Code of Conduct

This purpose includes its clients and customers and is achieved through the demonstration of the Xecurify values by those who interact with them.

Unity:

We respect and value the people we work with.
We are unified through a common purpose.
We embrace diversity and strive for inclusion.

Integrity:

We value transparency, communicate honestly and share information openly.
We act with integrity in everything we do.
We do not hide our mistakes and we learn from them.

Agility:

We act with a sense of urgency and decisiveness.
We are adaptable, responsive, and embrace change.
We take a smart risk.

Energy:

We are positively driven to make a difference and challenge the status quo.
We focus on and encourage personal leadership.
We motivate each other with our ambition.

Accountability:

We deliver maximum value to our customers and stakeholders.
We take ownership and are accountable for the outcome.
We reward and celebrate performance.

Accordingly, Xecurify encourages its customers to partner with it in achieving this goal, by ensuring that all their employees and subcontractors interact with Xecurify's personnel, clients, and customers on Xecurify's behalf, and demonstrate these values and behaviors.

This Code of Conduct aims to make sure that its customers share Xecurify's philosophy regarding these areas and encourage the customers to adhere to Xecurify's philosophy.

Xecurify supports the following principles and expects its customers to adhere to them:

To comply with all applicable laws and regulations of the countries in which it operates
To support and respect the protection of internationally proclaimed human rights.
Not to be complicit in human rights abuses.
To uphold the freedom of association and the effective recognition of the right to collective bargaining.
Not to make use of any forms of forced and compulsory labor or child labor.
To prevent discrimination in respect of employment and occupation.
To support a precautionary approach to environmental challenges.
To undertake initiatives to promote greater environmental responsibility.
To encourage the development and diffusion of environmentally friendly technologies.
To work against corruption in all its forms, including extortion and bribery.

Xecurify intends to make these principles key drivers of its purchasing policy.

1. Compliance with applicable laws and regulations

Xecurify adheres to the principle that its business should be conducted in accordance with all applicable laws of the countries where it conducts its businesses and any other applicable foreign jurisdictions.

2. Environment, Social and Governance(ESG)

Xecurify' ESG mission is to:

Deliver a high integrity ecosystem, for all our global stakeholders and our community, thereby enhancing the security and transparency of Xecurify’s markets.
Respect and develop our human capital, which is critical to our business success, and equip our employees with appropriate Human Resources policies.
Drive and facilitate sustainable finance, foster dialogue between the different players in the industry and contribute to the financing of the real economy in its transition to a sustainable society.

Xecurify recognizes that the management of environmental and social impacts is integral to good business practice. Xecurify encourages its customers to join it in similar environmental, social, and governance efforts and align with best practice activities including the following to maintain ESG policies, objectives, or targets which as a minimum include commitments to identify, measure and reduce significant environmental and social impacts and strive to facilitate a more sustainable society by supporting the allocation of capital to sustainable initiatives to support a precautionary approach to environmental challenges; to encourage the development and diffusion of environmentally friendly technologies; - to endeavor to reduce operational environmental impacts, such as the reduction of resource or water consumption, air emissions, management of hazardous materials, recycling, and waste production. to ensure working conditions show high regard for its employees and contractors’ health, safety, and general wellbeing;

3. Human Rights

Xecurify is really concerned with the protection of human rights around the world and is guided by fundamental principles such as those in the United Nations Universal Declaration of Human Rights and the International Labour Organisation (ILO) Core Conventions.

Xecurify welcomes relationships with its customers as opportunities to improve and evolve practices with respect to human rights. These behaviors and practices consider specifically:

To support and respect the protection of internationally proclaimed human rights and to ensure not to be complicit in any abuses of such rights.
To provide a safe and hygienic working environment that minimizes health and safety risks, bearing in mind the prevailing knowledge of the industry, the requirements of local health and safety laws, and of any specific hazards.
To ensure that all work is completed voluntarily.
Not directly nor indirectly to make use of child labor, whereby 'child' refers to any person less than 15 years of age (or 14 where the law of the country permits) unless the minimum age for work or mandatory schooling is stipulated as being higher by local law, in which case the stipulated higher age applies in that locality; for work that by its nature or the circumstances in which it is carried out, is likely to harm one’s health, safety or morals, the minimum age is 18 years.
To ensure that all workers are entitled to work and are paid for a minimum level of working hours, that working hours are not excessive and that maximum working hours comply with national laws.
To be responsible for employee compensation and payment of fair wages.
All employees should be paid a fair wage commensurate with prevailing industry conditions or the minimum wage, whichever is higher and any overtime should be voluntary and compensated appropriately.
To respect the rights of workers in relation to freedom of association.

4. Modern Slavery Act Statement

Xecurify Inc. and its subsidiaries and affiliates (collectively "Xecurify") are committed to ensuring that there is no modern slavery or human trafficking in our supply chains or in any part of our business. Our Anti-slavery position reflects our commitment to acting ethically and with integrity in all our business relationships, and to implementing and enforcing effective systems and controls to ensure slavery and human trafficking are not taking place anywhere in our supply chains.

Given the nature of Xecurify’s business, we believe there is minimal risk of practices that support, facilitate, or are complicit with modern slavery, within either Xecurify or our supply chain. Nevertheless, we require that all customers with whom we have a contractual arrangement explicitly agree to perform at the highest business and professional ethics level.

Due diligence and further steps: As part of our initiative to identify and mitigate risk, we are exploring ways to ensure we:

Identify and assess potential risk areas in our supply chains.
Mitigate the risk of slavery and human trafficking occurring in our supply chains.
Monitor potential risk areas in our supply chains.

Training: To maintain awareness and ensure a high level of understanding of the risks of modern slavery and human trafficking in our business, all employees have been made aware of this statement and reminders will be issued on an annual basis. This statement is made pursuant to section 54(1) of the Modern Slavery Act of 2015 and constitutes the slavery and human trafficking statement for the financial year ending 31 December 2018 for Xecurify Inc. and its subsidiaries to which the Act applies.

5. Diversity and Inclusion

Xecurify has a firm commitment to enabling equality of opportunity and workplace cultures that promote inclusion. Xecurify not only meets the basic legal requirements in every jurisdiction it operates in but seeks to lead the way in this area. Xecurify encourages its customers to partner with it to achieve excellence in equality, diversity, and inclusion through:

Treating all employees with dignity and respect.
Adhering to the principle of equality, diversity, and inclusion through all aspects of workplace management giving clear consideration to equality of opportunity in employment.
Improving a culture of inclusion for each of their stakeholder groups.
Promoting a workplace free from discrimination, victimization, harassment, physical or psychological violence or punishment, sexual exploitation or abuse, or any other form of inhumane treatment, inappropriate behavior, or abuse on any grounds.
Embedding relevant accessibility standards, innovation, and best practices to deliver inclusive products and services to customers and stakeholders.
Encouraging commitment and ability to support Xecurify’s aim to deliver products and services that meet the accessibility needs of its diverse customers and stakeholders, including the needs of people with disabilities.
Driving active management of downstream supply chains as part of their commitment so that the principles of inclusion and accessibility are encouraged through their supply chain; - working with diverse businesses and ensuring inclusive sourcing activities and decisions within their own organizations.

6. Business Integrity

Xecurify is firmly committed to conducting business in full compliance with all applicable:-

Anti-money laundering legislation, regulations, rules, etc. in order to prevent money laundering and terrorist financing and any activity that facilitates money laundering or the funding of terrorist activities.
Sanctions laws, including but not limited to the prohibitions and restrictions mandated by the sanctions programs administered by the U.K. and the Common and Foreign Security Policy (CFSP) of the European Union.
Anti-bribery and anti-corruption laws; accordingly, Xecurify or any person acting on behalf of Xecurify may not give or promise to give money or anything of value to any executive, official, or employee of any government, governmental agency, political party (including candidates for political office), company or other organization or person if it could reasonably be construed as being intended to influence a company business relationship with such entity or person.
Xecurify commits to respect the intellectual property (rights) of Xecurify and 3rd parties.

7. Reputation

Xecurify will not damage the reputation or image of any company of the Xecurify group.

8. Customer's Acknowledgment

By becoming a customer with and by purchasing products and/or services from Xecurify the customer commits to adhere to the principles and philosophy of the Code of Conduct throughout its relationship with Xecurify in order to help Xecurify to meet its values and principles as described in the Code of Conduct. Xecurify may in its absolute discretion, therefore, terminate its relationship with any customer in case of a material breach of the code.

Xecurify welcomes the customer's initiatives to ameliorate this Code in order to achieve its goals.

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