Reporting Bribery and Corruption Concerns
Version: 1.0
29 July 2026
This page provides Tokinvest’s public reporting channels for actual, suspected or possible bribery, corruption and related misconduct. Reports may be made by employees, clients, suppliers, counterparties, business partners or members of the public.
Our commitment
Tokinvest FZCO (“Tokinvest”) is committed to conducting its business honestly, ethically and with integrity.
Tokinvest has a zero-tolerance approach to bribery and corruption. Tokinvest, its Board, Staff, contractors, consultants, agents, suppliers and any other persons acting for or on behalf of Tokinvest must comply with all applicable UAE laws and regulations relating to anti-bribery and corruption, including the applicable Rules and requirements of the Dubai Virtual Assets Regulatory Authority (“VARA”).
Tokinvest prohibits the offering, promising, giving, requesting, agreeing to receive or accepting of any bribe, facilitation payment, kickback or other improper financial or non-financial advantage.
Who can make a report?
Any person may report an actual, suspected or possible incident of bribery or corruption involving:
o Tokinvest;
o Any member of the Tokinvest Board;
o Any Tokinvest employee or member of Staff;
o A contractor, consultant, agent, supplier or business partner acting for or on behalf of Tokinvest; or
o Any person seeking to improperly influence a decision or activity of Tokinvest.
Reports may be submitted by clients, prospective clients, employees, former employees, contractors, suppliers, counterparties, business partners or members of the public.
What should be reported?
You should make a report where you know, believe or reasonably suspect that any of the following has occurred, may be occurring or has been requested:
o The offering, promising, giving, requesting or accepting of a bribe;
o A request for an improper payment, gift, benefit or business advantage;
o A facilitation payment or kickback;
o Improper gifts, entertainment or hospitality;
o Misuse of company funds or assets;
o Undisclosed conflicts of interest connected with an improper advantage;
o Improper payments involving a public official, private individual or commercial organisation;
o Falsification or concealment of records relating to payments, gifts or expenses;
o Retaliation against a person who refused to participate in bribery or corruption;
o Retaliation against a person who raised a concern in good faith; or
o Any other actual or possible violation of applicable anti-bribery and corruption laws or regulations.
You do not need to have complete evidence before making a report. A concern may be reported where it is raised honestly and in good faith on the basis of a reasonable suspicion.
How to make a report
Reports may be submitted through any of the following confidential channels:
Email: [email protected]. Where possible, include “Confidential - Bribery and Corruption Report” in the email subject line.
Telephone: Telephone reports will be directed to, or formally recorded for review by, the Tokinvest Compliance Officer.
Post: Private and Confidential - Chief Compliance Officer, Tokinvest FZCO, Unit No. UT-12-PO-8, DMCC Business Centre, Level 12, Uptown Tower, Dubai, United Arab Emirates.
Other channels: Reports may also be submitted through Tokinvest’s published Whistleblowing reporting channels.
Information to include
To help Tokinvest review the concern, please provide as much information as reasonably possible, including:
o Your name and contact details, unless you wish to remain anonymous;
o A description of the suspected conduct;
o The names and roles of the persons involved;
o Relevant dates, times and locations;
o Details of any payment, gift, hospitality or other advantage involved;
o Details of any witnesses;
o Any supporting documents, messages, emails, invoices or other evidence; and
o Whether the matter has been reported to another person or authority.
A lack of complete information will not prevent Tokinvest from reviewing a genuine concern.
Anonymous reports
A report may be made anonymously.
However, providing a secure method by which Tokinvest can contact you may assist Tokinvest in obtaining additional information and conducting a complete investigation. An anonymous report may limit Tokinvest’s ability to verify or investigate some aspects of the concern.
Confidentiality
Tokinvest will treat the identity of a person making a report, and the information provided, as confidential to the extent permitted by applicable UAE laws and regulations.
Information will only be shared with persons who require access for the purpose of reviewing, investigating, escalating or resolving the reported concern, or where disclosure is required by law, a court, VARA or another competent authority.
Personal data contained in a report will be processed in accordance with applicable UAE data-protection requirements and Tokinvest’s Privacy Policy.
Protection from retaliation
Tokinvest does not tolerate retaliation, victimisation, intimidation, harassment or any other detrimental treatment against a person who:
o Raises a concern honestly and in good faith;
o Refuses to participate in bribery or corruption;
o Assists with an investigation; or
o Provides information relating to a suspected violation.
Any suspected retaliation should be reported immediately through the channels stated above.
Protection does not extend to a person who knowingly submits false or misleading information, acts maliciously or fabricates evidence.
What happens after a report is submitted?
All reports will be reviewed by the Tokinvest Compliance Officer.
Depending on the nature and seriousness of the concern, Tokinvest may:
o Open a formal investigation file;
o Prepare a written record of an oral or telephone report;
o Request additional information;
o Appoint a suitably independent person or external party to conduct an investigation;
o Notify the Tokinvest Board that an investigation has been opened;
o Take appropriate remedial or disciplinary action;
o Report unlawful conduct to VARA or another competent authority; and
o Retain investigation and remediation records in accordance with applicable regulatory requirements.
Investigations will be conducted fairly, objectively and without prejudging the persons involved.
Due to confidentiality, legal and regulatory restrictions, Tokinvest may not always be able to provide the reporting person with detailed information regarding the progress or outcome of an investigation.
Customer complaints and service enquiries
This reporting channel is intended for actual or suspected bribery, corruption and related misconduct.
For a complaint concerning Tokinvest’s services, transactions, account administration or customer service, please use Tokinvest’s Complaints Handling and Resolution Procedure or email [email protected].
General customer-support enquiries should be sent to [email protected].
