Whistleblowing policy
Note:
“PRYPCO Mint” is hereby referred to as “PRYPCO FZE”
This Whistleblowing Policy sets out the policies and procedures that PRYPCO FZE (“the Firm” or “PRYPCO Mint”) must follow in order to comply with the principles, rules and regulations of the Dubai Virtual Assets Regulatory Authority (“VARA”), and to maintain the highest standards of market integrity, transparency, ethical conduct, and fair treatment of customers in all its operations.
The Whistleblowing Policy provides a framework for employees, contractors, and other stakeholders to report unethical, illegal, or inappropriate behaviour without fear of retaliation. This policy ensures that all concerns are addressed promptly, fairly, and confidentially, reinforcing PRYPCO FZE’s commitment to ethical business practices.
Stakeholders of PRYPCO FZE have the right to whistleblow and to expect timely responses and resolutions. The following policy and procedures outline our process for handling complaints.
The policy is designed to address and mitigate the following types of misconduct and harmful actions:
Fraud:
Any intentional act or omission intended to deceive, resulting in financial loss or reputational harm to PRYPCO FZE or its stakeholders.
Corruption:
The misuse of entrusted authority for personal benefit, including bribery, kickbacks, and other unethical business practices.
Harassment and Discrimination:
Actions that foster a hostile work environment, including harassment or discrimination based on race, gender, religion, age, disability, or other protected characteristics, as well as unwanted advances, discriminatory hiring practices, or offensive remarks.
Safety Violations:
Failure to comply with safety protocols, resulting in risks to the health or well-being of employees, customers, or others. PRYPCO FZE prioritises a safe work environment and holds individuals accountable for upholding safety standards.
Market Offences:
Activities such as insider trading, market manipulation, or the unauthorised disclosure of confidential or sensitive information that undermine market integrity.
Retaliation:
Any form of reprisal against individuals who report misconduct, cooperate in investigations, or refuse to engage in unethical activities. PRYPCO FZE strictly enforces a non-retaliation policy, ensuring whistleblowers are safeguarded from adverse actions.
PRYPCO FZE’s whistleblower framework is a cornerstone of its commitment to corporate integrity, ensuring swift and thorough responses to all reported concerns. This policy aligns with regulatory standards and PRYPCO FZE’s values, fostering a culture of trust and accountability.
SECTION 1:
Prohibited Actions
PRYPCO FZE is dedicated to fostering a safe, ethical, and compliant work environment. To uphold the highest standards of integrity, the following actions are strictly prohibited:
Engaging in Fraud or Corruption
PRYPCO FZE strictly prohibits all forms of fraudulent and corrupt activities. This includes, but is not limited to:
Falsification of Records: Altering or manipulating financial records, timesheets, or any other official documents for personal or professional gain.
Financial Misconduct: Activities such as embezzlement, theft, or misappropriation of company funds.
Bribery: Offering, giving, receiving, or soliciting anything of value to influence a decision or gain an unfair advantage.
Participating in Harassment or Discrimination
PRYPCO FZE enforces a zero-tolerance policy for any behaviour that fosters harassment or discrimination, ensuring a respectful and inclusive workplace for all. This also includes:
Sexual Harassment: Unwelcome advances, requests for favours, or any verbal or physical harassment of a sexual nature.
Discrimination: Unfair treatment of employees, partners, or third parties based on race, gender, religion, age, disability, or other protected characteristics.
Violating Safety Protocols
Employees are required to comply with all safety standards and procedures to maintain a secure work environment. Violations include:
Ignoring emergency procedures.
Failing to use personal protective equipment (PPE).
Deliberate actions that compromise workplace safety.
Committing Market Offences
PRYPCO FZE is committed to strict adherence to market conduct regulations. The following offences are strictly prohibited:
Insider Trading: Trading based on non-public, material information to gain an unfair advantage.
Market Manipulation: Activities designed to create artificial pricing or mislead market participants.
Unlawful Disclosure of Information: Sharing confidential or privileged information without authorisation.
Compliance and Enforcement
Any employee found engaging in these prohibited actions will be subject to disciplinary measures, up to and including termination. PRYPCO FZE is committed to ensuring accountability and adherence to these standards across the organisation.
SECTION 2:
PRYPCO FZE is committed to providing channels for employees, clients, and other third parties to report concerns securely:
Customer Awareness of the Complaints Policy
PRYPCO FZE provides multiple secure and confidential channels for employees and stakeholders to report suspected misconduct covered under this policy. All reports are handled promptly, with fairness and confidentiality ensured throughout the process.
Dedicated Email: Reports can be sent to groupcompliance@prypco.com, monitored by the Compliance team.
Online Form: A secure whistleblower form is accessible through PRYPCO FZE’s website for confidential submissions.
In-Person Reporting: Individuals may report concerns directly to the Compliance Officer or designated senior management.
Anonymous Submissions
Individuals who prefer not to disclose their identity can submit concerns anonymously. PRYPCO FZE treats anonymous reports with the same level of seriousness and ensures they are thoroughly investigated.
Third-Party Reporting
Clients and other third parties can report concerns directly to PRYPCO through the following channels:
Website: www.prypco.com
Postal Mail: Concerns and escalation reports can be sent to our postal mail address, the details of which are available on our website
Email: groupcompliance@prypco.com
Telephone: 800-779726
SECTION 3:
PRYPCO FZE has established a comprehensive process for investigating all reported concerns: Impartial Investigations:
Upon receiving a report, an impartial party within the HR or Compliance department will lead the investigation. This process includes gathering relevant evidence, interviewing witnesses, and thoroughly documenting all findings.
Timelines and Transparency:
PRYPCO FZE commits to a timely investigation process, with clear timelines for responding to and resolving issues. The whistleblower will be informed of the progress and outcome, where appropriate.
Conflict Resolution:
In situations involving interpersonal conflicts, PRYPCO FZE offers mediation services to help resolve issues fairly. HR personnel are trained in conflict resolution techniques to ensure disputes are handled effectively.
PRYPCO FZE is committed to protecting individuals who report wrongdoing from any form of retaliation:
Non-Retaliation Policy:
PRYPCO FZE enforces a strict non-retaliation policy to safeguard whistleblowers. Any employee or manager found engaging in retaliation will face disciplinary action, including possible termination.
Confidentiality:
The identity of whistleblowers is protected to the fullest extent possible. Disclosure of the whistleblower's identity will only occur if legally required and will be limited to individuals directly involved in the investigation.
Disciplinary Measures for Policy Violations:
PRYPCO FZE upholds a fair and transparent process for addressing violations of all prohibited actions, including but not limited to the Code of Conduct, safety protocols, market conduct regulations, and any other internal or external regulations. The following outlines the range of disciplinary measures that may be applied:
Application of Disciplinary Measures:
Violations of any of PRYPCO FZE's policies, including those uncovered through whistleblower reports, result in appropriate disciplinary actions. These actions are designed to enforce compliance, maintain market integrity, and protect all stakeholders. Depending on the severity of the breach, disciplinary actions can range from warnings to termination of employment or expulsion from trading activities.
Consistency and Fairness:
PRYPCO FZE ensures that disciplinary actions are consistently applied across the organisation. This approach maintains fairness and upholds the integrity of PRYPCO FZE’s operations, ensuring that all employees and participants understand the consequences of non-compliance.
Structured Disciplinary Framework:
PRYPCO FZE maintains a structured and tiered approach to disciplinary actions to ensure that all breaches of company policies, regulations, or ethical standards are addressed appropriately. The goal of these disciplinary measures is not only to enforce compliance but also to educate and correct behaviour, thereby maintaining the integrity of PRYPCO FZE’s operations and fostering a culture of accountability. The severity of disciplinary actions corresponds to the nature and seriousness of the violation, with the aim of achieving both corrective and preventive outcomes.
Below are the types of disciplinary actions that PRYPCO FZE may implement:
Warnings: Formal warnings may be issued for minor infractions. These serve as an official notice of non-compliance and remind the individual of the expected conduct.
Reprimands: A formal reprimand is issued for more serious breaches of conduct. This indicates that the behaviour must be corrected immediately and that further infractions will result in more severe consequences.
Training: Mandatory training sessions may be required to correct and educate individuals on proper conduct. This aims to ensure that participants fully understand the rules and the importance of compliance.
Qualification Minimums: PRYPCO FZE may impose minimum qualification requirements for continued participation in certain activities. This may include demonstrating specific competencies or completing additional training.
Remediation Plans: In cases of non-compliance, PRYPCO FZE may develop and enforce remediation plans that outline specific actions the individual must take to correct their behaviour.
Compliance Audits: Audits may be conducted to ensure adherence to policies and regulations. These audits can be scheduled or unannounced and are intended to verify that all individuals are complying with the rules.
Restitution: Individuals may be required to provide restitution for damages caused by their non-compliance. This could include compensating affected parties for any losses incurred as a result of their actions.
Contractually Agreed Penalties: Penalties outlined in client agreements may be imposed. These penalties are predetermined and agreed upon during the account setup and are enforced when breaches occur.
Conditions on Trading: Specific conditions may be imposed on trading activities, such as restrictions on the types of trades, trade volumes, or trading times, to ensure compliance and market integrity.
Trading Prohibitions: PRYPCO FZE may impose temporary or permanent prohibitions on trading activities for individuals who violate market conduct rules. This could include being barred from trading on the platform for a specified period or indefinitely.
Suspensions and Restrictions: Trading privileges may be suspended or restricted while an investigation is conducted. This action helps to prevent further violations and protect market integrity during the investigative process.
Expulsions: In cases of severe or repeated infractions, PRYPCO FZE may expel the individual from the trading venue or other activities. Expulsion is considered the most severe disciplinary action and is reserved for the most egregious conduct.
Cancellation of Orders: PRYPCO FZE reserves the right to cancel a client’s orders and any outstanding instructions that are deemed to be in violation of the rules or that pose a risk to market integrity.
Regulatory Reporting and Criminal Referrals:
Reporting to VARA and UAE FIU: Serious breaches, including those that may constitute a market offence, attempted market offence, or any other unfair practice detrimental to the fair and orderly functioning of any market involving virtual assets, must be reported to the relevant authorities.
VARA Reporting: Any significant violations or suspicious activities must be reported to the Virtual Assets Regulatory Authority (VARA) for further investigation and potential regulatory action. This step ensures compliance with broader regulatory frameworks and addresses actions that may have a significant impact on the market.
FIU Reporting: Additionally, transactions, orders, or activities where there is reasonable suspicion that they could constitute a market offence or any other unfair practice must be reported to the UAE Financial Intelligence Unit (FIU).
Criminal Referrals: In cases where criminal activity is suspected, PRYPCO FZE will refer the case to the appropriate criminal authorities. PRYPCO FZE will fully cooperate with law enforcement agencies to ensure that any illegal activities are properly addressed and prosecuted.
Audit and Oversight:
Audit Procedures:
The whistleblower programme is regularly audited to evaluate its effectiveness and compliance with legal requirements. Audits include reviewing reporting mechanisms, investigating procedures, and assessing the enforcement of the non-retaliation policy.
Continuous Improvement:
Based on audit findings, PRYPCO FZE makes necessary adjustments to strengthen the programme and address any gaps, ensuring continuous improvement in its ethical practices.
Awareness and Accessibility:
Regular Training:
Training on the Whistleblower Policy is integrated into PRYPCO FZE’s compliance training programmes. Employees are educated on how to report concerns, the protections available to them, and the importance of maintaining ethical standards.
Ongoing Education:
Regular refresher courses are provided to ensure employees are aware of any updates or changes to the policy.
Accessibility:
The Whistleblower Policy is readily accessible to all employees through the company intranet and the employee handbook. It is also communicated during onboarding and periodically reinforced.
SECTION 4:
Record Keeping and Policy Updates
Retention of Records:
PRYPCO FZE maintains detailed and secure records of all whistleblower reports, investigations, and outcomes. These records are retained for a minimum of eight (8) years to ensure traceability and accountability. Access to these records is strictly limited to authorised personnel involved in the investigation and audit processes.
Policy Review and Regulatory Compliance:
The Whistleblower Policy is reviewed annually to ensure ongoing effectiveness and alignment with regulatory and legal requirements. Additionally, updates are made as necessary in response to changes in applicable laws or regulatory frameworks. All revisions are reflected in internal documentation and communicated appropriately to maintain transparency and compliance across the organisation.
