Purpose
Coordinate the ethical, anti-bribery, transparency, privacy and cybersecurity practices that support sound ESG governance, upholding integrity, transparency, and accountability across all business activities. The code of ethics is documented in the employee handbook.
Steps
| # | Action | Details | Evidence |
|---|---|---|---|
| 1 | Adhere to a strict Code of Ethics and Conduct, covering integrity, accountability, and respect | Maintain and communicate the Code of Ethics and related standards of conduct. | Code of Ethics, standards, acknowledgements and training records |
| 2 | Enforce anti-corruption and anti-bribery policies with mandatory staff training | Provide periodic ethics, anti-bribery, privacy and security awareness. | Anti-bribery training completion records |
| 3 | Maintain transparent financial and operational reporting aligned with international standards | Ensure material governance and ESG communications are accurate, approved and evidence-based. | Approved governance and ESG communications |
| 4 | Enforce data privacy and cybersecurity standards to protect customer assets and information | Maintain channels for questions and confidential reporting of suspected misconduct. | Concern, investigation and remediation records |
| 5 | Apply conflict-of-interest, gifts, hospitality and third-party integrity controls | — | Conflict, gift and third-party integrity records |
| 6 | Assess and investigate concerns under the applicable HR, ABC, compliance, privacy or security procedure | — | Concern, investigation and remediation records |
| 7 | Track remediation, disciplinary action and lessons learned and report material matters to management and the Board | — | Concern, investigation and remediation records |
Governance Pillars
- Ethical Conduct — Upholding integrity, transparency, and accountability across all business activities. We refer to our code of ethics documented in the employee handbook.
- Risk Management — Proactively identifying and addressing risks to safeguard the organization and its stakeholders. We refer to our Risk Management Framework Manual where this is documented.
- ESG Integration — Embedding sustainability considerations into investment decisions, product development, and operational strategies.
Proportionality Considerations
- Maintain concise, principle-based governance policies as a small VASP.
- Introduce board committees, independent oversight, and ESG audits progressively as complexity increases.
- The Compliance Officer and Management Board share responsibility for maintaining ethical, transparent, and sustainable practices.
Records
- Code of Ethics, standards, acknowledgements and training records
- Conflict, gift and third-party integrity records
- Anti-bribery training completion records
- Concern, investigation and remediation records
- Approved governance and ESG communications
Relationships
- Policy: POL-ESG-001 Governance Ethics and ESG Manual
- Process: PRC-GRO-001 Governance Risk and Outsourcing
- Control: CTRL-ESG-005 Ensure Ethical Conduct and Governance Standards Operate
History
- 2026-07-26: Created from section 4.1 of the approved ESG Manual.