Whistleblowing

Whistleblowing

Date: 25 October 2025

Version: 1.0

Commitment to Ethical Conduct and Transparency

At Nova Digital FZE (“Nova Digital”), integrity and transparency are central to how we operate. We are committed to fostering a workplace culture built on openness, accountability, and ethical behaviour in every aspect of our business.

We believe that maintaining a culture of honesty and responsible conduct is essential to preserving the trust of our clients, investors, regulators, and employees. To uphold these principles, Nova Digital has adopted a Whistleblowing Policy that enables individuals to report any concerns or suspicions of wrongdoing safely and without fear of retaliation.

Promoting a Speak-Up Culture

Nova Digital encourages all employees, contractors, business partners, and other stakeholders to raise concerns relating to misconduct, unethical behaviour, or breaches of law or regulation.

  • Matters that should be reported may include (but are not limited to):

  • Fraud, financial irregularities, or accounting manipulation

  • Corruption, bribery, or abuse of authority

  • Conflicts of interest or misuse of confidential information

  • Harassment, discrimination, or other workplace misconduct

  • Non-compliance with internal policies, laws, or regulatory requirements

Reports may be made openly, confidentially, or anonymously. While providing one’s name often helps in ensuring a more thorough investigation, Nova Digital recognises that anonymity may be necessary in some circumstances. In all cases, sufficient information should be provided to allow a proper and fair review.

Protection and Confidentiality

Nova Digital maintains a zero-tolerance approach to retaliation. Anyone who raises a concern in good faith is protected from dismissal, discrimination, harassment, or any form of adverse treatment as a result of their disclosure.

The identity of the whistleblower, and any information that could reasonably identify them, will be treated as strictly confidential. All reports are reviewed discreetly and investigated impartially by authorised Compliance or Risk personnel.

Where misconduct is substantiated, appropriate corrective, disciplinary, or remedial action will be taken. Anonymous disclosures will only lead to findings where corroborating evidence can be obtained through an independent investigation.

How to Report a Concern

Nova Digital provides secure and confidential channels for submitting whistleblowing reports:

  • By completing our Whistleblowing Form; or

  • By emailing us directly at whistleblowing@novadigital.xyz

All reports are reviewed by the Compliance Officer or another designated senior officer independent of the matter raised. Every report will be logged, assessed, and escalated appropriately to ensure a fair and professional resolution.

Our Assurance

At Nova Digital, we value the courage of individuals who speak up in good faith. Whistleblowers play a vital role in safeguarding our ethical standards and ensuring regulatory compliance.

We are committed to listening, protecting, and acting on concerns responsibly strengthening our integrity as a trusted investment management firm and contributing to a transparent and accountable organisation.

Date: 25 October 2025

Version: 1.0

Commitment to Ethical Conduct and Transparency

At Nova Digital FZE (“Nova Digital”), integrity and transparency are central to how we operate. We are committed to fostering a workplace culture built on openness, accountability, and ethical behaviour in every aspect of our business.

We believe that maintaining a culture of honesty and responsible conduct is essential to preserving the trust of our clients, investors, regulators, and employees. To uphold these principles, Nova Digital has adopted a Whistleblowing Policy that enables individuals to report any concerns or suspicions of wrongdoing safely and without fear of retaliation.

Promoting a Speak-Up Culture

Nova Digital encourages all employees, contractors, business partners, and other stakeholders to raise concerns relating to misconduct, unethical behaviour, or breaches of law or regulation.

  • Matters that should be reported may include (but are not limited to):

  • Fraud, financial irregularities, or accounting manipulation

  • Corruption, bribery, or abuse of authority

  • Conflicts of interest or misuse of confidential information

  • Harassment, discrimination, or other workplace misconduct

  • Non-compliance with internal policies, laws, or regulatory requirements

Reports may be made openly, confidentially, or anonymously. While providing one’s name often helps in ensuring a more thorough investigation, Nova Digital recognises that anonymity may be necessary in some circumstances. In all cases, sufficient information should be provided to allow a proper and fair review.

Protection and Confidentiality

Nova Digital maintains a zero-tolerance approach to retaliation. Anyone who raises a concern in good faith is protected from dismissal, discrimination, harassment, or any form of adverse treatment as a result of their disclosure.

The identity of the whistleblower, and any information that could reasonably identify them, will be treated as strictly confidential. All reports are reviewed discreetly and investigated impartially by authorised Compliance or Risk personnel.

Where misconduct is substantiated, appropriate corrective, disciplinary, or remedial action will be taken. Anonymous disclosures will only lead to findings where corroborating evidence can be obtained through an independent investigation.

How to Report a Concern

Nova Digital provides secure and confidential channels for submitting whistleblowing reports:

  • By completing our Whistleblowing Form; or

  • By emailing us directly at whistleblowing@novadigital.xyz

All reports are reviewed by the Compliance Officer or another designated senior officer independent of the matter raised. Every report will be logged, assessed, and escalated appropriately to ensure a fair and professional resolution.

Our Assurance

At Nova Digital, we value the courage of individuals who speak up in good faith. Whistleblowers play a vital role in safeguarding our ethical standards and ensuring regulatory compliance.

We are committed to listening, protecting, and acting on concerns responsibly strengthening our integrity as a trusted investment management firm and contributing to a transparent and accountable organisation.