WHISTLEBLOWING POLICY (PUBLIC NOTICE)

1. Our commitment
Cloverum Finance (CY) Limited (the “Company”, “Cloverum”, “we”, “us” or “our”) is committed to integrity, transparency and compliance. We encourage the reporting of genuine concerns about wrongdoing, misconduct, breaches of law or regulatory obligations, or other serious issues connected with the Company. We support an open workplace where individuals feel safe to report concerns in good faith without fear of retaliation. All reports will be treated confidentially and investigated appropriately.
2. Purpose of this public notice
This public Whistleblowing Policy explains how you can submit a whistleblowing report and how the Company will handle it. It is based on and aligned with the Company’s internal Whistleblowing Policy approved for regulatory purposes, and is intended to be made available via the Cloverum website.
This notice is designed for transparency and accessibility. It does not replace any applicable legal rights and obligations under the EU Whistleblower Protection Directive (EU) 2019/1937 and the Cyprus implementing law (Law L. 6(I)/2022), as amended from time to time, and any other applicable laws and regulations.
3. Scope — who can make a report
This Policy applies to any person who wishes to report a concern connected with the Company, including (as applicable) employees, contractors, consultants, interns, temporary staff, members of the board of directors, shareholders, clients, and other third parties engaged with the Company, whether current, past or prospective.
Reports should be made in good faith and in the public interest.
4. What is whistleblowing
Whistleblowing refers to reporting or disclosing information about illegal or unethical activities occurring within or connected to the Company. This includes reporting concerns about conduct that may be unlawful, improper, unethical, or contrary to regulatory obligations or the Company’s internal policies.
5. What you can report
You may report any concern that you reasonably believe relates to wrongdoing connected with the Company, including (non-exhaustive examples):
• Criminal offences or suspected criminal activity.
• Breaches of legal or regulatory obligations (including requirements applicable to regulated crypto-asset service providers).
• Fraud, corruption, bribery, financial misconduct or misappropriation.
• Risks to health and safety.
• Environmental damage.
• Data protection, confidentiality or cybersecurity breaches.
• Deliberate concealment of any of the above.
If you are unsure whether a matter qualifies as whistleblowing, you may still submit a report and we will assess it.
6. How to report a concern
To submit a whistleblowing report, please use the Whistleblowing Complaint Form (see Appendix A) and send it to:
Email (designated whistleblowing channel): [email protected]
This email address is accessed by the Company’s MLRO and at least one member of the Board of Directors. If the concern relates to the Compliance Officer, it will be treated by the Board directly.
7. What happens after you report
All whistleblowing reports are assessed to determine appropriate investigation steps, which may include an internal review and/or an external review where necessary. The Compliance Officer (or another designated investigator) will review the report, gather relevant information, and determine next steps.
We will handle the whistleblowing process within the timeframes specified by applicable law. Where the reporter has provided contact details (and subject to confidentiality and legal restrictions), we will provide information on the progress and/or outcome of the investigation.
1. Non-whistleblowing complaints
If your submission does not relate to whistleblowing (for example, a customer service complaint, a commercial dispute, or an HR grievance), it may be redirected to the appropriate procedure (e.g., Complaints Handling Procedure, HR process), or we may ask you to resubmit via the relevant channel.
8. Confidentiality, anonymity and protection
1. Protection against retaliation
The Company prohibits any form of retaliation against a person who reports concerns in good faith. Retaliation may include (non-exhaustive):
• Dismissal or termination of a contract;
• Demotion, suspension, or transfer to a less favorable role;
• Negative performance reviews or denial of promotion;
• Reduction of salary, benefits, or entitlements;
• Harassment, bullying, or intimidation in the workplace;
• Blacklisting or reputational harm.
Any employee engaging in retaliation will face disciplinary action, up to and including termination of employment.
2. Confidentiality
The identity of the whistleblower will be kept strictly confidential and disclosed only to those who need to know in order to investigate the concern. Information will not be shared outside the investigation process unless required by law or regulatory obligation. All reports will be securely stored and access restricted to authorized personnel only.
3. Anonymity
You may submit a concern anonymously. Where anonymity is chosen, the Company will investigate based on the available information, though anonymity may limit our ability to request clarifications or provide feedback.
4. Support and assistance
Whistleblowers will be provided with guidance on how their disclosure will be handled. The Compliance Officer acts as a designated contact point (where the whistleblower provides contact details), offering updates and support during the investigation. Where necessary, the Company may provide access to HR or external support services to support wellbeing.
9. Escalation and external reporting
If you feel your concern has not been handled appropriately, you may escalate the matter directly to the Board of Directors or to the Cyprus Securities and Exchange Commission (“CySEC”) as the competent authority, or to other regulators/authorities as applicable, without facing reprisal.
1. CySEC external reporting channels (informational)
CySEC publishes dedicated whistleblowing channels and may accept reports by name or anonymously. Please verify the latest details on CySEC’s official website. As of the most recently published CySEC materials, channels may include:
• Email: [email protected]
• Phone: +357 22 506 750
• Postal address: 19 Diagorou Str. 1097, Nicosia, Cyprus “for the attention of the Department of Market Surveillance and Investigations”
• External disclosure form: the “Whistleblowing External Disclosure Form”, found in Appendix A of CySEC Circular C177, to be submitted in electronic or paper format to the Department of Market Surveillance and Investigations of CySEC via the above email or postal address.
10. Monitoring and assurance
The Compliance Officer maintains a log of whistleblowing reports and monitors for any signs of retaliation, for a period of time to be determined by the Compliance Officer. The Board of Directors receives an annual report on whistleblowing cases, including details of protective measures taken. The Company reviews its whistleblowing framework periodically to ensure its effectiveness.
11. Contact
If you wish to submit a whistleblowing report, please use the designated channel: [email protected].
For general customer service complaints, please use the channels listed in our Complaints Handling Procedure available in the Cloverum website.