FinTrU Code of Conduct 2025

Our Code of Conduct

FinTrU’s Code of Conduct (“Code”) is designed to help and protect us and sets out the ground rules for everything we do at FinTrU. It is a statement of FinTrU’s commitment to integrity and the highest ethical standards that are expected from all of our employees. It should guide us to make the right decisions when performing our roles.

The 2025 Code will be reviewed and updated on an annual basis, or more regularly when necessary changes are required to be made. The Code is distributed to all employees annually and is published both on FinTrU’s internal policy portal, accessible to all employees, and externally on our company website. Compliance with the Code will be monitored by the Risk & Compliance Manager.

All FinTrU employees, interns and contractors (collectively referred to as “employees”) in all jurisdictions in which we operate, are responsible for understanding and abiding by the Code. Training on key aspects of the Code will be provided to all employees at various intervals.

Whenever an expectation in the Code is unclear, employees should speak with their manager. If employees are uncomfortable speaking with their manager, they can contact Human Resources or the Risk & Compliance Manager for guidance.

Accountability

All employees have a responsibility to maintain the trust of our clients and stakeholders and to comply with all applicable laws and regulations.

We expect all employees at all levels within FinTrU to:

Act with integrity and be accountable, committing to upholding the Code and making sure that you can answer for your acts or omissions.
Show respect to everyone, promote equality, diversity and inclusion and communicate in an open and effective way.
Build trust by making honest, ethical and transparent decisions, seeking advice when things are unclear.
Understand the risks associated with your role and how to manage them effectively.
Promptly complete all ethics and compliance training assigned to you.
Speak up – understand that it is your duty to report any suspected breaches of the Code.

As leaders, we expect all managers and supervisors, irrespective of corporate level, to:

Lead by example, demonstrating and reinforcing the Code.
Commit time to nurture your team to fulfil their ambitions and accomplish their goals within the remit of the Code, boosting our high performing culture.
Help employees understand how the Code applies to them and actively support employees to ensure adherence.
Hold employees accountable for adhering to the Code and company policies.
Ensure that members of your team have time to complete mandatory ethics and compliance training.
Foster a work environment where employees feel comfortable speaking up without fear of reprisal.
Be alert to breaches of the Code and report concerns as soon as possible with appropriate confidentiality.

The Code and Our Culture

The Code and our company culture, which is grounded in our core values of Partnership, Passion, People and Professionalism, guide all our actions.

FinTrU’s Mission statement reinforces the Code and our core values and demonstrates further what we do, how we do it and why we do it. It makes us what we are:

“Empowering our people to drive industry-disrupting, innovative solutions within financial services, making a positive contribution to global clients and local communities.”

We believe that this mission should be conducted in a unique way for us to look after our colleagues, provide outstanding service for our clients and safeguard our reputation. We call it FinTrU Business in a FinTrU Way.

Our Code illustrates what it means to live this mantra with every decision we make and action we take. We want everyone to enjoy coming to work each day and have fun, get involved, nurture yourself and others, win together as a team, respect everyone and, of course, be unique. Ultimately, how we do business at FinTrU is built on a foundation of honesty, integrity and respect. The Code outlines how you can meet these key behaviours.

Living the Code

Every employee has a responsibility to read the Code, understand it and put it into action. By adhering to the Code and doing FinTrU Business in a FinTrU Way, together we are:

EMPOWERING OUR PEOPLE
PROTECTING OUR ORGANISATION
DELIVERING FOR OUR CLIENTS
SUPPORTING OUR COMMUNITIES

Decision Making

When we experience a moral dilemma at work, there may be times where the correct course of action is unclear or challenging. Sometimes, deciding what the right thing to do is not an easy task and may test you.

FinTrU employees make decisions each day and we must evaluate whether those decisions align with the Code. If the answer to any of these questions is no, then do not proceed:

Questions to ask:

Is it legal?
Does it comply with FinTrU’s Code of Conduct and policies?
Does it align with our obligations to our clients?
Are you comfortable if your decision is made public?

Whilst our Code may not provide all the answers to every possible scenario, it should guide decision making. In the absence of a particular policy or procedure, you have a responsibility to use good judgement, comply with the spirit and intent of the Code and seek help from your manager, where appropriate.

Integrity and Ethics

The Code sets out rules and principles which broadly reflect the values and expectations of society. This means acting ethically, with integrity, in a non-discriminatory manner and within the law. It also means treating each other with respect. The Code goes beyond the law and our company policies – it highlights the expectations around your professional integrity and ethical behaviour and acts as a moral compass when faced with difficult situations.

FinTrU is committed to ensuring that all employees, regardless of your role in the Company, act with honesty and integrity, treat clients fairly and exercise sound judgement. Personal accountability and ownership are priorities and we expect you to hold yourself to the highest standards. You should always conduct yourself appropriately when acting on behalf of FinTrU – both inside and outside of the workplace. Your actions should reflect the company’s culture of integrity, dignity and respect.

Always deal fairly and in good faith with our clients, suppliers, competitors, business partners, regulators and colleagues. Never take advantage of anyone through manipulation, concealment, abuse of privileged or confidential information, misrepresentation of fact or other unfair dealings or practices.

FinTrU’s competitive advantage comes from the services and products we offer, our unique culture and you, our people. Never compromise FinTrU’s reputation by engaging, or appearing to engage, in any form of corruption or unethical and/or corrupt business practices. Be alert and escalate activities that are designed to hinder or prevent the detection of improper or illegal activity such as money laundering, tax evasion, fraud or bribery.

When you act with our Code in mind, we earn the trust of our clients, business partners, colleagues and the general public. Trust is more than just a value; it’s the foundation upon which FinTrU was built. By building trust today, we can inspire global trust in tomorrow.

Speaking Up

You are responsible for seeking guidance and asking for help if you become aware of potential misconduct, including violations of the Code. This includes wrongdoing within FinTrU or by an external party. FinTrU is committed to fostering an open, safe and transparent workplace where all staff feel comfortable to approach their line manager or a member of senior management to discuss issues openly and candidly. Allegations of misconduct are investigated and managed in an objective, thorough, consistent and timely manner with the goal of understanding and resolving concerns. Confidentiality will be honoured at every stage.

Reporting Channels

Employees are expected to report concerns to their manager. If they are uncomfortable doing so, they can report through the other channels listed below:

Executive or Managing Director
HR Business Partner
Risk & Compliance Manager
Via our Whistleblowing service

Our Whistleblowing service is provided by our external, independent partner Safecall. Reports can be made by current employees, ex-employees or third parties such as suppliers or external stakeholders. Reports to Safecall can be made anonymously. They will be fully investigated internally, and a response will be provided to the person reporting via the Safecall web platform. Details of how to make a report are contained in our Whistleblowing Policy.

You do not have to be certain about a concern. A genuine and honest concern about wrongdoing or misconduct is sufficient.

Investigations

We investigate all reports of suspected breaches of our Code or policies thoroughly, promptly and confidentially. Where required, all parties involved in an investigation will get a fair hearing to explain the circumstances and present their side of the story.

FinTrU employees are expected to fully cooperate in any internal or external investigation that is being conducted or directed by FinTrU. Employees must not withhold or tamper with information, or in any way attempt to influence others participating in the investigation.

If an investigation reveals that a breach of the Code has occurred, then a disciplinary process may begin in accordance with our Disciplinary Policy. The outcome of this process may involve disciplinary sanctions such as:

a verbal warning
a written warning
suspension pending the outcome of an investigation, or
termination of employment

The extent of sanctions will depend on the severity of the offence, the offender’s guilt, the background and the circumstances of the violation. In certain cases, breaches may also be reported to relevant law enforcement authorities, which could lead to legal action being instigated.

Commitment to Non-Retaliation

Retaliation will not be tolerated in any way against any employee who reports misconduct or speaks up in good faith about breaches of this Code, company policies or potential non-compliance with the law.

FinTrU will keep the information it receives and the identity of those who report violations of our Code confidential, where possible. FinTrU strictly prohibits any retaliation or intimidation against anyone who, in good faith, shares a potential or actual violation of our Code or assists with an investigation or inquiry. Similarly, FinTrU does not tolerate any attempt to bully or threaten anyone into not speaking up. These behaviours are a serious breach of our Code and could result in disciplinary action, potentially leading to dismissal.

EMPOWERING OUR PEOPLE

Our people are at the centre of everything we do. Our success is built upon the strength, professionalism, knowledge and resilience of our employees. We want our employees to nurture themselves and others, ensuring that they value their differences and are all treated fairly and respectfully. These behaviours will help to create and build strong partnerships within teams whilst promoting a joyous and inclusive workplace.

Respecting Human Rights

FinTrU invests heavily in our people as part of their professional careers and continue to support our employees on an ongoing basis. We consider ourselves to have a fundamental social purpose to create high-quality professional employment.
FinTrU respects the rights and dignity of everyone with whom we do business. This begins with our daily interactions with one another and our clients, promoting an environment that welcomes people from different backgrounds and with different experiences.
We seek to work with third parties who share our values and commitment to integrity. In selecting our contractors and suppliers, we undertake due diligence to make sure that they embrace transparent procurement processes, sustainability, fair trade and employment best practice.
We have direct control and oversight over our recruitment practices and working conditions and comply with all relevant employment and labour laws. We support efforts to prevent human rights abuses including modern slavery and human trafficking and we consider the risks of modern slavery and human trafficking within our workforce and our supplier base to be extremely low.

Embracing Diversity, Inclusion and Equality

All employees and applicants for employment are guaranteed the same, fair treatment. We recognise the value of different cultures, backgrounds, and perspectives, which we believe contributes to our continued success. The Code requires you to embrace our differences and treat each other with dignity, respect and fairness at all times. We acknowledge that when people feel happy, safe and secure at work, they can reach their full potential.
Meritocracy is important at FinTrU. We adopt recruitment practices in line with applicable legislation and treat all applicants in a fair and equitable manner. We recruit and promote employees based on individual ability and experience regardless of race, gender, culture, sexual orientation, religion or other protected characteristics. Basing our decisions on merit helps us to attract and retain the best talent we need to deliver exceptional service to our clients.

Promoting a Safe and Healthy Workplace

We make the safety and wellbeing of everyone who works with us a key priority. Maintaining a safe and healthy workplace is the responsibility of all employees. By doing so, we create an environment where people can thrive.
To perform at our best every day, all employees must perform their duties unimpaired by illegal drugs, alcohol, or by the improper use of legal substances.
Acts of violence, threats and physical intimidation will not be tolerated at FinTrU. Such actions can result in immediate disciplinary action, up to and including termination of employment.

Fostering a Respectful and Professional Workplace

All of our employees deserve to be treated with respect and dignity in the workplace. Inappropriate behaviour, including discrimination, harassment and bullying, has no place in the FinTrU culture. We want everyone to interact with empathy and be caring towards the feelings and perspectives of others, creating a positive and cooperative environment.
We expect our leaders to create and maintain a positive working environment where all employees are inspired to excel and are comfortable asking questions and raising concerns.
We support employee participation in off-site events which further FinTrU business objectives and core company values. Whilst we respect employee privacy and personal freedom, you are all ambassadors of FinTrU with individual responsibility for your actions. You should refrain from any act, on or off premises, that threatens the reputation of you, FinTrU or any of its clients
It is important to remain objective in your role. Personal relationships with those inside or outside of work can create, or appear to create, a conflict of interest. Whilst we do not wish to interfere unnecessarily, it is required that employees behave in a professional manner, do not abuse positions of power and do not allow personal relationships to cause perceived or actual conflicts of interest.

PROTECTING OUR ORGANISATION

Our long-term success depends greatly on safeguarding and protecting our company and its assets. We do this by ensuring a right first-time approach, applying appropriate controls in our daily roles, acting with integrity and always abiding by relevant policies and legislation to protect our company from risks.

Protecting Personal Information

Protecting the confidentiality of employee, supplier and client information is of the utmost importance. Safeguard and maintain the confidentiality of information and use it only for legitimate business purposes.
The loss or unauthorised disclosure of confidential information may harm FinTrU and can result in disciplinary action being taken.

Internal Information Controls

As a company, we are committed to implementing and maintaining a robust Information Security Management System and hold the ISO27001:2022 security standard. Our aim is to protect the confidentiality, integrity and availability of the data employed within our company.
FinTrU has strict rules which employees must follow regarding management of computer and printer workstations. This ensures that all sensitive and confidential information, whether it be on paper, a storage device, or a hardware device, is properly locked away or disposed of when a workstation is not in use. This also applies for working at home workstations.
All employees must adhere to our Password Security Policy and must never share passwords with anyone. Where you suspect passwords have been compromised this should be reported immediately.
FinTrU has robust security controls to ensure that you do not transfer confidential information outside of the FinTrU network, including to personal email address, or to non-company devices or storage locations. You must immediately report any leakage of confidential information.

Awareness

Cybercrime has become more organised and sophisticated than ever before, with the increasingly serious threat posed by malicious hackers and cybercriminals of significant concern to our company.
Phishing remains the number one form of attack due to its high success rate and fraudsters are using a range of social engineering tactics to manipulate employees into handing over data. It is your responsibility as employees to educate yourself on information security issues and follow applicable policies. Stay alert and guard against scams and phishing alerts.

Protecting Our Assets

The resources we use to conduct company business must be used for legitimate business purposes and should be appropriately safeguarded against cyber-related risk and attack, theft, loss, waste and abuse. You have a responsibility to care for all the assets entrusted to you by FinTrU at all times.
Any FinTrU equipment provided to you is your responsibility and should primarily be used for business purposes. Where damage occurs through negligence or carelessness you may be required to reimburse FinTrU of the value of the item damaged.
Depending on job role, you may have access to e-mail, cloud-based applications, computers, server networks and other communication platforms. You must never use these company systems or devices for activities that are illegal or that violate our policies and values. Communications on company and client systems should always remain professional. There is no tolerance for bullying, profanity, discrimination or derogatory language. Such occurrences may result in disciplinary action.

Intellectual Property and Proprietary Information

FinTrU proprietary information and Intellectual Property (IP) are valuable assets and are critical to our business success. We have great ideas and technology, which we all need to protect.
FinTrU IP includes ideas, processes, trade secrets, technology, software, proprietary know-how, inventions, designs, marketing materials, pricing methods, brands and other creations protected by law.
We respect the intellectual property rights of others and ensure that our innovations do not infringe on existing patents, copyrights, or trademarks. We also protect our own intellectual property to maintain our competitive edge.
We make significant investments in the development of IP and will fully enforce our rights should the need occur. All IP provided by our employees (unless otherwise provided by law) during the period of their employment must be disclosed and is the property of FinTrU.
You must always safeguard proprietary information that you help develop or to which you have access to as part of your role.

Accurate Records and Disclosures

FinTrU and its employees must follow applicable accounting standards, policies, procedures, internal controls and legal requirements. We will make accurate, timely and clear disclosures to regulatory authorities, clients and the public.
Employees must never falsify, or maintain inaccurate, information or data.
All payments to, and business transactions with, third parties must be accurately recorded.
Records retention guidelines and legal hold notices must be complied with.
Employees must ensure that all expenses are submitted accurately through required channels and with proper approval according to policies.

Preventing Bribery and Corruption

FinTrU has strict policies, procedures and controls in place concerning bribery, corruption and related offenses. We do not tolerate bribery or corruption in any form.

You must not:

offer, promise, give - or authorise others to offer, promise or give - anything of value, either directly or indirectly, to any party in order to gain an unfair or improper business advantage.

receive, or agree to receive, anything of value that may improperly influence your duties as a FinTrU employee.

Actual or suspected instances of corruption or bribery must be escalated immediately to the Risk & Compliance Manager or reported via our Whistleblowing service. Where appropriate, it may also be necessary to report instances of bribery, corruption and other related offences to the appropriate regulatory and/or law enforcement agencies.
If an employee bribes, attempts to bribe, or receives a bribe intended to obtain or retain an advantage in the conduct of FinTrU business, this will be considered to be an act of gross misconduct. FinTrU’s Gifts & Hospitality Policy and Gifts register supports business transparency and provides a mechanism for recording business-related gifts to deter such unethical and corrupt activities.

Anti-Money Laundering

FinTrU conducts business only through lawful commercial activities and with funds from legitimate sources. Money laundering occurs when the proceeds of crime are hidden in legitimate business dealings, or when legitimate funds are used to support criminal activities.
All companies are at risk of being exploited in this way and you must be on your guard to help protect our reputation and ensure we comply with the law in this area. You must avoid knowingly assisting in any form of tax evasion, including providing advice on how to avoid tax obligations.
Be alert and report any unusual activity according to applicable policies.

Fraud

Fraud is any intentional act or omission designed to deceive others in a way that is illegal or dishonest, resulting in the victim suffering a loss and/or the perpetrator achieving a gain. This can include theft or the misappropriation of company funds, information or assets. You are responsible for ensuring that any suspicions of fraud are reported promptly for investigation.
Employees engaging in fraudulent activities will be subject to disciplinary action, including dismissal. Employees who help others to engage in fraud, or elect to ignore while others engage in fraud, will also be subject to disciplinary action, including dismissal. Law enforcement agencies will be engaged where it is suspected that criminality has taken place.

Political Activities

Our place of work is not the forum to share political views or opinions. However, we respect the personal and voluntary right of employees to participate in political activities in their own free time and with their own resources, outside of the workplace. However, you must make clear that your external political views and actions are your own and not those of FinTrU.
Political activities may give rise to a potential conflict of interest and the remit of such activities should be approved in advance by the Compliance Department.

Communicating Responsibly

FinTrU is committed to making sure that communications about our company and its business are accurate and made by employees who are authorised to speak on our behalf. Consistent, accurate and professional communication with the media and others outside our company is important and can have an impact on our business reputation.
Only officially designated spokespersons may provide comments to the media or other third parties. Employees who are unauthorised to make such statements must refer all enquiries to their manager and the Marketing Manager.
FinTrU respects your right to engage in social, professional and political dialogue outside of work. You must use good judgement, including on your social media accounts, and carefully consider what your use of this media may have on FinTrU and our clients. Confidential information about FinTrU business, performance, financial conditions or legal issues should never be discussed on social media, as doing so may damage the company and breach legal or contractual obligations. Also, use care in internal communications and be responsible with your comments on the internal FinTrU-approved social media platforms.

DELIVERING FOR OUR CLIENTS

We aim to showcase our passion for our industry and how our wealth of knowledge and expertise can have a positive impact. Our goal is to always exceed the highest standards in client service delivery and technology solutions, whilst avoiding conflicts of interest and building successful and trusting partnerships.

Delivering Beyond Client Expectations

In accordance with the Service Agreements with our clients, we recruit and onboard employees who have appropriate educational and professional achievements required to successfully conduct each role. We do this by investing in our people and creating platforms to continuously encourage professional development and facilitate career development.
Strong and effective relationships with our clients are built on understanding their business needs, effective and timely communication, always showing respect to each client stakeholder and continuity of service. All of these crucial factors result in an exceptional service delivery to our clients.

Creating Innovative Technology Products

We prioritise the needs of our clients at every stage of product development. Understanding and addressing client pain points is essential to delivering valuable and impactful solutions.
FinTrU adheres to the highest ethical standards in its innovation processes. This includes respecting user privacy, ensuring data security and avoiding any practices that could harm individuals or society.
Innovation thrives in diverse and inclusive environments. We encourage collaboration across teams and value diverse perspectives to drive creativity and breakthrough solutions. Innovation is an ongoing process and we embrace a mindset of continuous improvement, regularly seeking feedback, learning from failures and iterating our products to enhance their performance and relevance.
We expect all employees to comply with all relevant law, regulations and industry standards in our product development processes. Integrity and transparency are fundamental to our operations, ensuring that our innovative products are trustworthy and reliable.
By adhering to these principles our employees aim to create impactful technology products that not only meet the highest standards of quality and innovation but also contribute positively to our clients.

Honest Practices and Fair Competition

FinTrU competes at all times with integrity within the marketplace. We win business on our merits and in doing so deal honestly and fairly with clients, potential clients, competitors and suppliers. We always follow client procurement rules and, while we proactively market our services, we expect our employees to compete ethically and always remain honest when promoting and representing our capabilities, experiences and services.

Responsibilities to Our Clients

Whilst contracted to a client, it is paramount that you follow client controls and procedures to protect confidential and restricted information that you are entrusted with. You must never send, record, copy or save any client related data on FinTrU systems or personal devices.
We commit to adhering to all client policies and standards notified to us, in addition to complying with FinTrU policies and procedures. These include client communication policies and policies regarding conflicts of interest.
It is essential that client communication tools are used for client-related professional communications only. FinTrU business and personal business should not be discussed on client systems and all communications should be professional. Any breach of this policy is categorised as gross misconduct and could lead to dismissal.

Preventing Insider Trading and Abuse

To ensure FinTrU’s clients meet applicable legal and regulatory requirements, and that the personal trading activity of employees does not result in actual or perceived conflicts of interest, you must never trade, encourage, or cause others to trade or recommend, securities, derivatives or other related financial instruments whilst in possession of material, non-public information related to those instruments.
As an organisation we expect you to comply with our clients’ personal trading policies in addition to our own policy, which outlines general rules, procedures and compliance requirements. Failure to do so could result in substantial reputational damage to FinTrU and our clients as well as personal consequences for employees.

Avoiding Conflicts of Interest

All employees are expected to act in the best interests of FinTrU rather than for personal gain and to be aware of potential conflicts of interest.
Conflicts of interest arise when our personal or financial interests interfere or appear to interfere with objectivity in our business decisions, our ability to do our jobs or to make unbiased decisions on behalf of FinTrU. Even the appearance of a conflict of interest can make others think we are acting improperly and should be avoided. By doing so, we protect FinTrU’s reputation and continue to build trust with our clients and other stakeholders.
Accepting outside employment while working for us can impact productivity and may also create a conflict of interest. Any external employment or outside business interest must be pre-approved by FinTrU Compliance to ensure that no actual or perceived conflict exists.

Accepting Gifts and Hospitality

Gifts and hospitality (including entertainment) are often given and received to build goodwill and strengthen business relationships. However, they may also be seen as inappropriate and may create a conflict of interest.
You are generally discouraged from giving or accepting gifts or hospitality to/from third parties, including clients and suppliers. We do, however, accept that there may be occasional modest giving and acceptance of gifts and hospitality, but it is essential that they do not influence - or appear to influence - business decision making. You must always consider whether the giving or receiving of a gift or hospitality is appropriate.
FinTrU employees must abide by the following principles.You must not:
Accept any offer from a client, potential client or third party which you know, or suspect would have the expectation of FinTrU providing a business advantage, reward or preferential treatment in return.
Offer money, gifts or other items or services of value to clients, potential clients or any third party for the purpose of receiving a business advantage, reward or preferential treatment.
Offer any payment to a government or local council official in any country to facilitate or fast-track a necessary routine or procedure.
Threaten or retaliate against another individual who has raised concerns about suspected bribery or corruption or who has refused to accept a gift or service.
Fail to challenge or report any suspicions of bribery regarding giving or receiving any form of gift or hospitality.

If there is ever any doubt as to the acceptability of any gift or entertainment activity, consult with FinTrU’s Risk and Compliance Manager.
All gifts and hospitality received by FinTrU employees must be approved in line with the guidance stipulated in FinTrU’s Gifts & Hospitality Policy and notified to the Risk & Compliance department for recording on the Gifts & Hospitality register. Certain monetary thresholds apply where gifts or hospitality cannot be accepted.

SUPPORTING OUR COMMUNITIES

We all appreciate the role each of us plays in our communities. They are where we live, work, socialise, learn and develop. Each employee must try their best to always protect and care for our communities as this will support a brighter future for our society. FinTrU is passionate about engaging with charities and local communities to make positive contributions and we encourage you all to get involved.

Protecting the Environment

We make conscious decisions to protect our environment and are proactive in ensuring a sustainable business approach. This includes the use of electric vehicles, solar panels on our offices, a predominantly printer-free office working environment and extensive recycling across all of our global office sites.

Contributing to Our Communities

We believe that Corporate Social Responsibility (CSR) is key to creating a sustainable and successful business. We encourage employees to volunteer their time, expertise and innovation to our local charity partnerships across all our global locations. We raise significant sums of money that makes a real difference for those charities that we support.
FinTrU is proud to contribute to the local economy by creating high-quality, well-paid jobs. We are also proud to support our local community, and we encourage you to be active participants.
We believe that when we make our communities better, we make our business better.

The FinTrU Core Values

Our values define who we are as a company. They form the foundations upon which FinTrU operates its business and should help guide each of us in our daily roles. This Code embodies these values and is at the heart of what we do.

People
Partnership
Passion
Professionalism

You, our employees, are at the very core of our business. You form the diverse and inclusive workforce that is key to our success as a company.
FinTrU invests significantly in the personal and professional development of our employees.
Employees should strive for the best whilst maintaining integrity without lowering ethical standards.

Engage and support charities and local communities to make positive contributions through your time and donations.
Seek to build strong, successful client and supplier relationships and to collaborate with clients to identify innovative solutions that suit their needs.

Dedicate yourself to deliver beyond client expectations.
Demonstrate commitment and ambition with humility.
Strive for excellence in everything that you do as FinTrU employees.

Put clients and co-workers first.
Represent the company as positive and proud ambassadors with high standards of ethics and integrity.
Carry out your work to the highest standards and adhere to the company-wide policy framework that governs all employees.

Appendix - Portugal

Following the Portuguese National Anti-Corruption Strategy 2020-2-24, Decree-Law no. 109-E/2021 was published in the official Journal on 9 December 2021, creating the National Anti-Corruption Mechanism (“MENAC”) and approving the General Regime for the Prevention of Corruption (“GPRC”).

THE GRPC requires in-scope entities to adopt and implement a Regulatory Compliance Programme (“RCP”) to prevent, detect and sanction possible acts of corruption and related offences carried out against of through the entity in question. The RCP must include at least the following elements:

A risk prevention plan for corruption and related offences;
A code of conduct;
A training programme; and
A whistleblowing channel

FinTrU Limited is a private limited company registered in the United Kingdom with offices in Portugal that employ more than 50 employees, thus is obliged to comply with the GRPC.

FinTrU’s Code of Conduct outlines the core principles applicable to all the activities of FinTrU Ltd. This Appendix to the Code addresses specific, additional requirements of the Portuguese GRPC.

I. Prevention of Criminal Risks

FinTrU is strongly committed to compliance with all applicable regulations and legislation in force in each of the jurisdictions in which we operate.

Accordingly, we have drawn up a Risk Prevention Plan (“RPP”) for Portugal, following the regime set forth in the GRPC, which establishes the rules and procedures to prevent the commission of crimes at our Portuguese offices, to reduce the risk of their commission and facilitate their rapid detection. Acting in compliance with our RPP and the GRPC is mandatory for all our Portuguese-based employees.

The RPP regulates all aspects relating to the prevention of criminal risks including their identification, classification and mitigation and will be published on our website.

II. Disciplinary Measures and Sanctions

Disciplinary actions following a violation of this Code of Conduct and/or other internal policies may involve disciplinary sanctions such as a verbal warning, a written warning, suspension pending the outcome of an investigation or termination of employment, depending on the severity of the offence, the offender’s guilt, the background and the circumstances of the violation.

III. Criminal Penalties for Bribery, Corruption and Related Offenses

Violations of Portuguese law in the case of bribery, corruption and related offenses may result in criminal prosecution, leading to the imposition of criminal penalties as follows (without prejudice to mitigating or aggravating circumstances provided for by law):

Crimes in the Penal Code (Decree-Law No. 48/95, of March 15)
Corruption	Practice or omission of any act, whether lawful or unlawful, in exchange for receiving undue financial or non-financial advantage, for oneself or for a third party.	Articles 372 to 374-A of the Penal Code
Undue receipt or offer of advantage	When the official, in the exercise of their duties or because of them, by themselves, or through an intermediary, with their consent or ratification, requests or accepts, for themselves or for a third party, a financial or non-financial advantage that is not due to them.	Article 372, No. 1 of the Penal Code
Embezzlement	When the official illegitimately appropriates for their own benefit or that of another person, money or any movable property, public or private, that has been entrusted to them, is in their possession or is accessible to them by reason of their duties.	Article 375, No. 1 of the Penal Code
Embezzlement of use	When the official uses or allows another person to use, immovable property, vehicle, or other movable property or animal of appreciable value, public or private, that has been entrusted to them, is in their possession or is accessible to them by reason of their duties.	Article 376 of the Penal Code
Economic participation in business	When the official who, with the intention of obtaining, for themselves or for a third party, illicit economic participation, harms in a legal transaction the patrimonial interests that, in whole or in part, they are responsible for, by reason of their function, administering, supervising, defending or carrying out.	Article 377, No. 1 of the Penal Code
Extortion	When the official, in the exercise of their duties or de facto powers arising from them, by themselves or through an intermediary with their consent or ratification, receives, for themselves, for the State or for a third party, by inducing error or taking advantage of the victim's error, a financial advantage that is not due to them, or is greater than what is due, namely contribution, fee, emolument, fine or penalty.	Article 379 of the Penal Code
Abuse of power	When the official abuses powers or violates duties inherent to their functions, with the intention of obtaining, for themselves or for a third party, an illegitimate benefit or causing harm to another person.	Article 382 of the Penal Code
Influence peddling	When someone by themselves or through an intermediary, with their consent or ratification, requests or accepts, for themselves or for a third party, a financial or non-financial advantage, or its promise, to abuse their influence, real or supposed, with any public entity.	Article 335 of the Penal Code
Money laundering	When the official converts, transfers, assists or facilitates any conversion or transfer operation of advantages, obtained by themselves or by a third party, directly or indirectly, for the purpose of concealing their illicit origin, or to prevent the author or participant of these infractions from being criminally prosecuted or subjected to a criminal reaction.	Article 368-A of the Penal Code
Crimes under Law No. 34/87, of July 16 (crimes of responsibility of political office holders)
Corruption	When the holder of a political office, by themselves or through an intermediary, with their consent or ratification, requests or accepts, for themselves or for a third party, a financial or non-financial advantage, which is not due to them, as consideration for making a decision contrary to the duties of the office, within the scope of their functions.	Article 17 of Law No. 34/87, of July 16
Undue receipt or offer of advantage	When the holder of a political office, in the exercise of their duties or because of them, by themselves or through an intermediary, with their consent or ratification, requests or accepts, for themselves or for a third party, a financial or non-financial advantage, which is not due to them.	Article 16 of Law No. 34/87, of July 16
Embezzlement	When the holder of a political office, in the exercise of their duties, illegitimately appropriates for their own benefit or that of another person, money or any movable property, public or private, that has been entrusted to them, is in their possession or is accessible to them by reason of their duties.	Article 20 of Law No. 34/87, of July 16
Embezzlement of use	When the holder of a political office uses or allows another person to use, immovable property, vehicle, or other movable property or animal of appreciable value, public or private, that has been entrusted to them, is in their possession or is accessible to them by reason of their duties.	Article 21 of Law No. 34/87, of July 16
Embezzlement by error of another	When the holder of a political office, in the exercise of their duties, but taking advantage of the circumstantial error of another, receives for themselves or for a third party fees, emoluments or other amounts not due or of a value greater than what is due.	Article 22 of Law No. 34/87, of July 16
Economic participation in business	When the holder of a political office who, with the intention of obtaining, for themselves or for a third party, illicit economic participation, harms in a legal transaction the patrimonial interests that, in whole or in part, they are responsible for, by reason of their functions, administering, supervising, defending or carrying out, as well as when the holder of a political office receives a financial advantage for the celebration of an act relating to interests over which, by virtue of their office, they have at that moment the powers of disposition, administration or supervision, even if they do not harm them.	Article 23 of Law No. 34/87, of July 16
Abuse of power	When the holder of a political office abuses powers or violates duties inherent to their functions, with the intention of obtaining, for themselves or for a third party, an illegitimate benefit or causing harm to another person.	Article 26 of Law No. 34/87, of July 16
Prevarication	When the holder of a political office, in the exercise of their duties, intervenes in a process in which they make unlawful decisions with the intention of harming or benefiting someone.	Article 11 of Law No. 34/87, of July 16
Breach of secrecy	When the holder of a political office reveals a secret that they have become aware of or has been entrusted to them by virtue of their duties, with the intention of obtaining an undue benefit for themselves or a third party or to cause harm to a public interest or that of a third party.	Article 27 of Law No. 34/87, of July 16
Crimes under Law No. 20/2008, of April 21 (criminal regime of corruption in international trade and the private sector)
Corruption prejudicial to international trade	Practice of any act or omission, directly or indirectly, in the sense of giving or promising to an official, national, foreign or of an international organization, or to a holder of political office, national or foreign, or to a third party with knowledge of those, an undue financial or non-financial advantage, with a view to obtaining or retaining a business, contract or other undue advantage in international trade.	Article 7 of Law No. 20/2008, of April 21
Corruption in the private sector	Practice of any act or omission, directly or indirectly, in the sense of requesting or accepting, for themselves or for a third party, an undue advantage or promise of undue financial or non-financial advantage, in exchange for any act or omission that constitutes a violation of their functional duties.	Article 8 of Law No. 20/2008, of April 21
Crimes under Decree-Law No. 28/84, of January 20 (anti-economic offenses and against public health)
Fraud in obtaining a subsidy or grant	When the official provides to the competent authorities or entities inaccurate or incomplete information about themselves or third parties and relating to facts important for the granting of a subsidy or grant; omit information about important facts; use a supporting document obtained through inaccurate or incomplete information; in order to obtain a subsidy or grant.	Article 36 of Decree-Law No. 28/84, of January 20
Fraud in obtaining credit	When the official submits a proposal for the granting, maintenance or modification of credit conditions, containing: a) Inaccurate or incomplete written information intended to accredit them or important for the decision on the credit application; b) Documentation, relating to the economic situation, inaccurate or incomplete, namely balance sheets, profit and loss accounts, general descriptions of	Article 36 of Decree-Law No. 28/84, of January 20

Document Control
Document name:	FinTrU Code of Conduct	Version:	1.0
Document Approver:	General Counsel & Regulatory Compliance Officer	Date of Approval:	March 2025
Publication Date	March 2025	Next review by:	March 2026