Whistleblower Policy

1. Scope & protected disclosures

This Policy applies to workers, employees, Professionals, contractors, partners and Users. Protected disclosures include suspected fraud, corruption, bribery, money laundering, sanctions breaches, data-protection or privacy violations, financial malpractice, discrimination, harassment, health-and-safety risks, and breaches of law or of our policies.

2. How to report

Reports may be made confidentially to hello@luxnova.estate with the subject line “Whistleblower Report”. Please provide as much detail as possible, including what happened, who was involved, dates and any supporting information. Reports may be made anonymously where permitted by applicable law.

3. Confidentiality & anonymity

We treat all reports confidentially and disclose the reporter's identity only where required by law or necessary for a fair investigation, and wherever possible only with the reporter's consent. Anonymous reports will be assessed on their merits.

4. Non-retaliation

We strictly prohibit retaliation of any kind against any person who makes a good-faith report or assists an investigation. Retaliation includes dismissal, demotion, harassment, discrimination or any detriment. Any retaliation is itself a serious breach of this Policy and may result in disciplinary or contractual action.

5. Investigation process

Reports are acknowledged, assessed and, where appropriate, investigated promptly, proportionately and impartially. We will keep the reporter informed of progress to the extent legally and practically possible, and take appropriate corrective action where wrongdoing is substantiated.

6. Good faith & misuse

Protection applies to disclosures made in good faith and on reasonable grounds, even if later found to be mistaken. Knowingly false or malicious reports are not protected and may lead to action.

Severability & local-law adaptation

Each provision of this document is severable. If any clause, or part of a clause, is held to be invalid, unlawful or unenforceable under the mandatory law of any jurisdiction, that clause (or the affected part) shall be deemed modified to the minimum extent necessary to be valid and enforceable, and all remaining provisions shall continue in full force and effect.

Where a mandatory statutory right, disclosure or protection applicable to you in your country or region is not expressly reflected in this document, that right shall nonetheless apply to the extent required by law, and the remainder of this document shall remain valid and effective.

Where you believe that a specific term, condition, data-handling practice or consumer protection required by your local or regional law is not yet addressed here, please contact us at hello@luxnova.estate with an enquiry. We will review your request and, where appropriate, incorporate the required provision on a jurisdiction-specific basis while all other provisions continue to apply.