Whistleblowing

Last updated: 21/08/2026

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1. Overview
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Scintilla Network FZE (“Scintilla”) operates under a strict zero-tolerance policy regarding bribery, corruption, extortion, and illegal inducements in any form. In accordance with VARA requirements, this stance applies universally to Scintilla’s Board, Management, Staff, and all external business relationships.

Scintilla is committed to maintaining the highest standards of integrity, transparency, and accountability. Employees, clients, and external third parties are strongly encouraged to report any concerns regarding misconduct, market abuse, insider dealing, financial crime, fraud, AML/CFT non-compliance, or regulatory breaches.

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2. Protections for Whistleblowers

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Scintilla strictly prohibits any retaliation against any whistleblower who raises a concern in good faith. Whistleblowers will not:

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* be dismissed, suspended, or disciplined;
* suffer reputational, career, or financial harm;
* be subject to retaliation, harassment, or discrimination by management or peers.

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3. How to Report a Concern

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Whistleblowing reports may be submitted confidentially via:
* Email: compliance@scintillanetwork.com
* Subject: Confidential Whistleblowing Report
* Phone: +971047700495

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Reports may be submitted anonymously. If a whistleblower chooses to disclose their identity, it will be held in strict confidence to the maximum extent permitted by UAE law and VARA regulations.

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4. Handling of Reports & External Escalation Rights

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* Review & Governance: Reports are independently reviewed by the Chief Compliance Officer and, where appropriate, escalated to the Board Risk & Compliance Committee.
* Regulatory Escalation: Material breaches or financial crime issues will be escalated and reported to VARA or other competent law enforcement bodies.
* External Reporting Rights: Nothing in this policy restricts employees, clients, or third parties from reporting suspected misconduct, market abuse, or regulatory violations directly to the Virtual Assets Regulatory Authority (VARA) or other competent UAE authorities.

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5. Contact Us

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For inquiries regarding Scintilla’s Whistleblowing Framework, please contact:

Email: compliance@scintillanetwork.com
Phone: +971047700495

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