Speak-Up program
If something looks wrong, report it. We will protect you.
- Statutory protection
- Dodd-Frank § 922 · SOX § 806
- Hotline vendor
- Independent third party
- Availability
- 24/7 · multilingual
- Anonymous
- Yes · end-to-end
What to report
If you are in doubt, report.
- 01
Financial misconduct
Accounting or financial-reporting irregularity, unreported related-party transactions, fraud on members or investors, false regulatory filings, and breach of the Financial Conduct Code. - 02
AML, sanctions, and BSA
Suspected failure to screen, onboard, monitor, or report as required; suspected facilitation of money laundering, sanctions evasion, or terrorist financing; Travel Rule violations. - 03
Market abuse
Insider trading, front-running, wash trading, spoofing, manipulation of registry data, or any conduct that would prejudice the fair operation of ORCH, Terminal, Market, or Attest. - 04
Regulatory non-compliance
Suspected breach of FinCEN, SEC, CFTC, FCC, ITU, or applicable non-US regulator requirements; misleading communications with regulators or counsel. - 05
Data protection and security
Unauthorised access to personal data, undisclosed breach of member data, circumvention of cryptographic controls, or tampering with the registry or Attest quorum. - 06
Ethics and conduct
Bribery, corruption, undisclosed conflict of interest, harassment, discrimination, retaliation, or any conduct that would fail the Code of Ethics standard of candour.
How to report
Four channels. All independent. All confidential.
Reporting channels
- Confidential hotline
- 24/7 multilingual telephone intake via independent vendor
Live operator. Calls can be made anonymously. Vendor is independent of Wavestar management.
- Web intake
- Secure web form hosted by the independent vendor
Supports anonymous submission, file attachment, and a secure follow-up ID for two-way conversation.
- Direct to Audit Committee
- audit-committee@wavestar.space
Email routed directly to the Chair of the Audit Committee of the Board of Directors.
- External counsel
- Reports may be made directly to external counsel
Contact details for standing whistleblower counsel are published in the staff handbook and on request.
- Regulator report
- SEC OWB · CFTC Whistleblower Office · FinCEN Tip Line
The right to report directly to a regulator is preserved and cannot be waived by any company policy or agreement.
Protection
Retaliation is prohibited. Always.
Wavestar prohibits any form of retaliation against a person who reports a concern in good faith, participates in an investigation, or refuses to participate in conduct they reasonably believe is unlawful. The prohibition covers termination, demotion, suspension, threats, harassment, pay or benefit reduction, adverse assignment, blacklisting, and any other materially adverse action. This protection applies to employees, former employees, contractors, agents, consultants, and third-party providers.
Statutory protections preserved
- Dodd-Frank § 922
- 15 USC 78u-6 · Securities whistleblower program, monetary awards, anti-retaliation provisions
Preserves the right to report to the SEC and to receive monetary awards for qualifying original information.
- CFTC whistleblower
- 7 USC 26 · Commodity Whistleblower Incentives and Protection
Mirror program for commodity markets. Awards up to 30% of monetary sanctions.
- Sarbanes-Oxley § 806
- 18 USC 1514A · Anti-retaliation protection for whistleblowers of public companies
Protection extends to subsidiaries and contractors of publicly held companies.
- Bank Secrecy Act § 6314
- Anti-retaliation protection for BSA and AML whistleblowers under the AML Act of 2020
Codified at 31 USC 5323. Awards of up to 30% of sanctions over USD 1M.
- Whistleblower Protection Act
- 5 USC 2302(b)(8) · Federal-employee protections
Protections where the employee is engaged with federal regulators or federal law enforcement.
- State law protections
- California Labor Code § 1102.5, New York Labor Law § 740, and analogous statutes
Additional state-level protections in the jurisdictions where we employ or operate.
Investigation
How reports are handled.
Principle
Why we protect speech.
A clearing house that silences its own people loses the first and best line of defence it will ever have.
Report a concern
Make a report. Anonymously if you choose.
The confidential hotline is operated by an independent third party and is available 24/7. If the concern involves the Audit Committee itself, contact external counsel directly. Your right to report to a regulator is always preserved.