1. Overview
Ingots.io enforces zero tolerance for corruption, bribery, or unethical conduct. This policy ensures safe, confidential reporting channels and robust protections for whistleblowers across all operations.
2. Scope
Applies to:
Internal: Employees, contractors, executives.
External: Users, vendors, partners.
All products: Dual Asset Trading, Ingots Indexed Token, MYRX Stablecoin.
3. Prohibited Conduct
Violations include but are not limited to:
Bribery, kickbacks, or facilitation payments.
Undisclosed conflicts of interest.
Misuse of company assets or insider information.
Retaliation against whistleblowers.
Consequences:
Immediate termination.
Clawback of ill-gotten gains.
Mandatory reporting to SC Malaysia, BNM, or MACC (Malaysian Anti-Corruption Commission).
4. Reporting Channels
Submit reports via:
Secure Form: whistleblowing.ingots.io (AES-256 encrypted).
Email: [email protected] (PGP key available).
Hotline: +60 [Insert Number] (24/7, anonymous calls accepted).
5. Whistleblower Protections
Anonymity: No IP logging; use Tor/ProtonMail for submissions.
Legal Shield: Protected under Malaysia’s Whistleblower Protection Act 2010 and indemnified against defamation claims.
Non-Retaliation: Retaliation results in disciplinary action, including termination.
6. Investigation Process
Triage: Initial response within 48 hours.
Resolution:
Minor cases: 14 days.
High-risk (e.g., fraud): 7 days, escalated to external auditors.
Documentation: Securely stored for 10 years (per SC Malaysia).
7. Oversight & Accountability
Quarterly Audits: By independent third parties (e.g., PwC Malaysia).
Regulatory Alignment: Updated in real-time for:
Malaysia: SC’s Anti-Money Laundering Guidelines.
Global: OECD Anti-Bribery Convention, FATF Recommendations.
8. Training & Awareness
Mandatory: Annual anti-corruption training for all staff.
Optional: User/partner webinars on ethical reporting.
Visibility: Reporting links pinned to all internal/external platforms.
9. Disclaimer
False reports made in bad faith may incur legal action.
Ingots.io cooperates fully with regulatory investigations.
Effective Date: 15 April 2025
Last Updated: 15 April 2025