Last updated: 27/09/2025

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1. Overview

Scintilla Network FZE (“Scintilla”) is committed to the highest standards of integrity and accountability. Employees, clients, and third parties are encouraged to report any concerns about misconduct, regulatory breaches, or unethical behaviour.

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2. Protections for Whistleblowers

No whistleblower will suffer detriment for raising a concern in good faith. Specifically, whistleblowers will not:

• be dismissed or disciplined;

• suffer reputational or financial harm;

• be subject to retaliation, harassment, or discrimination.

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3. How to Report a Concern

Whistleblowing reports may be submitted confidentially via:

• Email: contactus@scintillanetwork.com

• Phone: +971 (0)4 770 0495

Reports may also be made anonymously.

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4. Handling of Reports

• Reports are reviewed by the Compliance Officer.

• Where necessary, matters are escalated to the Audit, Risk and Compliance Committee.

• Material breaches are reported to VARA or other regulators as required.

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5. Contact Us

For details on Scintilla’s Whistleblowing Policy, please email: contactus@scintillanetwork.com

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