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Policies

Whistleblowing Policy

Glasial Remittance Ltd
Incorporation Number: BC1418776
Registered Address: 19628 55A AVENUE, SUITE 28, LANGLEY BC V3A 3X2, CANADA

1. Purpose and Scope

Glasial Remittance Ltd (“the Company”) is committed to the highest standards of ethical conduct, transparency, and regulatory compliance. This Whistleblowing Policy establishes a clear framework for employees, contractors, directors, shareholders, and other associated persons to report suspected misconduct, unlawful activity, or breaches
of Company policy.

 

The Policy ensures that reports are handled confidentially, investigated thoroughly, and that whistleblowers are protected from retaliation in accordance with applicable Canadian laws and regulations, including but not limited to:

 

  • The Criminal Code of Canada (offenses such as fraud, bribery, corruption, money laundering, and terrorist financing).
  • The Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA) and related FINTRAC reporting obligations.
  • Federal and provincial Employment Standards Acts, Human Rights Codes, and other workplace protections.
  • Other applicable Canadian corporate, tax, and financial services legislation.

2. Who Can Report (Notification Eligibility)

The following individuals are entitled to make a report (“Whistleblowers”):

 

  • Employees of the Company, whether permanent, temporary, or on probation.
  • Members of the Board of Directors and Company officers.
  • Shareholders and investors.
  • Contractors, consultants, and service providers engaged by the Company.
  • Former employees or contractors, if the information relates to their prior relationship with the Company.
  • Any individual with a direct work-related connection to the Company’s business activities.

3. What Can Be Reported (Reportable Violations)

Whistleblowers may report concerns involving, but not limited to, the following:

Criminal Offenses

  • Fraud
  • Corruption
  • Bribery
  • Money laundering
  • Financing of terrorism
  • Embezzlement
  • Forgery

Regulatory Breaches

  • AML/CTF violations
  • PCMLTFA non-compliance
  • FINTRAC reporting failures
  • Sanctions violations
  • Financial regulations breaches

Ethical Violations

  • Unethical conduct
  • Gross mismanagement
  • Conflicts of interest
  • Abuse of position

Policy Breaches

  • Internal policy violations
  • Code of conduct breaches
  • Safety violations
  • Privacy breaches

4. Reporting Channels (Submitting a Notification)

Glasial Remittance Ltd provides secure, confidential, and accessible channels for whistleblowers:

1. Email Reporting

Reports may be submitted to the designated Competent Person at:

📧 support@glasial.com

2. Written Submission

Reports may be submitted in writing to the Company’s registered office:

📍 Glasial Remittance Ltd
19628 55A AVENUE, SUITE 28, LANGLEY BC V3A 3X2, CANADA

Important: All reports should, where possible, include sufficient detail and supporting evidence to enable proper investigation. Anonymous reports will be accepted; however, anonymity may limit the Company’s ability to investigate thoroughly or provide feedback to the whistleblower.