Whistle-Blowing Policy

X12 Capital Ltd ("X12") is committed to the highest standards of integrity and regulatory compliance. Our Whistleblowing Policy provides a secure and confidential framework for reporting concerns about wrongdoing, misconduct, or regulatory breaches. A summary of the Policy follows:

Our Commitment

We are committed to the highest standards of integrity and transparency. If you see something wrong — such as fraud, misconduct, or a breach of our policies — we want you to feel safe speaking up.

What Can You Report?

You can report any concerns about

• Fraud or financial crime
• Breaches of laws, regulations, or company policies
• Health and safety risks
• Misconduct or mismanagement
• Attempts to conceal any of the above
• Your Protection
• Your identity will be kept confidential wherever possible
• We strictly prohibit retaliation against anyone who reports a concern in good faith. We actively monitor to ensure whistleblowers do not suffer any detriment
• How to Report
• You can report concerns confidentially or anonymously through any of these channels
• Phone / SMS: +971 (0)52 799 2154
• Email: compliance@ydifc.com
• Internal Auditor: [check with Chris for contact details of our IA]
• FSRA: +971 2 333 8955 (anonymous whistleblowing phone line)
• FSRA online: AMANAH Portal - Speak Up and Whistleblowing Channel | ADGM
• Reports can be made anonymously. We guarantee confidentiality and enforce strict non-retaliation measures.
• What Happens Next
• We confirm receipt of your report
• We follow a structured process
• Secure evidence and maintain confidentiality
• Interview relevant personnel
• Escalate serious matters to senior management and the Board
• We keep you informed where appropriate and take corrective action
• Independent Oversight
• If your report involves senior management or compliance staff, an independent external reviewer will oversee the investigation.
• Regular Review
• Our whistleblowing arrangements are reviewed by our Internal Auditor and external experts to ensure effectiveness and compliance with FSRA requirements.