Governance & Compliance

Whistleblowing Channel

A confidential channel for reporting suspected misconduct, fraud, bribery, or breaches of law, regulation, or the ERAM Invest Code of Conduct. All reports are treated with strict confidentiality and legal protection for the reporter.

Purpose & Scope

Our Commitment to Ethical Conduct

ERAM Invest is committed to the highest standards of integrity, transparency, and legal compliance. We operate in regulated financial services markets across the Western Balkans and CEE, where trust and ethical conduct are the foundation of every client relationship and capital partnership.

This whistleblowing channel enables employees, clients, counterparties, suppliers, investors, and any third party to report concerns about suspected wrongdoing in connection with ERAM Invest or its representatives. The channel complies with the Republic of Kosovo Law No. 06/L-085 on Protection of Whistleblowers and with applicable EU directives on the protection of persons reporting breaches of Union law.

Legal Basis

Law No. 06/L-085 on Protection of Whistleblowers (Republic of Kosovo) · EU Directive 2019/1937 on the protection of persons who report breaches of Union law · ERAM Invest Code of Conduct.

Reportable Matters

Concerns that may be reported through this channel include, but are not limited to:

Fraud & Financial Misconduct

Accounting irregularities, misrepresentation of financial information, misappropriation of funds or assets, or fraudulent reporting.

Corruption & Bribery

Offering, giving, receiving, or soliciting improper payments or benefits, including facilitation payments in violation of anti-corruption law.

Money Laundering

Transactions or arrangements suspected of concealing the origin of illicit proceeds, or breaches of AML / CFT obligations.

Sanctions Breaches

Engagement with sanctioned entities or jurisdictions in violation of EU, UN, US OFAC, or UK sanctions regimes.

Conflicts of Interest

Undisclosed personal, financial, or professional interests that could compromise the independence or judgment of an ERAM representative.

Data Protection Violations

Unauthorised disclosure, misuse, or loss of personal data or confidential client information.

Harassment & Discrimination

Workplace harassment, discrimination, bullying, or retaliation against employees or partners.

Regulatory Breaches

Non-compliance with financial services regulation, tax obligations, or any applicable law in the jurisdictions where ERAM Invest operates.

Reporting Channels

How to Submit a Report

You may submit a report through any of the channels below. You may choose to identify yourself or submit the report anonymously. All submissions are received directly by ERAM Invest’s designated Compliance Officer.

Channel 1

Secure Online Form

Use the confidential reporting form below. Submissions are encrypted in transit and delivered only to the Compliance Officer.

Scroll to form ↓

Channel 2

Confidential Email

Send a detailed report directly to the Compliance Officer. Attachments are accepted.

[email protected]

Channel 3

Postal Mail

Marked “CONFIDENTIAL – Compliance Officer”. Opened only by the designated officer.

ERAM Invest
Attn: Compliance Officer
Rr. Agim Ramadani, Pristina
Republic of Kosovo

Channel 4

External Authority

You may also report directly to the competent Kosovo authority, the Agency for Prevention of Corruption, or the relevant regulator.

Agency for Prevention of Corruption →

Legal Protection

Protection of the Whistleblower

Any person who makes a report in good faith through the channels described above is entitled to the full protection of applicable Kosovo and EU whistleblower protection law. ERAM Invest strictly prohibits any form of retaliation, discrimination, or adverse treatment against a whistleblower.

Confidentiality

Your identity, and any information that could reveal it, will not be disclosed to anyone beyond those strictly involved in receiving or investigating the report — unless disclosure is required by law, court order, or with your explicit written consent.

Anonymity

You may submit a report without disclosing your identity. Anonymous reports are investigated on the same basis as identified reports, provided the information is sufficient to enable investigation.

No Retaliation

Any form of retaliation — including dismissal, demotion, harassment, exclusion, or any other adverse action — against a whistleblower acting in good faith is strictly prohibited and will itself be treated as a serious breach of the Code of Conduct.

Legal Immunity

A whistleblower acting in good faith is protected from civil, criminal, and administrative liability arising from the report, in accordance with Law No. 06/L-085.

Support & Remedies

If you believe you have suffered retaliation, you may contact the Compliance Officer directly or file a complaint with the competent Kosovo authority. Remedies include reinstatement, compensation, and sanctions against the retaliating party.

Good Faith

Protection applies to reports made in good faith — meaning you have reasonable grounds to believe the information reported is true at the time of reporting. Knowingly false or malicious reports are not protected and may be subject to disciplinary or legal action.

Investigation Process

What Happens After You Report

01

Acknowledgement

Within 7 days of receipt, we acknowledge your report (if contact details are provided) and assign a confidential case reference.

02

Initial Assessment

Within 30 days, the Compliance Officer conducts an initial assessment to determine the credibility and scope of the concern.

03

Investigation

If warranted, a formal investigation is conducted by the Compliance Officer or an external independent investigator. Witnesses may be interviewed under confidentiality.

04

Outcome & Feedback

Within 3 months of acknowledgement, you receive feedback on the outcome to the extent permitted by law and confidentiality obligations.

If you submit anonymously and provide no return channel, you will not receive individual feedback, but your report will still be fully investigated. We recommend maintaining an anonymous contact method (e.g. a dedicated anonymous email address) if you wish to receive updates.

Submit a Report

Confidential Report Form

Use the form below to submit a report. You may provide your contact details or submit anonymously. Reports are received only by the designated Compliance Officer.

Before you submit: please be as specific as possible — include dates, parties involved, locations, and any supporting evidence. You may attach documents if the form supports attachments. Submissions are encrypted in transit.

    Before submitting: all reports are received only by the designated Compliance Officer. You may submit anonymously. Please be as specific as possible.


    Contact details are used solely to acknowledge the report and request clarification. They are not disclosed to anyone beyond the Compliance Officer.

    Nature of the Concern

    Max 10 MB. Documents, emails, photos, spreadsheets.

    Whistleblowers acting in good faith are legally protected under Kosovo Law No. 06/L-085. Retaliation is strictly prohibited. See the full Whistleblowing Policy.

    By submitting this form, you acknowledge that you have read and understood this Whistleblowing Policy. ERAM Invest processes personal data submitted through this form solely for the purpose of investigating the reported concern, in accordance with our Privacy Policy and applicable data protection law.

    Policy Owner

    Compliance Officer
    ERAM Invest

    Last Review

    April 2026

    Next Review

    April 2027