Whistleblowing Policy

Last Updated: December 16, 2025

Our commitment

Dream Finance OÜ is committed to integrity, transparency, and compliance with Estonia and EU legal standards.
If you observe behaviour that appears illegal, unethical, or improper, you can safely report it through our internal or anonymous channels.

We strictly prohibit any form of retaliation against individuals who report concerns in good faith. Every report is handled confidentially, professionally, and with respect for your rights.

What you can report

We encourage reporting concerns related to:

• Money laundering, terrorist financing, or sanctions violations
• Fraud, corruption, bribery, financial misconduct
• Violations of MiCA, DORA, Transfer of Funds Regulation (TFR), AMLD, DAC8 or other EU regulatory frameworks
• Unethical, abusive, discriminatory, or inappropriate workplace behaviour
• Data protection or cybersecurity breaches
• Violations of internal policies or legal obligations
• Misconduct that harms clients, employees, partners, or the public

If you are unsure – report anyway. We review every submission.

Your protection

We are committed to creating a safe environment where concerns can be reported without fear of retaliation or exposure. If you report a concern in good faith, you are protected under applicable Estonian and EU laws.

When you report a concern:

• Your identity is kept confidential.
• You may report anonymously.
• Retaliation, threats, or negative treatment are strictly prohibited.
• Reports are reviewed fairly, objectively and without delay.

Review Process and Timelines

We ensure that every report is assessed fairly, impartially, and without delay.

1. Acknowledgement: We confirm receipt of your report within 3 business days.
2. Review timeline: Our goal is to complete the initial assessment and investigation within 30 days.
3. If more time is needed due to complexity, we will keep you informed.

How to report

You may report a concern through any of the following channels:

1. Anonymous online form (below on this page)
2. Email: [email protected]
   Handling based on topic:
   • For AML/financial crime: handled by the MLRO
   • For unethical behaviour: handled by HR

We ensure appropriate separation of duties and confidentiality throughout.

External Reporting

In cases where internal reporting is not possible or appropriate, or if the whistleblower prefers to report externally, the following competent authorities in the Republic of Estonia may be used:

In cases where internal reporting is not possible or appropriate, or if reporter prefers to report externally, the following Estonian authorities may be used for submitting reports of illegal conduct, financial misconduct, whistleblower disclosures, etc.

1. Financial Intelligence Unit (Rahapesu Andmebüroo – FIU)
   • Reports related to money laundering, terrorist financing, sanctions compliance and suspicious financial transactions should be submitted via the FIU’s online reporting channel on fiu.ee.
   • In exceptional cases (e.g. if the online form is not usable), with prior agreement, a report may be sent by email to [email protected] – but a reasoned request must first be made.
   • The FIU publishes explanatory guidelines about how to prepare and submit reports (form, content requirements, procedural rules).
   • Website: https://fiu.ee
2. Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority)
   • For violations or misconduct in the financial services sector (e.g. licensing, market abuse, compliance failures), inform Finantsinspektsioon via their “Notify us about illegal activities” channel.
   • Methods of reporting to Finantsinspektsioon include:
     1. Email: [email protected]
     2. Online form (on their site) under “Notify us about illegal activities”
     3. Phone: +372 668 0555 (calls are recorded)
     4. If none of the above is suitable, one may call +372 668 0500 to request a meeting. In such cases, Finantsinspektsioon may grant anonymity for the reporter.
   • The reporter has the right to remain anonymous (unless revealing identity is necessary and consented), and confidentiality is to be preserved as far as possible under law.
   • Contact email for general enquiries: [email protected]
   • Address: Sakala 4, 15030 Tallinn, Estonia
3. Other competent authorities and Legal protection under Estonian Whistleblower Law
   • The Estonian Whistleblower Protection Act entered into force 1 September 2024, transposing the EU Whistleblower Directive.
   • Under this Act, the identity of the whistleblower can be revealed only with the whistleblower’s written consent, and retaliation (dismissal, demotion, etc.) is prohibited.

Whistleblowers are allowed to bypass internal channels and report directly to external authorities such a Tax and Customs Board, Police and Border Guard Board, Data Protection Inspectorate and other competent authorities depending on the nature of the matter.