Whistleblower Policy

Speak Up Without Fear

At Unicorn Currencies, we are committed to maintaining the highest standards of integrity, transparency, and ethical conduct. Our Whistleblower Policy provides a safe, confidential mechanism for employees, contractors, partners, and third parties to report suspected misconduct, violations of law, or breaches of our policies without fear of retaliation.

What You Should Report

We encourage you to report any concerns about:

Financial Misconduct

• Fraud, theft, or misappropriation of funds

• False accounting, financial statement manipulation, or invoice fraud

• Bribery, corruption, or kickbacks

• Money laundering or terrorist financing

• Sanctions violations or regulatory breaches

Unethical Business Practices

• Violations of our Code of Conduct & Ethics

• Conflicts of interest or self-dealing

• Misuse of confidential information or insider trading

• Anti-competitive behavior or market manipulation

• Mis-selling or unfair treatment of clients

Workplace Misconduct

• Discrimination, harassment, or bullying

• Health and safety violations

• Retaliation against whistleblowers or complainants

• Violations of employment laws or human rights

Regulatory and Legal Violations

• Breaches of financial services regulations (FINTRAC, FCA requirements)

• Data protection violations (UK GDPR, PIPEDA)

• Modern slavery or human trafficking

• Environmental violations

• Any other illegal activity

If you see something, say something. Even if you're not certain that a violation has occurred, we would rather you report your concerns so we can investigate.

How to Report

We provide multiple channels for reporting concerns:

Confidential Ethics Hotline

Email: ethics@unicorncurrencies.com

This dedicated email is monitored by our Compliance Officer and Chief Operating Officer. All reports are treated with strict confidentiality.

Anonymous Reporting

You may report anonymously if you prefer. While anonymous reporting may limit our ability to follow up or request additional information, we will investigate all credible reports to the fullest extent possible.

To report anonymously, you may:

• Send an anonymous email from a temporary email account to ethics@unicorncurrencies.com

• Contact us through anonymous communication channels (details available to employees via internal systems)

Direct Contact

You may also report concerns directly to:

Compliance Officer / Head of Compliance
Email: compliance@unicorncurrencies.com
UK Phone: +44 (20) 8064-0818
Canada Phone: +1 (548) 488-0818

Chief Operating Officer
Email: mohsen@unicorncurrencies.com (for concerns involving the Compliance Officer)

External Reporting

In serious cases, you may report directly to external authorities:

UK:

• Serious Fraud Office (SFO): https://www.sfo.gov.uk | +44 (0)20 7239 7272

• Financial Conduct Authority (FCA): https://www.fca.org.uk/consumers/report-firm-fca

• National Crime Agency (NCA): https://www.nationalcrimeagency.gov.uk

Canada:

• RCMP Anti-Corruption Unit: https://www.rcmp-grc.gc.ca | 1-800-387-0020

• FINTRAC: https://fintrac-canafe.canada.ca

What Happens After You Report

Acknowledgment

We will acknowledge receipt of your report within 48 hours (during business days) and provide you with a reference number for tracking purposes.

Confidentiality

Your identity will be protected to the fullest extent possible. Information about your report will be shared only with individuals who have a legitimate need to know for investigation purposes. We will not disclose your identity to the subject of the investigation without your consent, except where legally required.

Investigation

All reports are taken seriously and investigated promptly and thoroughly by the Compliance Officer, with assistance from Legal, Internal Audit, Human Resources, or external advisors as appropriate. Investigations are conducted:

• Impartially: Without bias or prejudgment

• Confidentially: With appropriate discretion to protect all parties

• Fairly: Providing the subject of allegations an opportunity to respond

• Thoroughly: Gathering and analyzing all relevant evidence

Timeline

We aim to complete investigations within 30 business days, though complex matters may require additional time. We will keep you informed of progress where possible (particularly if you have provided contact details).

Outcome

Following investigation, we will:

• Determine whether misconduct occurred

• Take appropriate corrective action (disciplinary measures, policy changes, process improvements, referral to authorities)

• Provide feedback to you on the outcome, to the extent permitted by confidentiality and legal considerations

• Implement measures to prevent recurrence

Protection Against Retaliation

Zero Tolerance for Retaliation

Unicorn Currencies strictly prohibits retaliation against anyone who:

• Reports suspected misconduct in good faith

• Cooperates with an investigation

• Refuses to engage in conduct that would violate our policies or laws

Retaliation includes:

• Termination, demotion, suspension, or other adverse employment action

• Harassment, intimidation, threats, or ostracism

• Withholding promotions, bonuses, or opportunities

• Any other conduct intended to punish or discourage reporting

Anyone who retaliates against a whistleblower will face severe disciplinary action, up to and including termination.

Your Rights

If you believe you have experienced retaliation for making a report, immediately contact the Compliance Officer, COO, or external legal counsel. We will investigate retaliation claims promptly and take corrective action.

Whistleblowers in the UK are protected by the Public Interest Disclosure Act 1998 (PIDA). In Canada, protections vary by province but generally prohibit retaliation for good faith reporting of violations.

Good Faith Reporting

This policy protects individuals who report concerns in good faith, even if the report ultimately proves to be unfounded after investigation. You do not need to be certain that a violation has occurred—reasonable suspicion is sufficient.

However, knowingly false or malicious reports made to harm others or for personal gain are not protected and will result in disciplinary action against the person making the false report.

Confidentiality and Legal Privilege

In certain circumstances, reports and investigation materials may be protected by legal privilege. We will assert privilege where appropriate to protect the integrity of investigations and the confidentiality of participants.

Questions and Support

If you have questions about this Whistleblower Policy or need guidance on whether to report a concern, please contact:

Email: ethics@unicorncurrencies.com
Compliance Officer: compliance@unicorncurrencies.com
UK Phone: +44 (20) 8064-0818
Canada Phone: +1 (548) 488-0818

Your voice matters. Your courage to speak up protects our clients, our colleagues, and the integrity of our business.

© 2025 Unicorn Currencies. All rights reserved.