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Whistleblowing Policy

1. PURPOSE

Shipfinex FZCO is committed to maintaining the highest standards of integrity and ethical conduct. We encourage anyone to report suspected wrongdoing, fraud, regulatory breaches, or unethical conduct without fear of retaliation. This policy outlines how you can report concerns and how we protect those who make reports in good faith.

2. WHO CAN REPORT

Anyone can report concerns under this policy, including:

Employees and contractors

Clients and customers

Partners and service providers

Any other third parties

3. WHAT CAN BE REPORTED

You can report suspected:

Financial misconduct or fraud

Regulatory or compliance breaches

Market abuse or market manipulation

Anti-money laundering (AML) or counter-financing of terrorism (CFT) violations

Data protection or privacy breaches

Unethical conduct or conflicts of interest

Misuse of company resources

Any other violations of law or company policy

4. HOW TO REPORT

You can report concerns through multiple confidential channels:

Whistleblower Email: [email protected]

Compliance Email: [email protected]

5. CONFIDENTIALITY AND ANONYMITY

Your identity and the details of your report will be treated confidentially. You may report anonymously, and your identity will be protected unless disclosure is required by law. Reports are handled only by appropriate personnel and kept secure.

6. PROTECTION FROM RETALIATION

Shipfinex strictly prohibits retaliation against anyone who makes a report in good faith. Retaliation in any form—including dismissal, demotion, harassment, or discrimination—is prohibited and will result in disciplinary action, up to and including termination.

7. INVESTIGATION PROCESS

When you report a concern:

Your report will be acknowledged and assessed for validity

An independent investigation team will be formed

Evidence will be collected and analyzed

You will be informed of the outcome where appropriate, while maintaining confidentiality

Corrective actions will be implemented as needed

8. ESCALATION TO VARA

If concerns cannot be resolved internally, or if you prefer, you can escalate your report directly to the Virtual Assets Regulatory Authority (VARA), Shipfinex's regulatory authority.

9. RECORD KEEPING

All reports and investigations are documented and maintained securely for a minimum of 8 years to support regulatory oversight and audit requirements.

10. CONTACT US

To report a concern: