General Overview

XBase Virtual Assets Broker & Dealer Services LLC (XBase Digital DED) (“XBase Digital”, “the Firm”) is committed to fostering a culture of transparency, accountability, and ethical business practices by providing a secure and effective whistleblower framework. This policy enables employees, clients, and stakeholders to report misconduct, unethical behaviour, or regulatory violations without fear of retaliation.

The whistleblower mechanism is designed to:

• Provide a confidential and secure reporting system for concerns related to market conduct, financial malpractice, conflicts of interest, or regulatory breaches.
  

• Ensure all reports are investigated fairly and promptly, with appropriate corrective actions taken.
  

• Prevent retaliation against whistleblowers, reinforcing the integrity of the Firm’s corporate governance and compliance practices.
  

• Align with VARA regulations and best industry practices, ensuring adherence to global whistleblower protection standards.
  

Scope and Applicability

This policy applies to all individuals who interact with XBase Digital, including:

• Employees, executives, and Board members, including contractors and third-party service providers.
  

• Clients, vendors, and other stakeholders who wish to report concerns related to the Firm’s activities.
  

This policy covers the reporting of any suspected or actual violations, including but not limited to:

• Regulatory breaches, including insider trading, market manipulation, and best execution failures.
  

• Financial misconduct, fraud, misrepresentation, or misuse of corporate assets.
  

• Conflicts of interest, corruption, bribery, or abuse of power.
  

• Workplace harassment, discrimination, or unethical conduct within the Firm.
  

• Security breaches, unauthorized disclosures, or improper handling of Inside Information.
  

• Any other activity that may damage the Firm’s integrity, reputation, or regulatory standing.
  

Reporting Procedures and Confidentiality

To facilitate the reporting of concerns, XBase Digital provides multiple secure and confidential channels that whistleblowers can use to report issues safely and effectively:

• Dedicated Email: Reports can be submitted via a secure email address compliance@xbase.digital managed by the Compliance Department.
  

• Anonymous Whistleblower Reporting: Whistleblowers can securely submit reports anonymously through a dedicated whistleblowing platform here or by writing to the company’s office address at Office Suite #1804, The Exchange Tower, Al Mustaqbal Street, Business Bay, Dubai, U.A.E.
  

• Direct Reporting to the Compliance Officer: Individuals can report directly to the Head of Compliance or a designated senior officer in person or in writing.
  

XBase Digital ensures that all reports, regardless of the reporting method used, are handled with strict confidentiality. Individuals can choose to report anonymously, and their identity will be protected to the fullest extent permitted by law. Unauthorized disclosure of a whistleblower’s identity without their consent is strictly prohibited, except where legally required.

Submission of Reports

To facilitate efficient investigation and response, whistleblowers should provide as much relevant detail as possible, including:

• A clear description of the concern or violation.
  

• Names of individuals involved, if known.
  

• Dates, times, and locations of incidents, if applicable.
  

• Supporting evidence, such as documents, emails, or transaction details, if available.
  

If a whistleblower wishes to remain anonymous, they may still submit anonymized supporting evidence through secure reporting mechanisms.

Investigation Process

Initial Acknowledgment and Assessment

Once a report is received, the Compliance Department will acknowledge receipt within two (2) business days (if the whistleblower’s contact details are available). If the report was submitted anonymously, a unique case reference number will be provided for tracking the investigation’s progress.

An initial assessment will be conducted to determine whether the reported issue requires a full-scale investigation or if additional information is needed.

Formal Investigation Process

If the report warrants further inquiry, a formal investigation will be initiated by the Compliance Department. The process includes:

• Evidence Collection and Review – A detailed examination of records, communications, financial transactions, and relevant documents will be conducted.
  

• Interviews and Fact-Finding – Key individuals, including those directly or indirectly involved in the reported issue, may be interviewed while maintaining strict confidentiality.
  

• Independent and Objective Assessment – The investigation will be conducted by staff independent of the issue to ensure impartiality.
  

If the reported misconduct involves criminal activity, regulatory breaches, or legal infractions, the case may be escalated to external regulators such as VARA, FIU, law enforcement agencies, or financial oversight bodies.

Resolution and Corrective Actions

Upon completion of the investigation, XBase Digital will determine appropriate corrective actions, which may include:

• Disciplinary actions, such as formal warnings, suspension, or termination of employment.
  

• Process and policy improvements to address systemic risks identified.
  

• Regulatory reporting and legal action for serious violations requiring external intervention.
  

Where possible, and within legal constraints, the whistleblower will be informed of the investigation outcome and any corrective measures taken.

Whistleblower Protection and No Retaliation

XBase Digital maintains a strict zero-tolerance policy against retaliation toward individuals who report misconduct in good faith. Retaliation includes, but is not limited to:

• Termination, demotion, or suspension of the whistleblower.
  

• Threats, harassment, or intimidation aimed at discouraging reports.
  

• Unjustified negative performance reviews or disciplinary actions as a form of retribution.
  

If a whistleblower experiences retaliation, they should immediately report it through the designated reporting channels, and the Firm will take corrective and disciplinary action against responsible parties.

While XBase Digital encourages good faith reporting, false or malicious allegations will not be tolerated. Any individual found to have deliberately made a false report with the intent to harm another party may face disciplinary consequences.

Reporting and Record-Keeping

All whistleblower reports, investigation records, and resolutions will be securely stored and retained for a minimum of eight (8) years. The Compliance Department ensures that:

• Reports remain confidential and are accessible only to authorized personnel handling investigations.
  

• Periodic summaries of whistleblower cases (without disclosing identities) are provided to the Board and Senior Management for governance and compliance oversight.
  

• Regulatory authorities, such as VARA, are provided with whistleblower records upon request for compliance monitoring.
  

Ongoing Review and Monitoring

To ensure the continued effectiveness of the Whistleblower Policy, XBase Digital conducts regular reviews and assessments to identify areas for improvement and ensure compliance with regulatory standards.

The policy is reviewed at least annually or whenever there are:

• Regulatory updates from VARA or other relevant authorities.
  

• Significant changes in business operations, compliance requirements, or risk exposures.
  

• Lessons learned from whistleblower cases requiring policy improvements.
  

As part of the Firm’s broader compliance framework:

• Training on whistleblower protections and reporting mechanisms is provided to all employees to reinforce ethical behaviour.
  

• Periodic audits are conducted to verify that the whistleblower program remains effective, accessible, and confidential.
  

• Employee awareness initiatives ensure that all stakeholders understand their rights and responsibilities regarding misconduct reporting.