Whistleblowing Policy
Speak up safely and confidentially
Purpose and Scope
ZINBLOCK FZE is committed to maintaining the highest standards of integrity, transparency, and ethical conduct. This Whistleblowing Policy provides a secure mechanism for employees, contractors, investors, and third parties to report suspected wrongdoing without fear of retaliation.
What Should Be Reported
You should report concerns about:
Financial Misconduct
- • Fraud or theft
- • Accounting irregularities
- • Misuse of company funds
- • False financial reporting
Regulatory Violations
- • VARA compliance breaches
- • AML/CFT violations
- • Securities law breaches
- • Data protection violations
Bribery & Corruption
- • Bribery or kickbacks
- • Conflicts of interest
- • Misuse of position
- • Facilitation payments
Other Serious Matters
- • Safety violations
- • Environmental breaches
- • Discrimination or harassment
- • Cybersecurity incidents
How to Report
Anonymous Hotline
+971 800 779726 (ext. 888)
Available 24/7, operated by third-party service
Secure Online Portal
whistleblow.zinblock.com
Encrypted submission with optional anonymity
Direct Contact
Chief Compliance Officer or Independent Board Member
For sensitive matters requiring personal discussion
Confidentiality and Anonymity
Your identity will be protected and kept confidential to the extent possible under law
You may submit reports anonymously through our secure channels
Access to reports is restricted to authorized personnel only
Your information will only be disclosed if required by law or for investigation purposes
Protection from Retaliation
ZINBLOCK strictly prohibits retaliation against anyone who reports concerns in good faith. Protected individuals will not face:
Important: Any employee found to have retaliated against a whistleblower will face disciplinary action up to and including termination.
Investigation Process
Receipt & Assessment
All reports are logged and assessed for severity within 48 hours.
Acknowledgment
If contact details provided, you'll receive acknowledgment and a unique reference number.
Investigation
Independent investigation conducted by qualified personnel or external experts.
Resolution & Reporting
Findings documented, appropriate action taken, and reporter updated (if not anonymous).
Good Faith Reporting
Reports must be made in good faith with reasonable belief that the information is accurate. Protection extends to reports that prove to be incorrect, provided they were made honestly.
Note: Deliberately false or malicious reports may result in disciplinary action and will not be protected under this policy.
Monitoring and Review
The Board of Directors receives quarterly reports on whistleblowing activity, including number of reports, categories, investigation outcomes, and any trends. This policy is reviewed annually and updated as needed.
External Reporting
You may also report concerns directly to external authorities:
VARA: complaints@vara.ae
UAE Central Bank: For financial regulatory matters
Dubai Police: For criminal matters
Ministry of Human Resources: For employment law violations
Your Voice Matters
Whistleblowing is an act of integrity that helps protect ZINBLOCK, our investors, and the broader financial system. We encourage you to speak up if you witness wrongdoing. Your courage in reporting concerns helps us maintain the highest ethical standards.
For questions about this Whistleblowing Policy, contact the Chief Compliance Officer at compliance@zinblock.com