Reporting Bribery and Corruption Concerns
Version 1.2 · 31-07-2024
This page provides MKX Virtual Assets Broker and Dealer Services LLC ("MKX") with public reporting channels for actual, suspected, or potential bribery, corruption, unethical conduct, or related misconduct. Reports may be submitted by employees, clients, prospective clients, suppliers, contractors, business partners, counterparties, or members of the public.
Our Commitment
MKX Virtual Assets Broker and Dealer Services LLC ("MKX") is committed to conducting its business with honesty, integrity, fairness, and professionalism.
MKX maintains a zero-tolerance approach to bribery and corruption and is committed to complying with all applicable laws, regulations, and regulatory requirements, including those issued by the Dubai Virtual Assets Regulatory Authority (VARA).
MKX prohibits:
• Offering, promising, giving, requesting, or accepting a bribe;
• Facilitation payments;
• Kickbacks;
• Improper gifts, entertainment, or hospitality;
• Any financial or non-financial advantage intended to improperly influence a business decision or outcome;
• Retaliation against any person who raises a concern in good faith.
All members of the Board, Senior Management, employees, contractors, consultants, agents, suppliers, and any other persons acting on behalf of MKX are required to comply with these standards.
Who Can Make a Report?
A report may be submitted by:
• Clients and prospective clients;
• Employees and former employees;
• Directors and Board members;
• Contractors and consultants;
• Suppliers and service providers;
• Business partners and counterparties;
• Any person dealing with MKX; or
• Members of the public.
Reports may relate to the conduct of:
• MKX;
• A member of the Board;
• A member of Senior Management;
• An employee;
• A contractor, consultant, agent, supplier, or business partner; or
• Any third party acting on behalf of MKX.
What Should Be Reported?
You should submit a report where you know, believe, or reasonably suspect that any of the following has occurred, may be occurring, or has been requested:
• Offering or accepting a bribe;
• Promising or requesting an improper payment;
• Facilitation payments;
• Kickbacks;
• Improper gifts, hospitality, or entertainment;
• Attempts to obtain an improper business advantage;
• Misuse of company assets or funds;
• Concealment of payments or records;
• Improper dealings with public officials;
• Conflicts of interest linked to an improper advantage;
• Retaliation against a person who refused to engage in bribery or corruption;
• Retaliation against a whistleblower; or
• Any violation of applicable anti-bribery and corruption laws, regulations, or MKX policies.
You do not need to possess complete evidence before making a report. Concerns may be raised on the basis of a genuine and reasonable suspicion.
How to Make a Report
Reports may be submitted through any of the following confidential channels:
Where possible, please include "Confidential – Bribery and Corruption Report" in the subject line.
Telephone
Reports received by telephone will be recorded and reviewed by the Compliance Officer.
In Person
Reports may also be submitted directly to the Compliance Officer.
Whistleblowing Channels
Reports may additionally be submitted through MKX's Whistleblowing reporting channels where available.
Information to Include
To assist MKX in reviewing the concern, please provide as much information as possible, including:
• Your name and contact details (unless submitting anonymously);
• A description of the suspected conduct;
• The names of persons involved;
• Relevant dates and locations;
• Details of any payment, gift, hospitality, or advantage involved;
• Witness information;
• Supporting documents, emails, messages, invoices, or evidence; and
• Whether the matter has been reported elsewhere.
A lack of complete information will not prevent MKX from reviewing a genuine concern.
Anonymous Reports
Reports may be submitted anonymously.
However, providing a method of communication may assist MKX in obtaining additional information and conducting a more effective investigation.
Anonymous reporting may limit MKX's ability to verify certain facts or seek clarification.
Confidentiality
MKX will treat reports and the identity of reporting persons as confidential to the maximum extent permitted by applicable UAE laws and regulations.
Information will only be disclosed where necessary for:
• Reviewing and investigating the concern;
• Taking appropriate remedial action;
• Fulfilling legal or regulatory obligations; or
• Responding to requests from VARA or another competent authority.
Protection from Retaliation
MKX strictly prohibits retaliation against any person who:
• Raises a concern honestly and in good faith;
• Refuses to participate in bribery or corruption;
• Assists in an investigation; or
• Provides information relating to a suspected violation.
Any retaliation, victimisation, intimidation, harassment, or other detrimental treatment should be reported immediately through the channels listed above.
Protection does not extend to persons who knowingly submit false allegations, act maliciously, or deliberately provide misleading information.
What Happens After a Report Is Submitted?
All reports are reviewed by the Compliance Officer.
Depending on the nature and seriousness of the concern, MKX may:
• Open a formal investigation file;
• Prepare a written record of an oral report;
• Request additional information;
• Appoint an independent person or external party to conduct an investigation;
• Notify the Board that an investigation has commenced;
• Implement corrective or disciplinary measures;
• Report unlawful conduct to VARA or another competent authority; and
• Retain investigation records in accordance with applicable regulatory requirements.
Investigations will be conducted fairly, independently, and objectively.
Where legally permissible, MKX may provide updates regarding the status of an investigation; however, confidentiality and regulatory obligations may limit the information that can be shared.
Record Keeping
Investigation reports and records of remedial actions will be retained by MKX for a minimum period of eight (8) years and will be made available to VARA upon request.
Customer Complaints
This reporting channel is intended only for concerns relating to bribery, corruption, unethical conduct, or related misconduct.
For customer complaints relating to products, services, transactions, accounts, or customer service, please contact:
For general enquiries:
