GLINT
MarketplaceAuctions

WHISTLEBLOWER POLICY

At GLINT, we are committed to maintaining the highest standards of integrity, transparency, and ethical conduct in our luxury marketplace

OUR COMMITMENT TO ETHICS

This policy establishes clear procedures for reporting concerns and ensures protection for those who speak up

Integrity First

We prioritize ethical conduct in every aspect of our luxury marketplace

Protection Guaranteed

Full protection against retaliation for good faith reporting

Transparency

Clear, transparent processes for all stakeholders

Policy Purpose

GLINT is committed to conducting business with integrity, transparency, and in compliance with all applicable laws and regulations. This Whistleblower Policy encourages employees, partners, customers, and other stakeholders to report suspected violations of law, regulations, or company policies.

We believe that an ethical workplace benefits everyone - our employees, customers, partners, and the luxury marketplace community as a whole. This policy ensures that concerns can be raised safely and will be addressed promptly and thoroughly.

REPORTING CHANNELS

Multiple secure and confidential ways to report concerns

Ethics Hotline

24/7 confidential hotline

+1-800-GLINT-01

Anonymous reporting
Multi-language support
24/7 availability

Ethics Email

Secure email reporting

ethics@glint.club

Encrypted communication
Confidential handling
Response within 48 hours

Online Portal

Secure web-based reporting

glint.club/report

Anonymous submissions
Case tracking
Document uploads

Management Reporting

Direct supervisor or HR

hr@glint.club

Face-to-face meetings
Written reports
Escalation procedures

PROTECTED DISCLOSURES

The following types of concerns are covered under this policy

Financial Misconduct

  • Fraudulent financial reporting
  • Money laundering activities
  • Unauthorized financial transactions
  • Embezzlement or theft of funds
  • Tax evasion or avoidance schemes

Operational Violations

  • Violation of authentication procedures
  • Unauthorized product listings
  • Breach of customer data protection
  • Non-compliance with regulatory requirements
  • Misrepresentation of product authenticity

Workplace Misconduct

  • Discrimination or harassment
  • Health and safety violations
  • Conflicts of interest
  • Abuse of company resources
  • Violation of employment policies

Legal & Regulatory

  • Violation of luxury goods regulations
  • Breach of anti-money laundering laws
  • Non-compliance with consumer protection
  • Violation of competition laws
  • Breach of international trade regulations

PROTECTION MEASURES

Comprehensive protection for whistleblowers reporting in good faith

Legal Protection

Full legal protection against retaliation under applicable whistleblower laws

Confidentiality

Strict confidentiality maintained throughout investigation process

Anonymous Reporting

Option for completely anonymous reporting through secure channels

No Retaliation

Zero tolerance policy for any form of retaliation against reporters

Anti-Retaliation Commitment

GLINT strictly prohibits retaliation against any person who makes a good faith report of suspected misconduct or who assists in an investigation. Retaliation includes, but is not limited to:

  • Termination or suspension
  • Demotion or loss of benefits
  • Harassment or intimidation
  • Discrimination or blacklisting
  • Threats or coercion
  • Any other adverse action

Any employee found to have retaliated against a whistleblower will face disciplinary action, up to and including termination.

INVESTIGATION PROCESS

Our systematic approach to investigating reported concerns

1

Report Receipt

Immediate acknowledgment and case number assignment

Within 24 hours
2

Initial Assessment

Preliminary review and investigation planning

Within 72 hours
3

Investigation

Thorough investigation by qualified personnel

2-4 weeks
4

Resolution

Appropriate action taken and outcome communicated

Within 30 days

Investigation Standards

Impartial and objective review
Qualified investigation team
Thorough evidence collection
Regular progress updates
Appropriate corrective action
Documentation and follow-up

LEGAL FRAMEWORK

Our policy complies with applicable whistleblower protection laws

Regulatory Compliance

Full compliance with SOX, Dodd-Frank, and other applicable whistleblower statutes

  • • Sarbanes-Oxley Act (SOX)
  • • Dodd-Frank Act
  • • False Claims Act
  • • State whistleblower laws

International Standards

Adherence to global best practices and international regulations

  • • EU Whistleblower Directive
  • • UK Public Interest Disclosure Act
  • • Canadian whistleblower protection
  • • Regional compliance requirements

Industry Standards

Alignment with luxury marketplace and financial services standards

  • • Anti-money laundering compliance
  • • Consumer protection standards
  • • Data protection regulations
  • • Marketplace governance principles

TRAINING & AWARENESS

Comprehensive education programs to promote ethical conduct

Employee Training

  • Mandatory ethics training for all employees
  • Annual refresher courses on whistleblower policy
  • Management training on handling reports
  • Role-specific compliance training

Community Outreach

  • Vendor and partner ethics briefings
  • Customer awareness programs
  • Industry collaboration initiatives
  • Regular policy updates and communications

Resources Available

We provide comprehensive resources to help our community understand and utilize this policy effectively.

Policy Guide

Detailed policy documentation

Training Materials

Interactive learning modules

Support Hotline

24/7 guidance and assistance

SPEAK UP WITH CONFIDENCE

Your voice matters. If you witness or suspect misconduct, we encourage you to report it through any of our secure channels.

CONTACT INFORMATION

Multiple ways to reach our ethics and compliance team

Ethics Hotline

+1-800-GLINT-01

24/7 Confidential Reporting

Ethics Email

ethics@glint.club

Secure Email Communication

Online Portal

glint.club/report

Anonymous Web Reporting

Last Updated: January 15, 2025

This policy is subject to applicable laws and regulations and may be updated from time to time.

For questions about this policy, please contact our Ethics Team at ethics@glint.club