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Whistleblowing Policy

VAY FINANCE INC., operating as "VayFinance", is committed to conducting its business honestly, ethically, and in compliance with applicable law. This Whistleblowing Policy explains how employees, contractors, customers, and other third parties can report genuine concerns about wrongdoing.

1. Who can report

This policy is open to employees, contractors, suppliers, customers, and any other person who has a genuine concern about conduct connected to our business.

2. What to report

  • Fraud, theft, or financial misconduct;
  • Money laundering, terrorist financing, or sanctions violations;
  • Bribery or corruption;
  • Breach of applicable law or regulation;
  • Serious risk to the health, safety, or security of any person;
  • Deliberate concealment of any of the above.

3. How to report

Reports can be sent to support@vayfinance.com marked "Confidential — Whistleblowing Report", or by mail to VAY FINANCE INC., 94 Lakeshore Road East, Unit 203, Mississauga, Ontario, L5G 1E3, Canada. Please include as much detail as possible — what happened, when, who was involved, and any supporting evidence — to help us investigate effectively. You do not need to provide your name, though it may help us follow up if we need more information.

4. Confidentiality

We will treat all reports as confidentially as possible and will only disclose information about a report to those who need to know in order to investigate and address it properly, or where required by law.

5. No retaliation

We will not tolerate retaliation against anyone who raises a genuine concern in good faith under this policy, even if the concern is later found to be mistaken. Anyone who believes they have suffered retaliation should report it immediately using the same channel.

6. How reports are handled

Reports are reviewed promptly by an appropriate person independent of the matter reported. We will assess the concern, carry out a proportionate investigation, and take appropriate action, which may include referral to regulators or law enforcement where required.

7. Good faith

This policy protects reports made honestly and in good faith, even if they turn out to be incorrect. It does not protect reports known to be false or made maliciously.

8. Contact / reporting channel

support@vayfinance.com, or by mail to VAY FINANCE INC., 94 Lakeshore Road East, Unit 203, Mississauga, Ontario, L5G 1E3, Canada.