Last Updated: May 2025
Commitment to Integrity
At Simple KYC, we are committed to maintaining the highest standards of integrity, transparency, and accountability in everything we do. We expect the same commitment from everyone we work with—our clients, suppliers, partners, and the wider community.
This Whistleblower Policy provides a secure and confidential channel for anyone outside our organization to report concerns about suspected misconduct, unethical behavior, or breaches of law involving Simple KYC or its employees.
Purpose and Scope
This policy aims to:
Encourage external stakeholders to report suspected or actual wrongdoing connected with Simple KYC’s operations or supply chain.
Ensure that concerns are handled confidentially, fairly, and without fear of retaliation.
Reinforce our commitment to ethical conduct, regulatory compliance, and global whistleblower protection laws.
This policy applies to:
Clients and prospective clients;
Suppliers and contractors (including their employees and subcontractors);
Partners, agents, and consultants;
Members of the public who have a legitimate concern involving Simple KYC.
What Can Be Reported
We encourage the reporting of any conduct that is:
Fraudulent, corrupt, or dishonest;
Unethical or illegal;
A conflict of interest or misuse of company resources;
A breach of data privacy, information security, or confidentiality;
A human rights violation or modern-slavery practice;
A financial or accounting irregularity;
Any serious improper, unsafe, or unlawful activity.
Reports may relate to incidents that are past, ongoing, or likely to occur in the future.
How to Report a Concern
Simple KYC provides multiple confidential options for raising concerns:
📧Email (anonymous or attributed)
suggestions@simplekyc.com
You may use your personal email address or create an anonymous account. You are not required to disclose your identity.
💬Phone or in person
You may also report directly to a Compliance Officer, Human Resources Officer, or other eligible recipient within Simple KYC.
Where appropriate, reports may be referred to an independent third party engaged by Simple KYC to assist with investigations.
Confidentiality and Protection
All reports are handled confidentially and fairly.
Information is shared only with individuals directly responsible for investigating and addressing the concern.
Simple KYC will not tolerate retaliation or adverse treatment against anyone who reports a concern in good faith.
Whistleblowers are protected even if their report, upon investigation, is not substantiated.
Disclosures may be made anonymously, and such reports will still be taken seriously and investigated to the fullest extent possible.
Investigation Process
Each concern is promptly reviewed by the Compliance team.
Dependingon the nature of the issue, the matter may be referred to the COO, Human Resources, or another relevant senior manager for investigation and resolution, following Simple KYC’s internal whistleblower procedures.
Simple KYC may also engage an independent third party to assist in conducting investigations.
Investigations are performed with impartiality, confidentiality, and procedural fairness.
Corrective actions will be implemented where wrongdoing is substantiated, and relevant regulatory or law-enforcement authorities may be notified when required.
Legal Protections
Simple KYC upholds whistleblower protections under applicable laws in all jurisdictions where it operates, including:
Australia: Corporations Act 2001 (Cth) and Taxation Administration Act 1953 (Cth)
New Zealand: Protected Disclosures (Protection of Whistleblowers) Act 2022
Philippines: Code of Conduct and Ethical Standards for Public Officials and Employees (RA 6713)
Spain: Law 2/2023 on Whistleblower Protection
Where local laws provide greater protection, Simple KYC will apply the higher standard.
External Regulatory Disclosures
Individuals retain the right to report directly to relevant regulators, such as:
The Australian Securities and Investments Commission (ASIC)
The Australian Prudential Regulation Authority (APRA)
The Australian Taxation Office (ATO)
The Office of the Ombudsman (New Zealand or Philippines)
Equivalent authorities in other jurisdictions
Simple KYC respects these rights and will not prevent or discourage anyone from reporting directly to regulators.
Non-Retaliation Commitment
We value and respect every individual’s courage to speak up. Retaliation, victimization, or intimidation against anyone who reports a concern in good faith—whether internal or external—will result in disciplinary or contractual action against those responsible.
Contact
For any questions about this policy or to make a report:
📧 suggestions@simplekyc.com
🌐 www.simplekyc.com
All reports are initially reviewed by the Compliance team and may be referred to the COO, HR, or other relevant senior managers for resolution in accordance with Simple KYC’s internal whistleblower procedures.
Your voice matters.
By speaking up, you help protect our company, our customers, and the integrity of the financial system.
