Whistleblowing Policy

Nas Tec Pte. Ltd. and its affiliated entities (collectively, “Kyber”, “we”, “us” or “our”) are committed to maintaining the highest standards of integrity, transparency, and ethical conduct across all our operations.

This Whistleblowing Policy provides a framework for employees, partners, and stakeholders to report concerns relating to misconduct, malpractice, or unethical behaviour in a safe and confidential manner.

1. Purpose of this policy

1.1 This Policy aims to:

1.1.1 encourage the timely reporting of misconduct or irregularities;
1.1.2 provide a safe and confidential channel for raising concerns without fear of retaliation;
1.1.3 ensure that all reported matters are reviewed, investigated, and addressed appropriately;
1.1.4 uphold accountability, transparency, and ethical business practices; and
1.1.5 protect the interests and integrity of Kyber and its stakeholders.

2. Scope of reportable matters

2.1 This Policy applies to, but is not limited to, concerns relating to:

2.1.1 fraud, corruption, or dishonest practices;
2.1.2 violation of laws, regulations, or internal policies;
2.1.3 financial misconduct or irregularities;
2.1.4 conflicts of interest;
2.1.5 unethical or improper business conduct;
2.1.6 harassment, discrimination, or workplace misconduct; and
2.1.7 any action that may harm the reputation or operations of Kyber.

3. Who can report

3.1 Reports may be made by:

3.1.1 employees (current or former);
3.1.2 contractors, consultants, or service providers;
3.1.3 business partners and vendors;
3.1.4 clients and customers; and
3.1.5 any other stakeholder interacting with Kyber.

4. Reporting channels

4.1 Reports may be submitted through the following channels:
Email: whistleblow@kyber-commerce.com
Address: TEC Capital Square, 23 Church Street, Unit 760-65, 7th Floor, Singapore 049481
Hotlineline: (+65) 8805 3653
4.2 Reports should, where possible, include:

4.2.1 a description of the incident or concern;
4.2.2 relevant dates, locations, and individuals involved;
4.2.3 any supporting evidence or documentation; and
4.2.4 contact information (optional, if the whistleblower wishes to remain anonymous)

5. Confidentiality and protection

5.1 Kyber is committed to protecting the identity of whistleblowers.
5.2 All reports will be treated with strict confidentiality, subject to the need to conduct a proper investigation and comply with legal obligations.
5.3 We do not tolerate retaliation against any individual who reports a concern in good faith.
5.4 Any act of retaliation will be treated as a serious violation and may result in disciplinary action.

6. Investigation process

6.1 All reports will be reviewed by the Compliance function or designated responsible parties.
6.2 Depending on the nature of the concern, the investigation may involve:

6.2.1 Compliance Department;
6.2.2 Senior Management (including the General Manager or CEO);
6.2.3 External auditors or professional advisors; and/or
6.2.4 relevant authorities, where required by law.

6.3 Further information may be requested from the whistleblower where necessary.
6.4 Upon completion of the investigation, appropriate actions will be taken based on the findings.

7. Handling and outcome

7.1 Kyber will assess each report objectively and take appropriate corrective or disciplinary actions where necessary.
7.2 Where appropriate, the whistleblower may be informed of the outcome, subject to confidentiality and legal considerations.

8. Anonymous reporting

8.1 Reports may be made anonymously.
8.2 However, providing contact details may assist in facilitating a more effective investigation.

9. False or malicious reports

9.1 Reports should be made in good faith.
9.2 Any knowingly false or malicious allegations may result in disciplinary action.

10. Policy review

10.1 Kyber reserves the right to update or amend this Policy at any time.
10.2 Updates will be published on our website.

11. Contact

11.1 For any questions regarding this Policy, please contact: whistleblow@kyber-commerce.com