Ethics Policy

Date: 17th August 2024

Version: 1.0

Whistleblowing Policy

Tungsten is committed to upholding the highest standards of integrity and ethics. We have implemented robust policies and a structured framework to encourage employees and stakeholders to report any wrongdoing or unethical behaviour. Whistleblowers are assured of protection and confidentiality, with appropriate actions taken against misconduct.

Our policy extends to all employees, contractors, vendors, clients, and anyone aware of activities violating our code of conduct, policies, or legal requirements. Tungsten values the crucial role of whistleblowers in maintaining our ethical standards and encourages the reporting of concerns in good faith, promising protection from retaliation.

Secure and confidential reporting channels are available. If you have any concerns about our company’s activities, please contact us at support@tungsten.ae.

Complaints

You can contact Tungsten by emailing support@tungsten.ae or submit the complaint through our complaint form

Tungsten will try to resolve as many complaints as possible immediately via the respective channel through which contact was established.

We shall acknowledge all complaints within one week of a complaint being made.

In all cases, we will provide you an update on the status of the complaint, and explain any extraordinary circumstances that are delaying the resolution within four weeks of the complaint being made. Moreover, will resolve all complaints no later than eight weeks from when the complaint was made.

There is no extra cost for raising a complaint. In case certain resolutions require a change in the scope of the product/service being offered to you, you will be made aware of it and, should you opt for it, your explicit consent will be sought and documented.

Irrespective of the channel, please try and give us as much context as possible about the nature of your complaint. This will help us effectively come up with both short and long term solutions for you.

Anti-Bribery and Corruption

At Tungsten, we are committed to conducting business with the highest standards of integrity, transparency, and ethical conduct. We recognise the importance of maintaining trust and confidence with our clients, partners, employees, and stakeholders. As part of this commitment, we have implemented a robust Anti-Bribery and Corruption Policy that reflects our zero-tolerance approach to any form of bribery or corruption.

Our Commitment

Zero Tolerance: We do not tolerate bribery or corruption in any form. This includes offering, giving, receiving, or soliciting anything of value to influence the actions of an individual or organization improperly.

Compliance with Laws: We strictly adhere to all applicable anti-bribery and corruption laws and regulations, including but not limited to the Virtual Assets Regulatory Authority (VARA) regulations, the anti-bribery provisions under the UAE Federal Penal Code, the UAE Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and Combatting the Financing of Terrorism, as well as relevant international standards. Our commitment extends to ensuring full compliance with these laws within the Emirate of Dubai and any other jurisdictions where we operate.

Employee Responsibility: All employees, officers, and directors of Tungsten Custody Solutions FZE are required to understand and comply with our Anti-Bribery and Corruption Policy. Regular training and resources are provided to ensure our team is well-equipped to identify and avoid any unethical practices.

Third-Party Due Diligence: We carefully select our partners, suppliers, and other third parties, ensuring they share our commitment to ethical business practices. We conduct thorough due diligence and require all third parties to comply with our Anti-Bribery and Corruption Policy.

Reporting and Accountability: We encourage all employees, partners, and stakeholders to report any concerns or suspicions of bribery or corruption. Reports can be made confidentially and without fear of retaliation. We are committed to investigating all reported incidents promptly and taking appropriate action.

Continuous Improvement: We regularly review and update our Anti-Bribery and Corruption Policy to ensure it remains effective and relevant. We are dedicated to continuous improvement in our efforts to prevent bribery and corruption in all aspects of our business.

By upholding these principles, Tungsten Custody Solutions FZE strives to create a fair, transparent, and ethical environment that benefits everyone involved. We believe that integrity is the foundation of long-term success, and we are dedicated to maintaining the highest ethical standards in everything we do.

For more information or to report any concerns, please contact us at support@tungsten.ae

Fair Treatment of Clients

At Tungsten, we are dedicated to maintaining the highest standards of ethical and professional conduct. Our Code of Business Conduct outlines the expectations we have for all employees, contractors, and third parties who work with or on behalf of our company. This policy serves as a comprehensive guide to ensure that all business activities are conducted with integrity, transparency, and in full compliance with applicable laws and regulations.

Key Principles

Ethical Conduct: We expect everyone involved with our company to act ethically and responsibly in all business dealings, ensuring fairness, integrity, and respect for all stakeholders.

Compliance with Laws: Adherence to local and international laws, including anti-bribery, anti-corruption, and anti-money laundering regulations, is mandatory. We cooperate fully with regulators and ensure that all actions are in line with the legal requirements.

Customer Relations: We are committed to treating customers fairly, protecting their confidential information, and addressing any concerns or complaints promptly and transparently.

Conflict of Interest: All employees must avoid situations where personal interests conflict with the interests of the company. This includes managing relationships with suppliers and other third parties to maintain impartiality and fairness.

Whistleblowing: We encourage a culture where employees and partners can report unethical behavior without fear of retaliation. Our zero-tolerance policy ensures that all reports are taken seriously and investigated thoroughly.

Safeguarding Assets: Protecting company assets, including intellectual property, financial resources, and information, is a shared responsibility. We ensure that all assets are used efficiently and protected against loss or misuse.

This policy forms the foundation of how we conduct our business, emphasising our commitment to ethical practices and legal compliance. It is essential for building trust with our clients, partners, and the wider community.