Whistleblowing Policy

Purpose

The objective of this RIV Technologies FZE (“RIV Technologies” or the “Company”) Whistleblowing Policy is to ensure that any whistleblowers are guaranteed to have safe, secure, and reliable avenues to report any suspicious activities without fear of any repercussion.

Applicability

This policy applies to all employees (whether full time, part time, temporary, interns, secondees, or any other position within the Company), officers, senior management, and directors of RIV Technologies, as well as to any third parties who deal with RIV Technologies, including, but not limited to, customers and suppliers.

Implementation

RIV Technologies’ compliance officer is responsible for:

(i) overseeing the management and implementation of, and compliance with, this policy;

(ii) communicating with relevant employees, departments, and third parties (including VARA) as necessary;

(iii) managing the investigation process of any whistleblowing reports received under this policy;

(iv) taking the necessary action in case evidence of any criminal activity is uncovered pursuant to any investigation;

(v) taking the necessary action in case a RIV Technologies employee is found to have violated this policy; and

(vi) reviewing this policy annually to update it as needed.

Whistleblowing Cases

The following suspicious activities may be reported pursuant to this policy:

a. Money Laundering

Money Laundering is the illegal process of “laundering” money generated by criminal activities appear to come from a “clean” source.

b. Fraud

Fraud is the illegal process of intentionally using deception and other misconduct to generally steal funds from another person or cause that other person to suffer loss.

c. Bribery

Bribery is the illegal process of paying money to a third party as a form of “kickback” to ensure a certain benefit or course of action for the briber by the bribee.

Whistleblower Protection

RIV Technologies is committed to ensuring the protection and full confidentiality of any whistleblowers who come forth pursuant to the reporting mechanisms outlined under this policy. Any such whistleblowers will have the following protections:

(i) Protection from disclosure of identity and location;

(ii) Protection from litigation against the whistleblower for any disclosure of confidential information, as long as the disclosure related to the whistleblowing report is true and genuine; and

(iii) Protection, to the maximum extent possible, from any bias or retaliative acts from the persons who are mentioned in the whistleblowing report.

Whistleblowing Reporting Procedure

Whistleblowers may report their concerns via any of the following channels:

(i) Email: please email RIV Technologies’ compliance officer at co@riv-technologies.com.

(ii) Phone: please call us at +971 4 526 4960.

(iii) Post: please mail your concerns and findings, marked for the attention of the “Compliance Officer”, to RIV Technologies FZE, The Offices 3 – One Central, Dubai World Trade Centre, Dubai, UAE.

Whichever channel you use, all concerns must be accompanied with adequate supporting evidence to support the claims which you are making. We will investigate all credible concerns and reports which are properly substantiated with supporting evidence. The more information you provide, the easier and faster it will be for us to complete our investigation process. If a false or unsubstantiated report is made for any reason, we may investigate the person making the report, which, in the case of employees, can result in disciplinary action.

If you are a RIV Technologies employee, you may discuss your concerns with your line manager in person or in writing. If you are uncomfortable doing so, you may discuss with another RIV Technologies manager. The matter should then be immediately referred to RIV Technologies’ compliance officer by the manager who received the report.

Investigation Process

RIV Technologies is committed to treating all whistleblowers and individuals involved in a whistleblowing investigation in fair and just manner.

The internal investigation process will consist of the following steps:

1. Reporting

The process begins when an employee or external stakeholder reports a suspected wrongdoing or unethical conduct. Reports can be made anonymously, and the whistleblower will be assured of confidentiality and protection from retaliation.

2. Acknowledgement:

Once a report is received, an acknowledgment is sent to the whistleblower, ensuring them that the report will be investigated promptly and thoroughly.

3. Initial Assessment:

A preliminary assessment is conducted to determine the credibility and significance of the report. If the report is found to be unsubstantiated or not in violation of any laws or policies, the investigation may be concluded at this stage.

4. Detailed Investigation

A detailed investigation will be conducted, gathering all relevant facts, documents, and evidence. The investigation may involve interviewing the whistleblower, the accused party and any potential witness.

All findings, evidence and interviews will be meticulously documented, to maintain the integrity of the investigation process.

5. Conclusion

Upon completion of the investigation process, the investigator formulates a conclusion based on the evidence collected and makes recommendations for corrective actions, disciplinary measures or policy changes, as appropriate.

Contact Us

If you have any questions or concerns regarding this policy, please contact us by sending an email to the RIV Technologies Compliance Officer at: co@riv-technologies.com.

ABAC Policy

Complaints Policy

Whistleblowing Policy

Conflicts Of Interest Policy

Regulatory Compliance Disclosure