Whistleblowing and Anti-Bribery Policy

Scope of the policy

1. This Whistleblowing and Anti-Bribery Policy exists to set out the responsibilities of WhiteBIT, represented by WB Fintech Development FZE and DigiFort FZE respectively (hereinafter - “the Company”, “WhiteBIT”) including the Board of Directors and staff with regards to observing and upholding the Company’s zero-tolerance position on bribery and corruption. 

2. It also exists to act as a source of information and guidance for employees of the Company in order to help them recognize and deal with bribery and corruption issues, as well as understand their responsibilities.

3. This Policy also allows for reports to be made by entities outside the Company’s group and makes provision for the protection of the identity of such entities reporting bribery and corruption in the Company. 

Policy statement 

1. The Company is committed to conducting business in an ethical and honest manner, and is committed to implementing and enforcing systems that ensure bribery is prevented. 

2. The Company has zero-tolerance for bribery and corrupt activities. All members of staff including the Board of Directors are committed to acting professionally, fairly, and with integrity in all business dealings and relationships, wherever in the country we operate. 

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3. Members of the Board of Directors and members of staff shall be prohibited from:

1. giving, promising to give, or offer, a payment, gift or hospitality to a third party or otherwise engage in or permit a bribery offence to occur, with the expectation or hope that an advantage in business will be received or to reward a business advantage already given;
2. giving, promising to give, or offering, a payment, gift or hospitality to a third party to facilitate or expedite a routine procedure;
3. accepting a payment, gift or hospitality from a third party if it knows or suspects that such payment, gift or hospitality is offered or provided with an expectation that a business advantage will be provided by the Company in return;
4. threatening or retaliating against another member of the Board or staff who has refused to commit a bribery offence or who has raised concerns; and
5. engaging in any activity that might lead to a breach of the anti-bribery and corruption rules in this Policy.

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4. The Company will constantly uphold all laws relating to anti-bribery and corruption in all the jurisdictions in which it operates. It is bound by the laws of the UAE in regard to its conduct. 

5. The Board of Directors shall have the overall responsibility for ensuring this Policy is updated on an ongoing basis. 

6. The Compliance Officer will monitor the day-to-day effectiveness of the anti-bribery and corruption policy on a regular basis and ensure that it is implemented within the Company. Any deficiencies should be identified and dealt with as soon as possible. 

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Who is covered by the Policy?

1. This policy applies to all employees (whether temporary, fixed-term, or permanent), consultants, contractors, trainees, seconded staff, home workers, casual workers, agency staff, volunteers, interns, agents, sponsors, or any other person or persons associated with us (including third parties), or any of our subsidiaries or their employees, no matter where they are located (within or outside the UAE).

2. The policy also applies to Officers, Board, and/or Committee members at any level. 

3. In the context of this policy, third-party refers to any individual or organisation our company meets and works with. It refers to actual and potential clients, customers, suppliers, distributors, business contacts, agents, advisers, and government and public bodies – this includes their advisors, representatives and officials, politicians, and public parties. 

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What is covered by the Policy? 

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1. The Company, including its employees and any third parties as identified in paragraphs 3.1 to 3.3 above, is prohibited from making any payment to a third party where there is any reason to believe that all or any part of such payment will go towards a bribe or otherwise facilitate corruption. 

2. It follows that all payments made by the Company for services must be appropriate and justifiable for the purpose of legitimate services. 

3. Any individual involved in bribery is liable to different imprisonment sentences depending on the stage of bribery that has been reached. This might vary from the period of offering, the acceptance and the failure to fulfil the action.

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Raising a Concern

1. A member within the Company or a third party is required to report any instance of bribery or corrupt activities occurring in relation to the Company. 

2. A member of the Company is required to report to the Compliance Officer as soon as possible if it believes or suspects that an action in conflict with the anti-bribery and corruption rules has occurred or may occur or has been solicited by another entity. 

3. The individual reporting any violation or possible violation of the applicable laws and regulations relating to anti-bribery and corruption can do so by phone, by email, by mail or verbally to the Compliance Officer.  

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4. The Compliance Officer shall investigate any report of a violation or possible violation of the anti-bribery and corruption Rules and shall follow the below procedure: 
   
   1. The Compliance Officer shall open an investigation file. In the case of an oral report, the Compliance Officer shall prepare a written summary.
   2. The Compliance Officer shall appoint an independent Entity who shall promptly commission the conduct of an investigation. The investigation will document all relevant facts, including entities involved, times and dates.
   3. The Compliance Officer will advise the Board of the existence of an investigation.
   4. The identity of the individual disclosing relevant information to the Compliance Officer shall be treated in accordance with applicable UAE laws and regulations.
   5. On completion of the investigation, a written investigation report will be provided by the Entity employed to conduct the investigation to the Compliance Officer. If any unlawful conduct is found, the Compliance Officer must advise the Board accordingly.
   6. If any unlawful conduct is found, the Company shall take such remedial action as the Board deems appropriate to achieve compliance with its internal anti-bribery and corruption policy and all applicable anti-bribery and corruption laws. The Entity employed to conduct the investigation shall prepare a written summary of the remedial actions taken.
   7. The written investigation report and a written summary of the remedial actions taken shall be retained by the Compliance Officer for a period of no less than eight [8] years from completion of the remedial action. Such reports shall be made available to VARA upon request.
5. The Compliance Officer shall immediately report to VARA any finding of unlawful conduct in breach of the Rules and this policy. 

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Training and Communication

1. This policy shall be provided to all new employees as part of the induction process together with training on the implications of this Policy. 

2. The Company’s anti-bribery and corruption policy and zero-tolerance attitude will be clearly communicated to all suppliers, contractors, business partners and to any third-parties at the outset of the business and as appropriate thereafter.

3. Should any employees feel their knowledge of how to comply with this policy needs to be enhanced, such employees are to inform the compliance officer who shall ensure that adequate training is provided.

4. The Company will implement and provide an anti-bribery and corruption training program for the Board and all Staff on a regular basis and monitor their compliance with all established procedures. All members of the Board and Staff must participate in all such training provided by the company.

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Employee Responsibilities

1. Employees of the Company must read, understand and comply with the information contained within this policy, and with any training or other anti-bribery and corruption information they are given.

2. All employees are equally responsible for the prevention, detection and reporting of bribery and other forms of corruption and are to avoid any activities that could lead to, or imply a breach of this anti-bribery policy.

3. If an employee has any reason to believe or suspect that an instance of bribery or corruption that breaches this policy has taken place or may take place, notification must be made to the Compliance Officer.

4. Any employee who breaches this policy will face disciplinary action and may have his/her employment terminated without notice.