Whistleblowing Policy
1. Background
MP Network Inc and MP PAYMENT INC, together with their respective affiliates (each a "Company" and together the "Group"), are committed to high standards of openness, integrity and accountability. This Whistleblowing Policy (the "Policy") forms an important part of the Group's risk management and internal control framework.
Whistleblowing is the act of reporting a serious concern about suspected fraud, malpractice, misconduct or irregularity (a "Concern"). A person who raises a Concern is a "Whistleblower". A Whistleblower may be an employee of a Company (an "Employee") or a third party, such as a user, a customer, a supplier, a contractor, a partner or the operator of a Bot or Mini App.
Whistleblowing is one of the most effective ways of uncovering fraud, malpractice, misconduct and significant risk inside an organisation before it causes harm.
Management of associated companies, jointly controlled entities and business partners is encouraged to bring this Policy to the attention of their own personnel and related parties, as appropriate to their operations.
2. Purpose
The purpose of this Policy is:
to encourage and assist Employees and third parties to raise a Concern and to disclose related information in confidence;
to provide clear reporting channels and guidance, so that a Concern is raised rather than ignored; and
to bring suspected fraud, malpractice or misconduct to light before it causes disruption or loss.
3. Responsibility
The Compliance team of the Group has overall responsibility for this Policy, for implementing it, and for monitoring and reviewing its effectiveness and the actions that follow an investigation.
Any amendment or update to this Policy requires the approval of the Head of Compliance.
4. What Can Be Reported
Conduct that may constitute malpractice or misconduct includes, but is not limited to:
(a) a criminal offence or a miscarriage of justice;
(b) non-compliance with law or regulation, including anti-money laundering, counter-terrorist financing, sanctions and money transmission requirements;
(c) impropriety or fraud relating to accounting, financial reporting, internal control or auditing;
(d) misuse or misappropriation of the assets or resources of a Company, including user funds and digital assets;
(e) any act that endangers the health or safety of an Employee or another person;
(f) a breach of a policy or guideline of a Company;
(g) improper use or leakage of confidential, personal or commercially sensitive information;
(h) bribery, corruption, or an undisclosed conflict of interest;
(i) retaliation against a person who has raised a Concern; and
(j) the deliberate concealment of any of the above.
A Whistleblower is not required to prove a Concern. A Concern raised in good faith is welcomed, even if an investigation does not substantiate it. Good faith means that the person raising the Concern holds a reasonable and honest belief that it is true, and is not acting out of personal interest or an ulterior motive.
5. Protection for Whistleblowers
A person who raises a Concern in good faith is assured of fair treatment. Each Company will make every effort to protect an Employee who raises a Concern against unfair dismissal, victimisation, demotion, exclusion or unwarranted disciplinary action, even where the Concern turns out to be unsubstantiated.
Management must ensure that a Whistleblower feels able to raise a Concern without fear of reprisal. Any form of retaliation against a Whistleblower is itself misconduct and will be treated as such, up to and including dismissal.
If a Whistleblower makes a report that is knowingly false, malicious, or made with an ulterior motive or for personal advantage, the relevant Company reserves the right to take appropriate action against that person, whether an Employee or a third party, and to recover any loss or damage caused by the false report.
6. Confidentiality
Each Company will make every effort to keep the identity of a Whistleblower, and the Concern reported, strictly confidential.
A Whistleblower should likewise keep the details of a reported Concern strictly confidential, including its nature and the persons involved.
Where the identity of a Whistleblower has to be disclosed in order to comply with law or regulation, or in the course of legal proceedings, the relevant Company will take reasonable steps to protect the Whistleblower from detriment, and will inform the Whistleblower in advance wherever it is permitted to do so.
A Whistleblower may report anonymously. Anonymous reporting is not encouraged, because limited information hinders investigation and follow-up, and because we may be unable to tell you the outcome. Whistleblowers are encouraged to come forward and to provide as much specific information as possible so that the Concern can be properly assessed and investigated.
7. How to Raise a Concern
An Employee or third party who wishes to raise a Concern should contact the Compliance team through:
the whistleblowing channel in the MPChat app; or
email to [email protected], which is monitored by the Compliance team.
Please provide as much detail as you can, including what happened, when and where it happened, who was involved, whether it is continuing, and any supporting documents or records.
A designated member of the team responsible for resolution will follow up with you within three (3) business days of receiving your report. That person will investigate the matter and may ask you for further information.
If your Concern is about a member of the Compliance team, say so in your report. Clause 8 explains how such a report is handled.
8. Investigation Process
The Compliance team records every Concern raised through the whistleblowing channel. Every reported case with valid contact details will be followed up.
The Head of Compliance evaluates the validity and relevance of each Concern received, decides how it should be categorised, and determines to whom it should be reported. The Compliance team reviews each investigation and determines the course of action to be taken.
Where the Compliance team considers it appropriate, a case may be referred to the relevant regulatory authority or to law enforcement.
Where the Concern relates to a member of the Compliance team:
(a) the Head of Compliance evaluates the validity and relevance of the case, assesses it, and decides whether an investigation is required; and
(b) where the Head of Compliance considers it appropriate, the case may be referred to the relevant regulatory authority.
Where the Concern relates to the Head of Compliance, the report is escalated to the board of directors of the relevant Company, or to a director who is independent of the matter, and the Head of Compliance is excluded from the handling of that case.
A person who is the subject of a Concern will not take part in its assessment or investigation.
9. Outcome
We will tell a Whistleblower who has provided valid contact details that the matter has been dealt with, and, so far as we are lawfully able and consistent with the confidentiality owed to others, what the outcome was. There will be occasions on which we cannot disclose the detail of an outcome, including where doing so would prejudice an investigation, breach a legal or regulatory obligation, or infringe another person's rights.
10. Records and Review
The Compliance team maintains records of Concerns raised, investigations conducted and actions taken, for the period required by applicable law. The Compliance team reviews the operation of this Policy periodically, and reports on its effectiveness to senior management.
11. Relationship with Other Policies
This Policy is for reporting suspected fraud, malpractice, misconduct or irregularity within the Group.
If you are dissatisfied with a service you have received, use the Complaint Policy.
If you wish to report content or conduct by another user, use the in-app reporting function.
If you wish to exercise a right in relation to your personal information, see the Personal Information Collection Statement.
12. Contact
In-app: the whistleblowing channel in MPChat
Email: [email protected]
MP Network Inc — 8 The Green, Suite B, Dover, Delaware 19901, United States of America
MP PAYMENT INC — 1500 N Grant St Ste R, Denver, Colorado 80203, United States of America
Whistleblowing Policy · Version 2.0.0 · Effective August 5, 2026