Code of Ethics and Conduct
A Message from Management
At Key2Pay Technologies Ltd, our mission is to transform the financial sector with innovative, secure, and transparent solutions. This goal is only possible if we act with unwavering integrity. This Code is not just a document; it is the compass that guides each of our decisions and actions. It represents our collective commitment to excellence, trust, and respect. We are counting on you to embody these principles every day and to build together an environment of which we can all be proud.
We are counting on you to embody these principles every day and to build together an environment of which we can all be proud.
1. To Whom Our Code Applies
This Code is the cornerstone of our culture and applies to everyone who is part of the Key2Pay Technologies Ltd family, without exception:
a. Employees: Directors and employees of the company.
b. Business Partners: Suppliers, consultants, agents, and any third party acting on our behalf.
In the event of a conflict between this Code and local laws, we will always apply the standard that imposes the highest level of ethical conduct.
2. Our Fundamental Principles
Our conduct is based on five core principles:
a. We Act with Integrity and Transparency: Honesty and clarity are the foundation of all our relationships, both internal and external.
b. Rigorous Regulatory Compliance: We comply with all laws, financial regulations, and internal policies. Legality is not an option; it is our starting point.
c. Respect for People: We foster an inclusive environment where diversity is valued and any form of discrimination or harassment is rejected.
d. Confidentiality and Data Protection: We protect the information of our clients, partners, and the company itself as our most valuable asset.
e. Zero Tolerance for Corruption: We actively reject fraud, bribery, money laundering, and any corrupt practices.
3. Our Commitments to Conduct
3.1. An Inclusive and Respectful Work Environment
a. We are committed to maintaining a safe, collaborative work environment free from any form of harassment, intimidation, or discrimination based on gender, ethnic origin, religion, sexual orientation, age, disability, or any other status.
b. We promote open communication, honesty, and constructive feedback at all levels of the organization.
3.2. Relationships with Clients and Partners
a. We offer products and services with clear, accurate, and truthful information, ensuring our clients make informed decisions.
b. We build relationships based on trust, service excellence, and fulfilling our promises.
c. We protect their personal data and confidential information with the highest security standards.
3.3. Relationships with Third Parties and Competition
a. Zero Tolerance for Corruption: We strictly prohibit offering, giving, soliciting, or accepting bribes, improper payments, or any illegal advantage to obtain or retain business.
b. Fair Competition: We compete in the market fairly and ethically, respecting free competition
laws.
c. Transparency: We maintain honest and transparent relationships with suppliers, government authorities, and other external entities.
3.4. Use of Company Assets and Resources
a. We protect KeyPay Techonogies Ltd’s assets, including intellectual property, technological equipment, and funds, using them responsibly and exclusively for professional purposes.
b. We ensure information security by complying with cybersecurity policies and reporting any incidents immediately.
4. Gifts, Entertainment, and Hospitality
We understand that exchanging courtesies can strengthen business relationships, but it must never compromise our objectivity.
a. It is prohibited to solicit gifts, favours, or entertainment of any kind.
b. We may accept gifts or invitations of symbolic value and on an occasional basis, provided they cannot be perceived as an attempt to influence a business decision. When in doubt, consult the Compliance Committee.
c. We record all gifts offered or received, in accordance with internal policy, to ensure maximum transparency.
5. Conflicts of Interest
A conflict of interest arises when our personal interests interfere, or appear to interfere, with the
interests of Key2Pay technologies Ltd.
a. We have an obligation to proactively identify, declare, and manage any relationship (personal, family, financial) that could create a conflict.
b. We abstain from participating in decisions where our objectivity could be compromised.
6. Ethics and Reporting Channel
We believe in an environment where everyone feels safe to speak up.
a. We provide a confidential and secure Reporting Channel to report any potential violation of this Code.
b. What can be reported? Fraud, corruption, bribery, harassment, discrimination, misuse of assets, or any unethical conduct.
c. c. Guarantee of non-retaliation: Key2Pay Technologies Ltd strictly prohibits any form of
retaliation against anyone who reports a concern in good faith. All reports, anonymous or not, will be investigated fairly and rigorously.
7. Application of the Code and Consequences
a. Oversight: The Compliance and Risk Prevention Committee is responsible for overseeing the application of this Code, as well as its periodic review.
b. Consequences: Failure to comply with this Code will have consequences. Disciplinary measures will be proportional to the severity of the offense and may range from a formal warning to the termination of the employment or contractual relationship, without prejudice to any applicable legal action.
8. Our Personal Commitment
This Code only comes to life through our daily actions. Therefore, every person who is part of the Key2Pay Technologies Ltd family commits to:
a. Knowing and Applying the principles and rules of this Code at all times.
b. Consulting and Asking the Compliance department with any questions about how to act ethically.
c. Reporting and Speaking Up by using the Ethics Channel if they observe conduct that may violate our principles.
