Legal
Whistleblower Policy
RohoPay encourages anyone with knowledge of misconduct to speak up. We are committed to protecting those who report concerns in good faith.
What to report
Financial misconduct, regulatory violations, unethical behavior, or security concerns — reasonable suspicion is enough.
You do not need to be certain misconduct occurred to file a report
Our protection
Anyone who reports a concern in good faith is protected, regardless of the outcome.
Purpose
This policy establishes a framework for reporting concerns about unethical behavior, financial misconduct, regulatory violations, or other wrongdoing at RohoPay. It applies to all employees, contractors, merchants, and third parties who interact with the company. The goal is to ensure that concerns are heard, investigated, and resolved — and that anyone who reports them is protected.
What Constitutes a Reportable Concern
You should report if you have knowledge or reasonable suspicion of any of the following:
Financial misconduct
Fraud, embezzlement, misappropriation of funds, falsification of financial records, or manipulation of transaction data.
Regulatory violations
Non-compliance with applicable laws, regulations, or licensing requirements related to payment processing, anti-money laundering, or data protection.
Unethical behavior
Bribery, corruption, conflicts of interest, harassment, discrimination, or any conduct that violates RohoPay's code of conduct.
Security concerns
Unauthorized access to systems, data breaches, or circumvention of security controls that could compromise the integrity of the platform.
Merchant or customer harm
Practices that knowingly expose merchants or customers to financial loss, fraud, or privacy violations.
How to Report
Reports can be made anonymously. Send your concern to whistleblower@rohopay.com. Please include as much detail as possible: what happened, when it occurred, who was involved, and any supporting evidence (documents, screenshots, transaction references).
You do not need to be certain that misconduct occurred — a reasonable suspicion is sufficient. We would rather investigate and find nothing than miss a genuine concern.
Anti-Retaliation
RohoPay strictly prohibits retaliation against anyone who reports a concern in good faith. This protection applies regardless of whether the investigation confirms the reported concern. Retaliation includes, but is not limited to: termination, demotion, harassment, intimidation, reduction in responsibilities, or any other adverse employment action.
Anyone found to have retaliated against a reporter will be subject to disciplinary action, up to and including termination.
Investigation Process
1. Acknowledgment
All reports are acknowledged within 5 business days. Anonymous reporters who provide a contact method will receive confirmation.
2. Assessment
The report is reviewed by a designated compliance officer to determine the appropriate scope and severity of investigation.
3. Investigation
A thorough, impartial investigation is conducted. Relevant documents are reviewed, individuals are interviewed, and evidence is gathered.
4. Resolution
Findings are documented and appropriate corrective action is taken. The reporter is informed of the outcome to the extent possible without compromising confidentiality.
Have a concern?
Report it confidentially — retaliation is never tolerated.
