Updated on: 01 August 2025
Version
Effective Date
Prepared By
Reviewed By
Remarks/Updates
V1
July 2025
Lexim Trading DMCC
Compliance Officer
Published on the website.
1.1 Lexim is committed to conducting its business with the highest ethics, integrity, and compliance standards. As part of this commitment, we encourage all employees, contractors, and stakeholders to report any known or suspected violations of laws, regulations, internal policies, or unethical conduct within Lexim. This Whistleblowing Policy is designed to provide a framework for individuals to report such concerns and protect them from retaliation.
1.2 All employees have the responsibility to report behaviour that violates this Policy and applicable laws via appropriate channels.
1.3 Any Lexim employee or Board member who realises or suspects that any parties are participating in activities that are inappropriate or contrary to our standards and policies is encouraged to report all suspected criminal or unethical conduct. Lexim treats all reports confidentially, consistently, fairly and in a timely manner.
2.1 Lexim has established, maintained, and published on its website, methods of contact, including but not limited to a telephone line, email address, or mailing address, for receiving reports of any violation or possible violation of any applicable laws and regulations relevant to anti-bribery and corruption by Lexim, its Board, or staff on its behalf.
2.2 This may be done either in person or anonymously:
(a) Concerned Individuals:
i. Line Manager; and/or
ii. Head of Human Resources
(b) Lexim's Email Address for Reporting: compliance@lexim.digital or hr@lexim.digital.
(c) Lexim's Mailing Address for Reporting: Lexim Trading DMCC, Mazaya Business Avenue 2201, Tower AA1, First Al Khail St Jumeirah Lake Towers, Dubai, United Arab Emirates.
(d) Lexim's Contact Number for Reporting: +971 (0)4 375 1987.
2.3 Individuals may choose to report concerns anonymously. To facilitate this, Lexim has established a confidential reporting channel through which whistleblowers can report their concerns without revealing their identities. The anonymous reporting can be made via and anonymous e-mail to compliance@lexim.gold or hr@lexim.gold.
2.4 Without forced preference, Lexim also encourages staff and Board members to report concerns directly to their supervisor, manager, or the designated whistleblower officer. Non-anonymous reporting may allow for a more efficient investigation and follow-up process.
2.5 The Whistleblowing channel shall be used to report any of these concerns related to, but not limited to, the following areas:
(a) Insider trading/profiting from material non-public information;
(b) Money laundering or financing of illegal activities;
(c) Conflicts of interest or abuse of authority;
(d) Cybersecurity breaches or data privacy breaches;
(e) Violations of applicable laws, regulations, or industry standards;
(f) Corruption or bribery;
(g) Fraud, theft, embezzlement, misappropriation of company funds or assets;
(h) Harassment, discrimination or retaliation;
(i) Unethical, improper, illegal behaviour or conduct;
(j) Health and safety violations; and
(k) Environmental violations.
3.1 Any report of suspicious conduct will be treated as confidential, and no employee will be threatened and/or retaliated for refusing to commit a bribery offence or raising a concern or report in good faith. All employees in such scenarios are protected from suffering any detriment, loss of employment or victimisation.
3.2 This Policy allows for reports to be made by entities outside of Lexim and ensures the protection of identity and confidentiality of the entity who has made a report at all times.
3.3 Any form of retaliation, including but not limited to adverse employment actions, threats, harassment, or discrimination, against a whistleblower will be treated as a serious violation of this Policy and may result in disciplinary action, including termination of employment and potentially further legal action.
4.1 Whistleblowers are encouraged to provide as much detail as possible when submitting their concerns, including specific incidents, individuals involved, dates, and supporting evidence. Anonymous whistleblowers are encouraged to provide sufficient information to enable proper investigation.
4.2 Upon receiving a report, the designated whistleblower officer or an appropriate representative of the compliance team will review and evaluate the concern. An internal investigation will be conducted to gather facts and evidence if necessary. The investigation will be handled promptly, impartially, and with due regard to all parties' rights.
4.3 Where possible, whistleblowers will be provided with an acknowledgement of receipt of their report. While maintaining confidentiality, whistleblowers may be contacted for additional information or clarification during the investigation process. After the investigation is completed, Lexim will take appropriate action based on the findings and communicate the outcome, where permitted, to the whistleblower.
5.1 Lexim will maintain adequate records of all whistleblower reports, investigations, and actions taken, ensuring the confidentiality and security of such records in accordance with applicable laws and regulations.
6.1 Lexim will provide Whistleblowing Policy training and awareness programs to all employees, contractors, and stakeholders to ensure understanding of the Whistleblowing Policy and its importance in maintaining a culture of integrity and compliance. This training forms part of the induction and onboarding programme made available to all new Board members and staff. All new employees joining Lexim are required to certify that they have read and understood this Policy. On an ongoing basis, Lexim's employees will receive regular training regarding their obligations under this Policy.
7.1 This Whistleblowing Policy is in addition to and does not replace any other reporting channels or legal rights that may be available to individuals under applicable laws and regulations.
8.1 As an integral part of the ABC Policy, this Whistleblowing Policy will be periodically reviewed and updated by CO as necessary to ensure its effectiveness and compliance with changes in laws and regulations.
9.1 For any inquiries or clarifications under this Whistleblowing Policy, please contact the Compliance Officer.
