Whistleblowing Policy
Commitment to integrity and transparency
At Hubpay Limited ("Hubpay"), we are committed to upholding the highest standards of integrity, transparency, and ethical conduct across all areas of our operations. We foster a culture of accountability and compliance, encouraging all employees, stakeholders, and business partners to adhere to the principles that define our organisation.
Maintaining an open and ethical environment is vital to our success and to maintaining the trust of our clients, employees, regulators, and partners. To support this, we have implemented a comprehensive Whistleblowing Policy that enables the reporting of any suspected misconduct, unethical behaviour, or regulatory violations. This page summarizes that policy, which is approved by our Board of Directors and reviewed at least annually.
Encouraging transparency and reporting misconduct Hubpay actively encourages all employees, contractors, vendors, clients, and other stakeholders to report concerns or suspected wrongdoing, including but not limited to:
Fraud, financial misconduct, or breaches of regulatory obligations
Bribery, corruption, or conflicts of interest
Market abuse, manipulation, or insider dealing
Misselling, unfair treatment of customers, or other consumer harm
Danger to the health or safety of any individual
Harassment, discrimination, or other unethical workplace behaviour, where connected to a reportable concern
Non-compliance with internal policies, procedures, or legal requirements
Deliberate concealment of any of the above
Personal grievances, workplace complaints unconnected to a reportable concern, and customer complaints are handled through our separate HR and customer complaints procedures. If you wish to report suspicious activity affecting your account or a transaction such as fraud, unauthorized activity, or attempted money laundering by a third party please use our Report suspicious activity form instead. This whistleblowing channel is for concerns about Hubpay's own conduct, or the conduct of its people.
Reports may be made openly, confidentially, or anonymously. While we encourage open or confidential reporting to facilitate effective investigation and remediation, we also recognize that some individuals may prefer to report anonymously. If you wish to remain anonymous, please email us from a personal (non-work) address rather than your Hubpay address. You are not required to gather evidence before reporting simply set out the facts as you understand them, in as much detail as you can, together with your suspicions.
Protection and confidentiality for Whistleblowers
Hubpay has a strict zero-tolerance policy against retaliation. Any individual who reports a concern in good faith is protected from adverse action, discrimination, harassment, or retribution, whether or not the concern is ultimately substantiated. Protection extends to anyone who assists you in making a report, and to colleagues or family members who may be affected. It covers not only your identity but any identifying information that could indirectly reveal it, recognising that certain facts may act as a "signature".
All concerns will be treated with the highest degree of confidentiality and sensitivity. Your identity will not be disclosed without your consent, except where disclosure is required by law or regulatory obligation, necessary for legal proceedings, or necessary to prevent serious harm to an individual and even then, only to the minimum extent necessary, and we will tell you in advance wherever possible. Investigations will be conducted thoroughly, fairly, and impartially, and where misconduct is substantiated, appropriate corrective and disciplinary actions will be taken. Anonymous reports are assessed on their merits and are not treated as inherently less credible; as with any report, a final finding of misconduct will be reached only where the allegations are corroborated by the evidence gathered during investigation.
If you believe you have suffered retaliation for raising a concern, tell us immediately using the same email address below, marking your message "retaliation concern". It will be routed to a senior manager independent of your report, and, where appropriate, escalated to our Chief Risk Officer or CEO.
Reporting channels
Hubpay provides secure and confidential channels for whistleblowers to raise concerns safely. If you suspect wrongdoing, unethical behaviour, or regulatory non-compliance, you can report your concerns securely via Email at: [email protected]. All concerns will be escalated appropriately and handled by our designated Whistleblower Receiving Officer to ensure a professional and impartial review.You are not required to use this channel in order to be protected. A concern raised with any Hubpay director, officer or manager is equally capable of being treated as a protected disclosure. Anyone who receives a concern in this way is required to escalate it to the Whistleblower Receiving Officer and must not investigate it informally.
You may also raise your concern directly with the relevant authorities including the ADGM Financial Services Regulatory Authority (FSRA) and the ADGM Registration Authority without first reporting it to us, and doing so does not affect the protections available to you.
At Hubpay, we value and appreciate the essential role whistleblowers play in safeguarding our organisation's ethical foundation. Your voice helps protect our integrity, ensure regulatory compliance, and build a stronger, more transparent future.
Report-suspicious-activity: https://hubpay.io/report-suspicious-activity This form is for reporting suspicious activity affecting your account or a transaction for example fraud, unauthorised activity, or attempted money laundering.
If your concern relates to misconduct, unethical behavior or regulatory non-compliance by Hubpay or its people, please use our page https://hubpay.io/whistleblowing , which supports confidential and anonymous reporting