LCT

Whistleblower Policy

Introduction

The purpose of this policy is to ensure that the cryptocurrency exchange operates with the highest standards of ethics and compliance. This policy aims to encourage employees, customers, and other stakeholders to report any unethical or illegal behavior while ensuring the protection of whistleblowers. LCT emphasizes the importance of reporting misconduct in maintaining a transparent and fair-trading environment and commits to protecting those courageous individuals who stand up to uphold these standards

Scope

This policy applies to LCT, its employees, contractors, customers, and other stakeholders.

Reporting Procedure

1) Channels for Submitting Reports.

  • Email: [email protected]
  • Telephone: +971 54 7924238
  • Physical Address: Office No. 01, DD 1.01 - 04 MAKTABI Business Center, 18th floor, Sheikh Rashid Tower, DWTC, Dubai, UAE. Please mark the envelope with "Whistleblower Report - Confidential" to ensure privacy and proper handling.

LCT does not restrict the type of channels used or the number of times a report can be submitted.

2) Report Content Reports should include as much detailed information as possible, encompassing a description of the event, involved personnel, time, location, and any available evidence. The below information should be provided.

Category
Description
Event Description
Provide a detailed description of the incident, including the nature of the misconduct or illegal activity. Describe the background and possible motives of the event.
Involved Personnel
Provide identity information of the involved personnel, including possible witnesses, individuals, or teams suspected of violations. If internal employees are involved, provide their position or department information.
Time and Location
Specify the exact date and time of the event (if possible). Describe the location or geographical scope of the incident.
Evidence
Encourage the provision of any relevant evidence, such as documents, emails, transaction records, audio, or video materials. Indicate how to safely access or submit these pieces of information.
Previous Reports or Attempts
If there have been previous reports or attempts to address the issue, please provide relevant information and outcomes.
Whistleblower Contact Information
If the whistleblower is willing to provide, leave contact information for further communication and investigation. Ensure that the identity of the whistleblower is protected even if contact information is provided.
Any Other Relevant Information
Encourage whistleblowers to provide any other information or observations they believe may assist in the investigation.

Whistleblowers are encouraged to furnish as much specific and verifiable information as possible to facilitate an efficient and accurate investigation.

3) Processing of Reports Upon receipt of a report, it will be meticulously recorded and assigned to the appropriate investigative team. Whistleblowers will receive a confirmation notification and be kept informed of the progress of the process if they choose to disclose their identity.

Confidentiality and Anonymity

1) Commitment to Confidentiality LCT firmly commits to maintaining the confidentiality of the whistleblower's identity. The handling of any report will adhere to the highest standards of confidentiality. Throughout the investigative process, LCT will take all necessary measures to ensure that the identities of whistleblowers are not disclosed to involved parties or stakeholders.

2) Protective Measures during the Process LCT will implement stringent internal controls and information access management to safeguard the confidentiality of the whistleblower's identity. Any investigative activities conducted by LCT will be carried out in a manner that avoids revealing the whistleblower’s identity, ensuring they are protected from any form of retaliation or unfair treatment.

3) Option for Anonymous Reporting Whistleblowers have the right to choose to report anonymously to LCT Global. The company provides appropriate channels for anonymous submissions, ensuring that the whistleblower’s identity is not recorded or disclosed. If the whistleblower chooses not to remain anonymous, LCT will provide additional protective measures to ensure their personal safety and interests.

4) Rights and Support for the Whistleblower LCT emphasizes the rights and support available to whistleblowers throughout the process. Whistleblowers can be informed about the progress of their report at any time by LCT and will not suffer adverse consequences as a result of their reporting.

Anti-Retaliation

1) Firm Commitment to Confidentiality LCT firmly opposes any form of retaliation against whistleblowers. This constitutes a core aspect of the company's culture and ethical principles, and LCT takes any violation of this principle seriously. Any attempts at retaliation, intimidation, or any form of adverse impact on whistleblowers will be met with the strictest disciplinar

2) Clear Protective Measures LCT will implement explicit protective measures to ensure that whistleblowers do not suffer workplace retaliation, career damage, or personal security threats after reporting. Any suspected retaliatory actions will be thoroughly investigated by LCT Global, and necessary steps will be taken to protect the interests of the whistleblowers.

3) Support and Counseling LCT provides support and counseling to whistleblowers who may feel pressured or insecure. Whistleblowers at LCT will have access to necessary resources, including legal and psychological counseling services.

4) Education and Training LCT conducts regular education and training for all employees, emphasizing the anti-retaliation policy and the importance of whistleblowers. Management and team leaders at LCT are ensured to understand their responsibilities and roles in upholding this policy.

Investigation Procedure

Stage
Involved Parties
Activities
Report Reception
Compliance Department, HR Department
Receive and record the report. Send confirmation notification to the whistleblower (if identity is known).
Preliminary Assessment
Compliance Department, Internal Audit Team
Assess the seriousness and credibility of the report. Decide whether a formal investigation is needed.
Special Handling Mechanism Initiation
Senior Management, External Consultants (if applicable)
If the report involves HR or the Compliance Department, initiate a special handling mechanism. Assign independent senior management or external consultants to conduct the investigation.
Investigation Initiation
Special Investigation Team (may include legal advisors)
Collect and review relevant evidence. Interview witnesses and involved personnel.
Progress Updates
Investigation Team, Compliance Department
Regularly provide progress updates to the whistleblower. Maintain communication channels to receive more information or feedback.
Investigation Conclusion and Reporting
Investigation Team, Senior Management
Complete the investigation and draft the report. Present the investigation results to senior management.
Follow-up Actions and Feedback
Senior Management, HR Department
Take appropriate actions based on the investigation results. Provide the final outcome and actions taken to the whistleblower.
Filing and Auditing
Compliance Department, Internal Audit Team
Archive all documents and evidence. Regularly audit the effectiveness of the investigation process.

Anti-Bribery and Corruption

LCT adopts a zero-tolerance approach to bribery and corruption in any form and is committed to conducting its business ethically, honestly and in compliance with applicable anti-bribery and corruption laws.

LCT prohibits the offering, promising, giving, soliciting, accepting or receiving of bribes, kickbacks, facilitation payments or other improper payments or benefits. Employees, contractors and third-party service providers acting on behalf of LCT are required to comply with applicable anti-bribery and corruption laws and LCT's internal policies and procedures.

Bribery or corruption, including any suspected conduct of this nature involving LCT or persons acting on its behalf, may be reported through the reporting channels set out in this Whistleblower Policy.