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
Ethics Email
Secure email reporting
ethics@glint.club
Online Portal
Secure web-based reporting
glint.club/report
Management Reporting
Direct supervisor or HR
hr@glint.club
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
Report Receipt
Immediate acknowledgment and case number assignment
Initial Assessment
Preliminary review and investigation planning
Investigation
Thorough investigation by qualified personnel
Resolution
Appropriate action taken and outcome communicated
Investigation Standards
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