to the people handling your report. It is never disclosed without your explicit consent. The only exception is where the law requires disclosure, for example in judicial proceedings. In that case we tell you beforehand, unless doing so would harm those proceedings. We process personal data in line with the GDPR.
Last reviewed: 20 October 2026.