Whistleblowing Policy

This Whistleblowing Policy is published pursuant to Rule II.B.1(b) of the VARA Exchange Services Rulebook and Rule I.B.1(b) of the VARA Broker-Dealer Services Rulebook

1. Introduction

Rain MENA FZE (the "Company") is committed to conducting its business with honesty and integrity. The Company expects all persons associated with it to maintain high standards of ethical conduct. Any suspected wrongdoing or breach of applicable laws or standards should be reported as soon as possible.

This policy applies to all persons who wish to raise the type of concern covered by it, including:

• All employees, officers, consultants, contractors, and interns of the Company; and
• Any external party, including clients, counterparties, suppliers, and members of the public, who wishes to report a concern relating to the Company's activities.

2. Policy Objectives

The aims of this policy are to:

• Encourage all persons to report suspected wrongdoing as soon as possible;
• Provide clear guidance on how concerns may be raised;
• Ensure that persons who raise genuine concerns are protected from retaliation, even where those concerns turn out to be mistaken; and
• Ensure that the Company can identify and address any wrongdoing promptly and effectively.

3. What Should Be Reported

This policy covers the reporting of suspected wrongdoing or dangers in connection with the Company's business. This may include (without limitation):

• Criminal activity;
• Misappropriation of the Company's assets or clients' assets;
• Financial fraud or mismanagement;
• Money laundering or the financing of terrorism;
• Bribery, corruption, or kickbacks;
• Facilitation of tax evasion;
• Breach of internal policies and procedures;
• Breach of legal or regulatory obligations, including VARA's rules and regulations;
• Health and safety risks;
• Conduct likely to damage the Company's reputation or financial wellbeing;
• Unauthorized disclosure of confidential information;
• Negligence; or
• The deliberate concealment of any of the above matters.

4. How to Report a Concern

Any person, including employees and external parties, may report a concern via the whistleblowing@rain.com. 

Reports may also be submitted anonymously through the above channels. Where a report is made anonymously, the Company will make every effort to investigate it effectively while preserving the anonymity of the reporting person.

Concerns may also be reported directly to the Virtual Assets Regulatory Authority (VARA) here: https://www.vara.ae/en/register-a-complaint/.

5. Confidentiality

The Company will treat all reports with the strictest confidence. The identity of any reporting person will only be disclosed where strictly necessary for the purposes of investigating the concern and to the extent required by applicable law.

6. Protection from Retaliation

The Company will support anyone who raises a genuine concern under this policy, even if the concern turns out to be mistaken. No person who raises a genuine concern will suffer any detrimental treatment as a result, including dismissal, disciplinary action, threats, demotion, or any other unfavorable treatment.

Any person who believes they have suffered retaliation as a result of raising a concern in good faith may report this to the Responsible Individuals listed here.

Any person found to have threatened, retaliated against, or otherwise mistreated a person who has raised a genuine concern will be subject to disciplinary action.

Note: This policy does not protect persons who make deliberately false or malicious allegations. Any person found to have made malicious allegations may be subject to disciplinary proceedings.