ROECNY expects directors, officers, employees, consultants, contractors, and business partners acting on its behalf to conduct business professionally, fairly, and with integrity.

ROECNY does not tolerate bribery, corruption, fraud, falsification of records, misuse of company assets, improper payments, or deliberate circumvention of legal, regulatory, or internal control requirements.

Concerns may be raised by internal or external parties who encounter suspected misconduct connected with ROECNY's business, operations, staff, products, customers, vendors, or counterparties.

• Employees, consultants, and temporary personnel.
• Customers, merchants, vendors, banking partners, and service providers.
• Applicants, counterparties, or other parties who interact with ROECNY in the course of business.

• Suspected bribery, corruption, kickbacks, or improper payments.
• Fraud, theft, embezzlement, forgery, or misuse of company or customer assets.
• Falsified books, records, invoices, onboarding materials, compliance files, or transaction information.
• Sanctions, anti-money laundering, licensing, regulatory, or legal compliance concerns.
• Conflicts of interest, unethical conduct, harassment tied to retaliation for speaking up, or other serious misconduct.
• Attempts to conceal improper activity or interfere with controls, audits, investigations, or reporting processes.

ROECNY encourages people to raise concerns promptly and in good faith whenever they reasonably believe misconduct, illegality, or control failures may have occurred.

A report does not need to be proven before it is submitted. The reporting person should provide the information they have honestly and without deliberate falsification.

ROECNY does not support retaliation against a person who raises a concern in good faith or who assists with a related review or investigation.

Retaliation concerns may themselves be reported through the same reporting channels and will be reviewed seriously.

ROECNY will seek to protect the confidentiality of reports and related information to the extent reasonably possible, taking into account the need to assess, investigate, escalate, and respond appropriately.

Information may be shared internally or with professional advisers, regulators, law enforcement, or other appropriate parties where reasonably necessary for review, investigation, legal compliance, or protection of ROECNY and affected parties.

At present, ROECNY uses its existing reporting channels for feedback, concerns, and misconduct reports.

• Use the ROECNY Feedback & Reporting page to submit a written report online.
• Email cs@roecny.com if you need to raise a concern directly in writing.
• Call (+1) 631 382 0555 for urgent matters that should be escalated promptly.

• Reports are reviewed to determine the nature of the concern and the appropriate handling path.
• ROECNY may route matters to relevant internal stakeholders, including management, legal, compliance, operations, or other responsible personnel.
• Where appropriate, ROECNY may conduct or coordinate a fact review, request supporting information, preserve relevant records, and determine next steps.
• ROECNY may take remedial, disciplinary, control, legal, or reporting action where warranted.

ROECNY may further develop its reporting framework over time, including additional intake channels, dedicated contact points, or more formalised case-handling processes.

If ROECNY introduces dedicated whistleblowing tools or independent service-provider channels in the future, this page will be updated accordingly.