Whistleblower Policy

Effective Date: 26 March 2025

1. Purpose

Huobi is committed to the highest standards of integrity, transparency, and accountability. This Whistleblower Policy aims to encourage and protect individuals who wish to report concerns regarding misconduct, unlawful activity, or breaches of company policies within Hotcoin, without fear of retaliation.

2. Scope

This policy applies to all employees, contractors, consultants, interns, suppliers, and third parties associated with Huobi.

It covers concerns relating to (but not limited to):

Fraud, bribery, or corruption

Criminal offences or unlawful conduct

Breaches of legal or regulatory obligations

Health and safety risks

Environmental damage

Misuse of company resources

Serious breaches of internal policies

Attempts to conceal any of the above

3. What Is Whistleblowing?

Whistleblowing is the act of reporting suspected wrongdoing or dangers in connection with workplace activities. A whistleblower is someone who raises a concern in the public interest.

Personal grievances that do not affect the wider public interest should generally be addressed through the grievance procedure, not this policy.

4. Raising a Concern

Concerns can be raised verbally or in writing. You may choose to remain anonymous, although doing so may limit our ability to investigate the matter fully.

To raise a concern, contact:

Whistleblowing Officer

Email: huobihtxi@gmail.com

Tel: [Insert confidential hotline if available]

Address: [Insert secure correspondence address]

You may also speak to your manager, a member of senior management, or the HR department.

5. Confidentiality and Anonymity

All concerns raised will be treated in strict confidence. Where requested, every effort will be made to protect the identity of the whistleblower, unless disclosure is required by law or is necessary for a fair investigation.

6. Investigation Process

Once a concern is raised:

An acknowledgement will be sent within 5 business days.

A preliminary review will be conducted.

If appropriate, a formal investigation will follow.

Findings will be documented and acted on.

Feedback will be shared where possible.

7. Protection Against Retaliation

Huobi strictly prohibits retaliation against any individual who raises a concern in good faith. Retaliation will be treated as a serious disciplinary offence.

8. False Allegations

Deliberately false or malicious allegations may result in disciplinary action. However, genuine concerns raised in good faith will be respected and protected.

9. External Reporting

Where appropriate, concerns may be raised with regulatory bodies such as:

The Financial Conduct Authority (FCA)

The Health and Safety Executive (HSE)

The Information Commissioner's Office (ICO)

An independent legal advisor

Employees have the right to approach such bodies under the UK Public Interest Disclosure Act 1998.

10. Monitoring and Review

This policy is reviewed annually and may be updated to reflect legal or business changes.