Whistleblower Policy

1. INTRODUCTION AND COMMITMENT

At World Golden Gate Virtual Assets Broker & Dealer Services L.L.C (WGG), we believe in doing the right thing—even when no one is watching. We are committed to upholding the highest standards of ethical conduct, transparency, and accountability.

This Whistleblower Policy reflects our commitment to building a culture where speaking up is safe, protected, and encouraged—whether you are an employee, client, contractor, or third-party partner.

2. WHAT IS WHISTLEBLOWING?

Whistleblowing is the act of raising a concern about misconduct, unethical behavior, or legal/regulatory violations, whether observed or suspected. It is a vital part of strengthening governance and preserving market integrity.

3. SCOPE OF PROTECTION

This policy applies to:

• Employees and officers

• Contractors and consultants

• Vendors, clients, and service providers

All are protected when raising concerns in good faith, regardless of the outcome of the investigation.

4. WHO CAN REPORT?

Any individual who has a legitimate concern relating to WGG’s operations, conduct, or employees may submit a whistleblower report. We accept concerns from both internal stakeholders and external parties who interact with our business.

5. WHAT CAN BE REPORTED?

Reports may involve, but are not limited to:

• Violations of UAE law or VARA regulations

• Fraud, embezzlement, or financial crimes

• Insider trading or market manipulation

• Bribery, corruption, or abuse of position

• Breaches of WGG’s internal policies or codes of conduct

• Retaliation or harassment linked to speaking up

If you're unsure whether a situation qualifies—report it anyway. All concerns will be assessed in good faith.

6. HOW TO REPORT A CONCERN

We offer secure and confidential channels for reporting concerns:

Dedicated email: 

• whistleblowing@worldgoldengate.com

• Anonymous online portal https://worldgoldengate.com/whistleblowing

• Confidential Hotline: A dedicated whistleblowing hotline will be established to allow real-time voice reporting +97142941481

• In-person or direct reporting to the Compliance Officer

All reports are handled discreetly and in line with our commitment to protection and fairness.

7. CONFIDENTIALITY AND ANONYMITY

WGG guarantees that:

• Your identity will remain confidential to the fullest extent permitted by law

• You may choose to report anonymously

• Your report will be handled discreetly, without disclosing personal details to uninvolved parties

8. PROTECTION AGAINST RETALIATION

Retaliation of any kind is strictly prohibited. WGG does not tolerate:

• Harassment, demotion, or dismissal linked to a report

• Blacklisting or career-related harm

• Intimidation or adverse treatment

Anyone found retaliating will be subject to internal disciplinary action and possible regulatory referral.

9. INVESTIGATION AND REMEDIAL ACTION

All concerns are reviewed by our Compliance team and, if necessary, escalated to a specialized committee. Depending on the case:

• Investigations will be conducted with fairness and neutrality

• Findings may lead to corrective measures, including disciplinary action or regulatory reporting

• Whistleblowers will be informed of the outcome when legally possible

WGG aims to address all cases within 30 days, with extensions where justified.

10. REGULATORY ALIGNMENT

This policy aligns with:

• Dubai VARA rulebooks (Compliance & Risk Management, Market Conduct)

• UAE Labor Law

• CBUAE and UAE FIU compliance frameworks

• Whistleblower protections under UAE Penal Code

Our protocols ensure that reports are recorded, stored, and protected for a minimum of eight (8) years, supporting both internal integrity and regulatory oversight.

11. TRAINING AND AWARENESS

WGG fosters a speak-up culture through:

• Mandatory annual training for all staff

• Specialized training for leadership and investigators

• Quarterly awareness campaigns that reinforce openness, ethical behavior, and zero tolerance for retaliation

12. OUR SPEAK-UP CULTURE

At WGG, speaking up is not just allowed—it is respected and protected. We believe that a healthy, compliant, and ethical workplace is built on courageous conversations and transparent action.

We encourage everyone—internally and externally—to help us uphold our standards by reporting concerns honestly and safely.

13. DISCLAIMER

This Whistleblower Policy Summary is provided for transparency purposes and does not replace WGG’s internal whistleblower protocols or investigation procedures. For regulatory bodies or stakeholders requiring more information, please contact compliance@worldgoldengate.com