Legal

Whistle-Blowing Policy

X12 Capital Ltd ("X12") is committed to the highest standards of integrity and regulatory compliance. Our Whistleblowing Policy provides a secure and confidential framework for reporting concerns about wrongdoing, misconduct, or regulatory breaches. A summary of the Policy follows:

Our Commitment

We are committed to the highest standards of integrity and transparency. If you see something wrong — such as fraud, misconduct, or a breach of our policies — we want you to feel safe speaking up.

What Can You Report?

You can report any concerns about:

  • Fraud or financial crime
  • Breaches of laws, regulations, or company policies
  • Health and safety risks
  • Misconduct or mismanagement
  • Attempts to conceal any of the above

Your Protection

  • Your identity will be kept confidential wherever possible
  • We strictly prohibit retaliation against anyone who reports a concern in good faith. We actively monitor to ensure whistleblowers do not suffer any detriment

How to Report

You can report concerns confidentially or anonymously through any of these channels:

  • Phone / SMS: +971 (0)52 799 2154
  • Email: compliance@x12capital.com
  • Internal Auditor: info@x12capital.com
  • FSRA: +971 2 333 8955 (anonymous whistleblowing phone line)
  • FSRA online: AMANAH Portal - Speak Up and Whistleblowing Channel | ADGM

Reports can be made anonymously. We guarantee confidentiality and enforce strict non-retaliation measures.

What Happens Next

  • We confirm receipt of your report
  • We follow a structured process:
    1. Secure evidence and maintain confidentiality
    2. Interview relevant personnel
    3. Escalate serious matters to senior management and the Board
  • We keep you informed where appropriate and take corrective action

Independent Oversight

If your report involves senior management or compliance staff, an independent external reviewer will oversee the investigation.

Regular Review

Our whistleblowing arrangements are reviewed by our Internal Auditor and external experts to ensure effectiveness and compliance with FSRA requirements.

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