Whistleblowing Disclosure (English)

Wirex Digital is committed to maintaining a working environment and an operational model based on integrity, transparency, and accountability in line with the principles set out in EU Directive 2019/1937.

The purpose of this is to promote an ethical corporate culture in which anyone who interacts with Wirex Digital – whether internally or externally – can, in good faith, report behaviours that may compromise the legality, fairness, or reputation of the company. Here we outline the principles and procedures for reporting unlawful acts, breaches of laws, regulations, or ethical standards, ensuring protection for whistleblowers and the proper, impartial, and confidential handling of all reports.

Scope and reportable conduct

Reportable conduct includes, but is not limited to, fraud, corruption, embezzlement, breaches of financial or cybersecurity regulations, abuse of power, harassment, discrimination, conflicts of interest, misuse of company data or resources, and any other behaviour contrary to applicable laws or the company’s ethical values.

Reports may be submitted by employees, contractors, consultants, suppliers, former employees, job applicants, or clients, as well as by any other individual who has had a direct or indirect relationship with Wirex Digital.

Wirex distinguishes between internal and external whistleblowers:

• Internal whistleblowers include employees, contractors, or consultants of the company who report misconduct identified in the course of their work activities.

• External whistleblowers include individuals external to the company – such as suppliers, independent consultants, business partners, or clients – who wish to report suspected violations or unethical behaviour observed in connection with their relationship with Wirex.

Wirex Digital is firmly committed to safeguarding external whistleblowers from any form of retaliation or unfair treatment, ensuring that all reports are taken seriously and thoroughly assessed. In accordance with EU Directive 2019/1937, external whistleblowers are also protected, provided they act in good faith and have reasonable grounds to believe that the information disclosed is accurate.

Reporting channels

Wirex Digital provides dedicated, secure, and confidential channels through which reports may be submitted in electronically.

Reports are handled by an independent Whistleblowing Officer, reachable at whistleblower@wirexapp.com, who is responsible for receiving, recording, and assessing each report impartially and in compliance with applicable legislation.

All personal data and information shared are processed in accordance with Regulation (EU) 2016/679 (GDPR) and relevant national data protection laws.

If you plan to submit a whistleblowing report, please make sure to include your signed Privacy Information Notice for Whistleblowers with your report

In some cases, when a whistleblower considers it unsafe or inappropriate to use internal channels, reports may also be submitted through external channels, by contacting the relevant competent authorities (for example, supervisory or regulatory bodies).

Depending on the nature of the violation, the main competent authorities include:

• Bank of Italy (Banca d’Italia) – for violations related to financial services, anti-money laundering, transparency, or the management of client funds;

• CONSOB – for issues concerning misconduct in, crypto-assets services;

• Italian Data Protection Authority (Garante per la Protezione dei Dati Personali) – for breaches related to personal data protection or misuse of customer information.

Investigation and outcomes

All reports received are subject to a preliminary assessment to determine their validity and relevance.

If a report appears credible, the Whistleblowing Officer may initiate internal investigations or propose further inquiries.

After the investigation is concluded, immediate steps will be taken to address and mitigate the breach.

Investigations are carried out in full compliance with the principles of confidentiality and non-retaliation, and may lead, where necessary, to corrective or disciplinary actions.

Wirex Digital encourages everyone involved in its business activities to report any irregularities, ensuring that each report is handled with seriousness, respect, and professionalism.