OFZA FINTECH VIRTUAL ASSET EXCHANGE SERVICES L.L.C (“OFZA”) WHISTLEBLOWER POLICY

1. Introduction 

   1. OFZA Fintech Virtual Asset Exchange Services L.L.C. (“OFZA” or “the Firm”) is committed to maintaining the highest standards of integrity, transparency, fairness, and accountability in all aspects of its business operations.

   2. This Whistleblower Policy establishes a confidential, independent, and retaliation-free framework that enables employees, contractors, clients, and other stakeholders to report, in good faith, any suspected misconduct, unethical behaviour, or regulatory breach, in accordance with the Dubai Virtual Assets Regulatory Authority (VARA) Rulebooks, OFZA internal policies, and applicable UAE laws.

   3. The framework is administered by the Compliance Officer under the oversight of the Board of Directors, ensuring all disclosures are handled fairly, impartially, and with appropriate governance.

   4. The Policy aims to:

      1. Encourage the prompt and responsible reporting of genuine concerns.

      2. Ensure all disclosures are handled confidentially, fairly, and independently.

      3. Protect individuals who raise concerns in good faith from retaliation or adverse consequences.

      4. Support OFZA’s broader governance, compliance, and ethical culture.

    

2. Scope

   1. This Whistleblower Policy applies to all individuals and organizations connected with OFZA, including:

      1. Employees, directors, and officers.

      2. Contractors, consultants, and authorized representatives acting on behalf of OFZA.

      3. Clients, vendors, service providers, and other business partners.

   2. If, for any reason, internal reporting is not possible or appropriate, stakeholders may raise their concerns through other suitable channels, including with the relevant regulatory or competent authorities, in line with applicable laws and established procedures.

    

3. Reportable Concerns

   1. Whistleblowing may relate to any actual or suspected misconduct, bribery, corruption, wrongdoing, or breach of law, including but not limited to:

      1. Financial malpractice, impropriety, fraud, theft, embezzlement, bribery, or corruption.

      2. Money laundering, terrorist financing, regulatory law, or sanctions violations.

      3. Conflict of interest, abuse of authority, or misuse of position.

      4. Misuse of confidential or client information, data privacy breaches, or unauthorized disclosure.

      5. Improper conduct, unethical behaviour, or obstruction of an internal or regulatory investigation.

      6. Harassment, discrimination, bullying, or other forms of workplace misconduct.

      7. Actions endangering the health, safety, security, or wellbeing of employees, clients, or the public.

      8. Environmental damage or failure to comply with sustainability or safety standards.

      9. Concealment, suppression, or deliberate non-disclosure of any of the above.

      10. Any other matter that may reasonably trigger a whistleblowing report or indicate misconduct or wrongdoing.

    

4. Reporting Channels

   1. If you know or suspect that any employee(s), consultant(s), or their related persons—or any persons claiming to be employees or consultants of OFZA—have engaged in bribery or any other reportable concern mentioned in Section 3, you shall promptly notify through the following channels:

      1. Email: [email protected]

      2. Phone: +971 52 106 9982

   2. Anonymous Reports: Anonymous reports made in good faith and with sufficient detail receive the same protection as identified reports.

    

5. Investigating a Report

   1. All whistleblowing reports at OFZA are handled with integrity, confidentiality, and independence, in line with the Dubai Virtual Assets Regulatory Authority (VARA) Rulebooks and UAE laws. All reports and related records are securely retained in accordance with OFZA’s record-keeping standards.

    

6. Protection and Safeguards

   1. OFZA maintains a zero-tolerance policy toward any form of retaliation, harassment, demotion, or adverse treatment against individuals who make a disclosure in good faith under this Policy.

   2. A disclosure is deemed to be made in good faith if:

      1. It is based on reasonable grounds and supported by available information.

      2. The individual is not acting for personal gain or with malicious intent.

   3. Any act of retaliation—including but not limited to threats, intimidation, loss of employment, punitive work assignments, or unfair treatment—will be treated as a serious disciplinary offence, subject to appropriate action up to and including termination.

   4. Confidentiality: All disclosures are treated with the highest level of confidentiality.

   5. Employees will usually be the first to know when someone inside or connected with an organization may be doing something improper but may feel apprehensive about voicing their concerns. This may be because they feel that speaking up would be disloyal to their colleagues or the organization itself. Or it may be because they do not think that their concerns will be taken seriously or because they are afraid that they will be penalized in some way. However, OFZA promote zero tolerance against any reportable concerns and does not believe that it is in anyone's interest for employees with knowledge of wrongdoing to remain silent. Whistleblowers are encouraged to report any misconduct or perceived retaliation immediately to dedicated OFZA channels.

    

7. Record Keeping

   1. The Firm will retain all records related to whistleblowing reports, investigations, and their outcomes including supporting evidence, findings, correspondence, and closure summaries for a minimum period of eight (8) years.