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.

Direct Contact

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), Financial Conduct Authority (FCA), National Crime Agency (NCA). Canada — RCMP Anti-Corruption Unit, FINTRAC.

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.

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.

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.

Outcome: Following investigation, we will determine whether misconduct occurred, take appropriate corrective action (disciplinary measures, policy changes, referral to authorities), and 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.

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.

Key Questions