EBANX COMPLIANCE & CORPORATE GOVERNANCE
Code of Conduct
Effective Date: July 8, 2024
Expiration Date: July 8, 2025
Index
Ebankers
1. Values
2. Diversity, Equity, and Inclusion
3. Work Environment
4. Training and Awareness
5. Internal Fraud Prevention
6. Ethics and Integrity
6.1. Conduct Committee
6.2. Report violations to the appropriate authorities
6.3. Commitment to Integrity
Society
1. Sustainability in business
2. Social Impact
3. Care for the environment
Business
1. Anti-Bribery and Anti-Corruption
2. Gifts, Presents, and Hospitality
3. Conflicts of Interest
4. Prevention of Money Laundering and Terrorist Financing
5. Compliance with regulations and laws
6. Records Retention
7. Information Security
8. Artificial Intelligence
9. Image and Reputation
EBANKERS
1. Values
EBANX’s values have driven the company's growth since its founding in 2012. Through them, EBANX connects global companies with customers in the world's fastest-growing digital markets, enabling millions of consumers to access international products and services.
Ebankers share these values, guided by respect for human life, economic, social and environmental sustainability, and EBANX's business mission: to improve access.
Knowledge: ebankers believe knowledge opens many doors and is the key to sustainable growth. At EBANX, knowledge of the business, the digital and payments industry, and self-knowledge are always encouraged through study and practice.
Commitment: ebankers are committed to promoting global access for all. EBANX is motivated by passion, respect, and trust in the work of each ebanker in pursuit of development and growth – personal, professional, and of the company.
Persistence: ebankers work with persistence, resilience, and creativity to solve challenges and achieve shared objectives. EBANX is proud of every achievement and lesson learned and persists in its mission.
Results-Oriented: ebankers know where they want to go and direct their actions toward their desired results. At EBANX, knowledge is encouraged, commitment and results-driven persistence are given, and achievements are always celebrated.
Big Dream: EBANX's vision is vast and limitless. ebankers are driven by the desire to innovate, reinvent, and have an impact. ebankers dream big daily to achieve personal and professional fulfilment and help promote access.
2. Diversity, Equity, and Inclusion
EBANX is a diverse company made up of diverse people. For EBANX, it is important that each ebanker feels comfortable being who they are and fosters diversity. In addition to valuing people, EBANX believes that diversity is the only way to continue to grow the company's capabilities, drive innovation, and fulfil its mission of providing access.
EBANX is committed to having diverse people working on business solutions, acting on initiatives that contribute to the equity of underrepresented groups, and being a space for inclusion so that each ebanker can be their best professional self.
In addition to seeking to ensure an inclusive work environment, EBANX does not tolerate prejudice or discrimination based on gender identity and expression, race and ethnicity, disability, sexual orientation, nationality, age, social class, religion, beliefs, or other related statuses. We invite all ebankers to be ambassadors for diversity - and to make inclusion a practice.
3. Work Environment
EBANX conducts its business in compliance with all applicable environmental and workplace health and safety laws and regulations. For this to happen, the company has established guidelines to ensure that the actions of all ebankers provide a safe and healthy work environment for everyone and avoid adverse impacts and damage to the environment and the communities in which the company operates.
Interactions between ebankers are based on respect, transparency, and team spirit. To this end, it is vital that all ebankers:
Work so that respect and interpersonal collaboration prevail in pursuing goals.
Respect human rights and labor relations.
Recognize diversity, respect differences, and never discriminate based on religion, nationality, age, gender identity, race and ethnicity, disability, sexual orientation, or political views, or promote any prejudice or hate speech.
Fight against and denounce any racist or sexist treatment or that which could be seen as sexual or moral harassment.
Preserve the integrity of their work, never using it or the information gathered due to their professional activity to sway decisions that could favor private interests or those of third parties.
Respect intellectual property, recognizing the value and authorship of projects, ideas, proposals, and initiatives.
Always keep internal processes and documents secure and confidential.
Use internal media only for work-related matters and in a constructive manner.
Use all materials provided responsibly and appropriately, exclusively for work-related activities, ensuring the equipment is kept safe and well preserved.
Assist in the internal dissemination of this Code of Conduct.
And remember that it is the responsibility of all ebankers NOT to:
Discriminate in recruitment, promotion, and retention.
Use drugs on EBANX premises at any time or at their home office during working hours.
Commit any acts of hostility, intimidation, or violence against others in the workplace and in places where business is conducted.
Bring firearms, explosives, or any other weapons onto EBANX premises or into any work-related environment, regardless of whether they have a license to carry such weapons.
EBANX may hold parties and happy hours where alcoholic beverages are served. At these events, it is important to remember that consumption must be mindful, without excess, and that the consumption of alcoholic beverages by people under 18 years of age is prohibited.
4. Training and Awareness
Learning is one of EBANX's core values. To promote learning in each ebanker's journey, everyone has access to development tools and training, encompassing both hard and soft skills.
During the onboarding process, new ebankers are introduced to some of this content and gain access to the EBANX Academy platform, which includes mandatory courses--the Must Dos--that must be taken within the first 30 days.
In addition, they are introduced to a number of topics to raise awareness, many related to the Code of Conduct, such as respect and well-being in the work environment, harassment prevention, strengthening the company’s culture, diversity and inclusion, and information security.
5. Internal Fraud Prevention
Internal fraud prevention is vital to the integrity, continuity, and reputation of the company. In addition to compromising EBANX’s assets, confidence in the institution, and financial statements, fraud can directly affect the employees involved.
EBANX is committed to maintaining high ethical standards and acting transparently in all operations and matters related to accounting, financial controls, internal reporting and taxation. The company strives for compliance with accounting principles and the integrity of records, which must not be distorted to conceal, disguise, or otherwise alter our true financial position.
In addition, no conduct must be carried out using deception or trickery for one’s own benefit or that of a third party.
EBANX has a structured Risk Management program in place to monitor its financial processes and respective controls and assess the risks and impacts that could affect the sustainability of its operations.
All ebankers are responsible for adhering to established internal policies and controls and actively collaborating in the prevention, identification, and reporting of any suspected fraudulent activity or behavior.
6. Ethics and Integrity
EBANX’s Ethics and Integrity program is a set of internal initiatives and regulations that guarantee transparency and prevent irregular process practices.
It includes the code in question and other policies, such as the Anti-Bribery and Anti-Corruption Policy and the Gifts, Presents, and Hospitality Policy.
To ensure this program’s effectiveness, EBANX offers the EBANX Helpline, a whistleblowing channel hosted by a third party, which guarantees the confidentiality of the information reported, preserves whistleblowers’ anonymity, and forwards the reports received, following best market practices.
Violations of this Code of Conduct, human rights, company policies, any illegal or irregular practices, or other matters that may cause harm to EBANX or ebankers should be reported by ebankers or third parties through the EBANX Helpline.
The EBANX Helpline is a crucial pillar of the EBANX Global Compliance Program. It is available 24 hours a day, seven days a week. To access it, visit www.ebanxhelpline.com or call 0800 512 5577.
6.1 Conduct Committee
The Conduct Committee is responsible for evaluating violations of the following:
➔ EBANX Values.
➔ Code of Conduct.
➔ Policies that supplement this Code; and
➔ Applicable laws.
This Committee is also solely responsible for deciding on the applicable legal and/or disciplinary measures. Additional responsibilities of the Conduct Committee include evaluating cases not covered in the above documents and choosing the person or area responsible for them, among others.
6.2 Reporting violations to the appropriate authorities
Violations of the Code involving illegal behavior will be reported to the appropriate authorities.
All ebankers are entitled to certain protections for cooperating or reporting legal violations to government agencies or entities and self-regulatory organizations. As such, nothing in this Code is intended to prohibit disclosing or reporting violations or cooperating with a government agency entity or self-regulatory organization, even without notifying EBANX.
No ebanker will be retaliated against for any of these activities, and nothing in this Code or otherwise requires ebankers to forego any monetary award or other payment to which they may be entitled from a governmental agency entity or self-regulatory organization.
Retaliatory conduct includes dismissal, demotion, suspension, threats, harassment, and any other form of discrimination in terms and conditions of employment due to any legal act that an ebanker may have performed.
All ebankers have the right to:
Report possible violations of laws or regulations that have occurred, are occurring, or are about to occur to any government agency entity or self-regulatory organization.
Voluntarily cooperate or respond to any inquiry or provide testimony before any self-regulatory organization or any other federal, state, or local regulatory or law enforcement authority.
Make reports or disclosures to law enforcement or regulatory authorities without prior notice or authorization from EBANX.
Disclose confidential company information, including the existence and terms of any confidential agreements between the ebanker and EBANX (including employment or termination agreements), to any government agency or entity or self-regulatory organization.
Respond truthfully to a valid summons.
EBANX cannot:
Require ebankers to withdraw reports or filings alleging possible violations of federal, state, or local laws or regulations or offer any type of incentive, including payment, to do so.
Ebankers are protected by whistleblower laws, including a monetary award, if any, that cannot be waived by any agreement, policy form, or condition of employment, including a pre-dispute arbitration agreement.
Even if an ebanker has participated in a potential violation of the law, they may be eligible to participate in the confidentiality and retaliation protections offered by applicable whistleblower laws, and they may also be eligible to receive an award under those laws.
6.3 Commitment to Integrity
EBANX is strongly committed to honesty and integrity and fully complies with all applicable laws, rules, and regulations. No ebanker should commit an illegal or unethical act or instruct others to do so for any reason.
EBANX and ebankers are committed to maintaining the integrity of their business relationships in a transparent and fair manner, and to working with customers and suppliers who share and respect these values and act under this Code of Conduct.
Regarding customers and suppliers, every ebanker must:
Act transparently and impartially.
Comply with agreements signed with third parties.
Be open and receptive to criticism, suggestions, and requests.
Ensure that customers and suppliers receive clear, accurate, and appropriate feedback on their questions and requests.
Recognize and report possible errors made by customers or suppliers.
Respect privacy, ensuring that information relating to customers or suppliers is treated confidentially and used only with their knowledge.
Make purchasing, contracting, and sales decisions based solely on technical and professional criteria.
Each ebanker must guarantee the quality of the services provided by EBANX and its suppliers. Any violation of this Code or the Company’s Policies must be reported through the EBANX Helpline.
SOCIETY
1. Sustainability in business
EBANX is committed to conducting its operations in a responsible and sustainable manner, taking into account not only the economic impact but all the impacts of its activities on society. EBANX believes that an ethical and sustainable business approach is fundamental to promoting the well-being of the communities in which it operates and ensuring long-term success.
EBANX’s operations are guided by the principles of integrity, transparency, equity, accountability, and sustainability. EBANX aims to maintain high integrity, transparency, and ethics standards in all business activities and relationships. Seeking fair and equal treatment for stakeholders, considering their rights, duties, needs, interests, and expectations.
We recognize the responsibility to the countries and regions where EBANX operates and to contribute positively to their socio-economic development—maintaining high standards of corporate governance to ensure accountability, transparency, and protection of the interests of all stakeholders and ensuring the economic and financial viability of the organization, seeking to reduce the negative impacts of its business and operations while increasing the positive ones.
EBANX is committed to integrating these principles into all areas of its business and to working collaboratively with ebankers, customers, suppliers, and partners to achieve sustainability goals and promote a lasting positive impact.
2. Social Impact
EBANX seeks to impact society by looking first at its main asset: its team of ebankers. EBANX offers a series of initiatives to provide a pleasant and welcoming work environment and offers development paths for ebankers to explore their own potential and grow along with the business.
We take seriously the Internal Compensation Policy, which seeks fairness in compensation. The salary scale adopted is based on market analysis and makes EBANX competitive in the labor market and internally equitable. All ebankers receive compensation appropriate to the salary range of their peers or similar positions.
EBANX also seeks to offer a complete wellness benefits package. Ebankers receive food vouchers, transportation vouchers, life insurance, health plans, and educational and wellness benefits.
In addition to looking after the internal community, EBANX also carries out actions that impact society. With an increasingly global presence, the company seeks to generate local impact by being close to the community and supporting cultural and social development programs. Giving back is part of EBANX's culture, and being involved in initiatives that truly transform people's lives is an aspect that is related to its strategy.
At EBANX, we support initiatives aligned with internal values and vertical values to promote:
Diversity, equity, and inclusion of underrepresented groups, especially for women, black people in Brazil, people with disabilities and the LGBTQIA+ community.
Democratization of culture via a Funding Notice, allocating income tax resources to bring art to different socioeconomic groups.
Fundraising campaigns to contribute to society's most pressing needs.
Access to knowledge and community empowerment occurs through technical meetups led by ebankers and the socio-educational Codes of Tomorrow program, which trains people from groups typically underrepresented in technology.
3. Care for the environment
EBANX seeks to operate its business environmentally and socially responsibly, collaborating with its customers to address global sustainability challenges.
Conducting business guided by the principles of environmental and social responsibility is fundamental to EBANX's success. It reflects the company's commitment to the well-being of the planet and the communities in which it operates and to a more sustainable and prosperous future for all.
BUSINESS
1. Anti-Bribery and Anti-Corruption
EBANX values integrity in its relationships, rejects corruption and bribery practices, and has zero tolerance for them. It always seeks transparency and integrity.
The Anti-Bribery and Anti-Corruption Policy establishes the expected conduct of ebankers and third parties with whom EBANX conducts business and sets out guidelines for gifts, presents, and hospitality; conflicts of interest; the registration of financial transactions; relations with public officials; relations with third parties; and donations and sponsorships.
2. Gifts, presents, and Hospitality
Gifts, presents, and hospitality can only be offered or accepted if they do not influence or appear to influence EBANX's decisions or those with whom the company maintains business relations.
Exchanging gifts, presents, and hospitality to generate or appear to generate an advantage in the business relationship and/or illegal acts is unacceptable.
The exchange of gifts, presents, and hospitality is an acceptable way of establishing business relationships and demonstrating esteem in the business environment. When offering and receiving gifts, presents, and hospitality, it is essential to follow certain guidelines, such as:
Respect local and foreign legislation regarding the prevention of bribery and corruption.
Only offer or accept gifts, presents, and hospitality if the item(s) are within the amount allowed by the Gifts, Presents, and Hospitality standard.
Always be transparent when offering or accepting gifts, presents, and hospitality, document the exchange, and record expenses.
The exchange must not influence or appear to influence EBANX’s decisions or the decisions of those with whom the company has business relations.
The exchange must not unduly favour or appear to favour a specific partner.
Any gifts, presents, or hospitality that could result in a feeling of personal obligation must not be given or accepted.
Favours or perks with commercial value offered by customers, suppliers, partners, third parties, public agents, and other public or private entities must be refused. It is particularly forbidden to accept or offer gifts or business entertainment of any kind to any public agent without the prior approval of the Risk & Compliance teams.
It is forbidden to accept or offer entertainment that could be embarrassing for third parties, EBANX, or ebankers, such as that of a sexual nature.
3. Conflicts of Interest
All ebankers must conduct themselves honestly and ethically, always keeping the company’s best interest in mind.
A conflict of interest occurs when a person's private interests interfere, or appear to interfere, with the interests of EBANX, including those of its subsidiaries and affiliates. A conflict of interest can arise when an ebanker takes an action or has an interest that makes it difficult for them to carry out their work objectively and effectively. It can influence or appear to influence people's conduct and decisions.
All ebankers should strive to avoid situations that present a potential or actual conflict between their interests and those of the company. Examples of prohibited situations include:
Carrying out a professional activity externally equivalent to that carried out at EBANX or related to EBANX's business models.
Using company assets and resources, such as facilities, equipment, email accounts, software, etc. for personal benefit. All ebankers must protect such assets against loss, theft, or misuse. Any suspected loss, misuse, or theft must be reported through the EBANX Helpline.]
Accepting gifts of more than modest value or receiving personal discounts (if such discounts are not generally offered to the public) or other benefits due to your position in the company from a competitor, customer, or supplier.
Sharing confidential information or knowledge at external events or activities.
Favouring merchants, customers, suppliers, competitors, or partners out of personal
interest.
Working for a competitor, customer, or supplier while employed by EBANX.
Competing with EBANX in the purchase or sale of property, products, services, or other interests. Competition can include involvement in the same line of business or any situation in which the ebanker takes away opportunities to sell or purchase property, products, services, or interests.
Having an interest in a transaction involving the Company, competitor, customer, or supplier (except as an employee, director, or director of the Company and not including routine investments in publicly traded companies).
Receiving a loan or security for a bond because of your position with EBANX.
Directing business to a vendor owned or managed by, or that employs, a relative or friend.
In addition to the above, there is also the issue of subordinate relationships between family members (spouse, partner, or relatives up to the fourth degree by consanguinity or affinity, linear or collateral, such as father, mother, children, grandparents, grandchildren, nephews and nieces, cousins, uncles and aunts, in-laws and brothers-in-law). Such situations must be avoided, as they may cause a conflict of interest when carrying out professional activities.
All ebankers are prohibited from taking for themselves business opportunities that are discovered using corporate property, information, or standing. No ebanker may use corporate property, information, or standing for their own personal gain or to compete with EBANX.
Should a real or apparent conflict of interest arise, the conflict must be handled ethically, following this Code.
EBANX senior executives must disclose any transaction or material relationship that could reasonably give rise to such a conflict to Risk & Compliance leadership.
If you have any questions, contact the Risk & Compliance teams.
4. Prevention of Money Laundering and Terrorist Financing
The possibility of third parties (Merchants, End Users, Providers and other persons or entities that may establish relationships with us) trying to use EBANX services and products for money laundering is real.
Money laundering refers to hiding the illicit origins of financial assets so that they appear to be licit. EBANX rejects these practices. If misuse of these services is suspected, every ebanker must:
Collect as much information as possible about the third party, following appropriate internal policies and procedures (KYP, KYM, KYC, among others).
Never integrate third parties who may use EBANX services and products to facilitate money laundering.
In the event of reasonable suspicion of illegal activity on the part of an already integrated third party, inform the Risk & Compliance team immediately, highlighting all evidence that proves such suspicion. It is important to remember that the third party should not, under any circumstances, be made aware that they are under suspicion.
The Risk & Compliance team is available for further consultation and clarification if you have any questions.
Remember that EBANX has zero tolerance for money laundering and is committed to mitigating money laundering risks. EBANX will take the necessary preventive measures and will promptly investigate any suspicion of money laundering. EBANX's Senior Management is committed to the effectiveness and continuous improvement of the AML/CTF Program.
5. Compliance with Regulations and Laws
Antitrust laws prohibit agreements between competitors on issues such as pricing, conditions of sale to customers, and the division of markets or customers.
These laws are complex, and violating them can result in serious consequences for the company and its employees, including criminal sanctions such as fines, imprisonment, and civil liability. If there are any questions regarding EBANX's antitrust compliance policies, consult the Legal & Regulatory team for additional clarification.
6. Records Retention
All EBANX business records and communications must be clear, true, and accurate. Ebankers should avoid exaggerations, assumptions, legal conclusions, and derogatory comments or characterizations of people and companies. This applies to all forms of communication, including e-mail and “informal” notes or memos. Records must always be handled by record retention rules.
If an ebanker is unsure whether a document should be kept, they should consult the Risk & Compliance Information Security, and Corporate Governance teams before proceeding.
7. Information Security
It is essential to protect confidential verbal or written information. But what exactly is confidential information?
This is information that, if accessed without authorization, could cause irreversible damage to our business and/or EBANX's reputation. It may or may not be identified as “confidential” and must be kept in strict confidence, except where disclosure is authorized by us or required by law. On the other hand, the disclosure of public information does not harm the organization.
EBANX's confidential information may include:
Proprietary information and all non-public information that may be useful to competitors or harmful to the company, its customers, or suppliers if disclosed.
Intellectual property, such as trade secrets, patents, trademarks, and copyrights, as well as business plans, research and new products, objectives and strategies, records, databases, salary and benefits data, employees’ medical information, lists of customers, employees, and suppliers, and any unpublished financial or pricing information that must also be protected.
EBANX considers the unauthorized use of or distribution of proprietary information to violate this Code of Conduct and may be illegal even after the ebanker leaves the company. Such use or distribution may negatively affect EBANX and the individuals involved, including possible legal and disciplinary action.
The personal data of EBANX stakeholders is considered confidential information. Personal data is any form of data that can be used to identify an individual. EBANX protects this data in order to protect people’s privacy and fundamental rights.
Therefore, you should keep all information about EBANX and its stakeholders confidential and avoid discussing it in public spaces or sharing it on social networks.
Care must be taken when discussing this, even within the company's premises, as not all information is public to all ebankers. In addition, publicly naming third parties with business relationships with EBANX should be avoided, as confidentiality agreements may have been signed with them.
8. Artificial Intelligence
Artificial intelligence (AI) is increasingly present in society and, consequently, in EBANX's daily operations, providing significant benefits for the company.
Although EBANX does not prohibit using artificial intelligence, all ebankers must understand the importance of using this technology ethically and responsibly.
AI offers numerous opportunities to improve operations and drive innovation, but it also brings potential risks that must be carefully considered and mitigated.
To this end, it is essential to guarantee the privacy and security of EBANX data, according to its classifications (PUBLIC, INTERNAL USE, RESTRICTED and CONFIDENTIAL), avoiding - whenever possible - the sharing of information when using AI solutions and/or chatbots, such as ChatGPT and similar.
9. Image and Reputation
Ebankers are the personification of EBANX's values and business. When representing EBANX, whether on professional or social occasions, ebankers must follow the corporate values and the principles of integrity expressed in this Code, never adopting practices that compromise the company's image, reputation, or interests.
It should be noted that when approached with an invitation to speak on behalf of EBANX - whether at events or interviews - ebankers must follow the rules in the Ebankers Speakers Standard by informing the Marketing department and waiting for guidance on how to proceed.
As an ebanker, I always keep in mind that private actions can impact EBANX's reputation, whether they are carried out in person or through social networks.
As a company and brand, EBANX values diversity and respects differences. However, ebankers mustn't publicly express opinions on certain topics, such as politics, religion, beliefs, and sports, when officially representing EBANX on official communication platforms, at events, or in other situations and environments.
On their personal platforms, when expressing opinions or engaging in discussions on these topics, ebankers must refrain from mentioning or making any relationship with EBANX (using hashtags, for example).
When using a social media or a professional networking site and identifying yourself as an ebanker or mentioning EBANX, you should follow these recommendations:
Never disclose sensitive information about EBANX or its business, customers, or suppliers.
Ensure that the opinions expressed are yours and not those of EBANX.
Remember that the company's commitment to equal opportunities, non-discrimination, and fair employment applies to social media sites.
Be respectful to colleagues and all people associated with EBANX, including customers and suppliers.
Immediately report any social media content that is inaccurate or inappropriate to the Public Relations team.
Never respond to any request for information about EBANX sent by media outlets, other companies and/or individuals before confirming with the responsible team.
Never engage in discussions and/or respond to comments that may contain inaccurate information about EBANX or complaints about the company.
Never publish documents, parts of documents, images, or video or audio recordings made with EBANX property, products, services, or people without approval.