Legal

Whistleblower Notice

If you work with PolyExhange, hold an account, or otherwise see something that should not be happening on this exchange, you can tell us — or a competent authority — without being punished for doing so in good faith.

1. What this notice covers

This channel is for serious misconduct connected to the operation of the exchange, not ordinary support tickets. Report if you reasonably believe any of the following is happening or is about to happen:

  • Theft, embezzlement, or unauthorised movement of customer balances.
  • Falsifying ledgers, prices, fills, or withdrawal statuses.
  • Bribery, kickbacks, or trading ahead of customer orders.
  • Deliberate failure to review withdrawals as described on our Security page.
  • Sanctions evasion, money laundering, or instructions to ignore a freeze we are legally required to apply.
  • Retaliation against someone who already raised a concern in good faith.
  • A material security hole that, if exploited, would put customer funds or personal data at risk — see also the Bug Bounty Program.

Account disputes or a disagreement about a fee belong in the help center. Those are not whistleblowing.

2. How to report to us

Use the help center and mark the subject clearly: Whistleblower — confidential. Describe what you saw, when, which accounts or assets if you know them, and how we can reach you if you are willing to be contacted. Attach only what you already have. Do not break into systems, exfiltrate data, or “prove” a theory by moving funds.

If the concern is about the people who would normally read support mail, say so in the first line. That ticket is routed away from the named team and read by a principal, not the queue that handles deposits and KYC.

3. Anonymous reports

You may omit your name. We will still read it. An anonymous note with dates, transaction IDs, or a clear description of a process failure is more useful than a named note with none of those. We cannot always reply to an anonymous sender, and we cannot always complete an investigation without a way to ask follow-up questions.

4. No retaliation

We will not close, freeze, or degrade an account, nor fire or demote staff, because they raised a good-faith concern under this notice. Bad-faith reports — knowing falsehoods, a campaign to harass a colleague, or a threat dressed up as a disclosure — are not protected. We may still take the action the underlying facts require (for example, closing an account used for fraud) even if the same person also filed a whistleblower note.

5. What happens next

We log the report, restrict access to the people who need to see it, and decide whether it is a support issue, a security bug, or a conduct investigation. You should expect an acknowledgement when we have a way to write back. We will not give you a running commentary on another customer’s account or on a law-enforcement matter. If the facts show a control failed, we fix the control and, where the law requires it, notify the people who need to know.

6. Reporting outside PolyExhange

Nothing in this notice stops you from speaking to a lawyer, a regulator, a financial-intelligence unit, or the police in a jurisdiction that has authority over the conduct. If you are required by law to report a crime, do that. Our Law Enforcement Request Policy describes how we handle lawful process served on us; it is not a substitute for you making a report to the authorities yourself.