Version #1
Effective Date: 14/10/2025
Last Revised Date: 14/10/2025
This Whistleblowing Policy (“Policy”) is reviewed annually, unless there is a change in regulation that requires to implementation of an earlier update.
A. Policy statement
Gate Technology FZE (the “Company”) is committed to the highest standards of Integrity, quality, honesty, fairness, openness, accountability, and transparency. An important aspect of accountability and transparency is a mechanism to enable Employees, contractors, suppliers, consultants, business partners, and any third parties associated with the Company to uphold these standards.
We recognise that external parties may, in the course of their engagement with the Company, become aware of potential misconduct, unethical behaviour, or regulatory breaches. To promote an open and transparent environment, the Company encourages external parties to report such concerns in good faith through the channels provided below.
B. Scope
External parties may report any suspected misconduct to the Company, including but not limited to:
A. Protection against detriment
The Policy is designed to offer protection against detriment to those parties who make a protected disclosure, provided the disclosure is made:
The Company strictly prohibits any form of retaliation or disadvantage against individuals who raise concerns in good faith, regardless of the investigation outcome. Any complaint of retaliation in response to such disclosures, including but not limited to, threats of health, safety, loss of job, and environment, will be promptly investigated. Such a complaint must be made and shall be investigated in accordance with the procedure mentioned under clause 3 of this Policy.
B. Confidentiality
The Company will treat all such disclosures in a confidential and sensitive manner. Any reports submitted are accessible only to those persons who have, in the judgment of the Chief Compliance Officer, a need to know the information. The identity of the individual making the allegation shall be kept confidential so that the whistleblower is protected.
C. Anonymous allegations
This Policy encourages individuals to put their names to any disclosures they make. Concerns expressed anonymously are much less credible, but they may be considered at the Company’s discretion.
In exercising this discretion, the factors to be considered will include:
Allegations made anonymously should contain sufficient detail and information so that, if necessary, a meaningful investigation can be conducted.
They should, ideally, put in writing the nature of their complaint with as many facts as possible, e.g., dates, names, places etc. Should the Employees not feel comfortable with approaching their line manager, they should approach a vertical manager (e.g., operations manager, finance manager, etc.). Should this still not be acceptable then there are a number of other lines of communication available:
Reports can be made through the following secure and confidential channels:
All reports will be promptly reviewed by the Compliance Officer / MLRO, or where appropriate, escalated to the Managing Director. Where an investigation confirms that a regulatory breach or misconduct has occurred, appropriate remedial and disciplinary actions will be taken, and where required, the matter will be reported to the Virtual Assets Regulatory Authority (VARA) or other competent authorities.
Due to the varied nature of these complaints, it is not possible to lay down precise timescales for such investigations. However, the Company will ensure that investigations are undertaken as quickly as possible within a reasonable period of time, without affecting the quality and depth of those investigations.
Gate Technology FZE is committed to maintaining open communication and upholding the highest ethical standards in its operations. This Policy will be reviewed regularly to ensure its continued effectiveness and alignment with applicable UAE laws and regulatory expectations.