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General policy: The purpose of this document is to communicate policy regarding the deterrence and investigation of suspected misconduct and dishonesty by employees and others, and to provide specific instructions regarding appropriate action in case of suspected violations.

GCM is committed to high standards of ethical, moral, and legal conduct. In line with this commitment and also GCM's commitment to open communication, this policy aims to provide an avenue for employees to raise concerns about suspected misconduct, dishonesty, and fraud, and to provide reassurance that they will be protected from reprisals or victimization for good faith whistle-blowing.