UAB Superb Payments Whistleblowing Policy
Last Updated: 31.12.2024
1. Terms used in the document
1.1. Defamation: The act of damaging the good reputation of a company or a person.
1.2. External Party: Any party with which Superb Payments, UAB has a valid contract or other form of established relationship, including clients, service providers, outsourcing parties, payment scheme partners, and shareholders, excluding company employees.
1.3. Protected Disclosure: Disclosure of information that members of staff reasonably believe demonstrates malpractice. Individuals making protected disclosures are safeguarded against retaliation.
1.4. Malicious Reporting: Reporting with the sole purpose of causing harm to Superb Payments, UAB or its employees.
1.5. Vexatious Reporting: Reporting intended to annoy, frustrate, or cause unnecessary concern to Superb Payments, UAB or its employees.
1.6. Whistleblowing: The act of revealing information about activity within a company that is deemed illegal, unethical, unsafe, or fraudulent.
2. Introduction
2.1. Superb Payments, UAB, as a Virtual Asset Service Provider (VASP) licensed by the Bank of Lithuania, is committed to ensuring a transparent and accountable whistleblowing process within the organization.
2.2. The purpose of this Whistleblowing Policy (hereafter "Policy") is to establish a framework for external parties to report misconduct, unethical conduct, or illegal activities.
2.3. Superb Payments, UAB aims to create a culture of openness, where individuals can report concerns without fear of retaliation or discrimination.
2.4. This Policy provides a mechanism for reporting, investigating, and addressing wrongdoing.
3. Scope
3.1. This Policy is designed to facilitate the reporting of suspected wrongdoing, including but not limited to:
3.1.1. Criminal offenses
3.1.2. Violations of legal or regulatory obligations
3.1.3. Financial fraud or bribery
3.1.4. Money laundering or terrorism financing
3.1.5. Misuse of company resources
3.1.6. Health and safety risks
3.1.7. Environmental damage
3.1.8. Harassment or discrimination
3.1.9. Any deliberate attempt to conceal the above
3.2. Reports should be made in the best interest of the public, the company, or the clients.
4. Principles
4.1. This Policy offers protection to individuals who disclose whistleblowing concerns in good faith.
4.2. Retaliation against whistleblowers is strictly prohibited. Any form of intimidation, dismissal, or discrimination resulting from a protected disclosure may lead to disciplinary action.
4.3. This Policy is not designed to support grievances related to employment disputes, which should be addressed through internal HR procedures.
4.4. Whistleblowing reports should be submitted within three months of the alleged misconduct unless exceptional circumstances apply.
5. Confidentiality of concerns raised
5.1. All disclosures will be handled in a confidential and sensitive manner.
5.2. The identity of whistleblowers will be kept confidential unless disclosure is legally required or hinders the investigation.
6. Anonymous disclosure
6.1. Although whistleblowers are encouraged to provide their identity, anonymous disclosures will be considered based on:
6.1.1. The seriousness of the issue
6.1.2. The credibility of the concern
6.1.3. The likelihood of verifying the allegation through available sources
7. Untrue allegations or defamation
7.1. No action will be taken against individuals making genuine disclosures in good faith.
7.2. False or malicious allegations intended to harm the company or its employees may result in legal action or disciplinary measures.
8. Process of disclosure
8.1. Whistleblowing reports should be submitted using complaints@superbbit.com email, with “whistleblowing” in the title.
8.2. Reports should include:
8.2.1. A full description of the concern
8.2.2. The date, time, and location of the incident
8.2.3. The individuals or entities involved
8.2.4. Supporting evidence (if available)
8.3. An investigation will be initiated based on the reported information.
9. Process of Whistleblowing
9.1. Reports can be submitted via email complaints@superbbit.com
9.2. The form will be reviewed by designated compliance officers to determine the next steps.
9.3. Whistleblowers will receive an acknowledgment within two business days and an update on the investigation process within ten business days unless they remain anonymous.
9.4. If the reported matter falls outside Superb Payments, UAB’s jurisdiction, it will be forwarded to the relevant authorities.
10. Investigation outcome
10.1. Possible investigation outcomes include:
10.1.1. No further action (if the concern lacks sufficient evidence)
10.1.2. Internal investigation (which may result in disciplinary action)
10.1.3. Referral to law enforcement or regulatory authorities
10.2. Whistleblowers will be informed of the investigation outcome where possible.
10.3. If dissatisfied with the outcome, whistleblowers may escalate the matter to the Bank of Lithuania or other competent authorities.
11. Final provisions
11.1. This Policy will be reviewed at least annually by the Risk and Compliance Officer.
11.2. The Policy must be approved by the Management Board.