The Code outlines what we expect from our employees, in terms of our behaviour and actions. We are familiar with the Code and all policies and procedures that apply to our respective roles. You will keep these values in the forefront of our mind at all times.
It is critical that we comply with relevant laws, regulations and company standards in everything we do. Making sure that WadzPay operates within these laws, regulations and standards is the personal responsibility of every one of us.
The laws and regulations which apply in each state or country in which we operate, along with our company standards provide us with a framework of rules within which we must always function.
We must all:
• Act ethically, honestly, professionally and with integrity at all times
• Comply with all relevant legal and regulatory requirements. Make sure we know and understand them, and act in a way which follows their instructions and the spirit in which these rules are intended. If we fail to do so, the consequences can be severe, including damage to our brand, loss of clients, loss of confidence from our regulators and the public, suspension or withdrawal of the licences we hold and fines or other penalties
• Comply with corporate standards. We must do this unless local laws or regulations are either stricter than, or do not allow, our standards – in which case local laws or regulations apply
• Some countries have requirements for people, organisations or particular activities to be licensed, registered, or certified. These are regulatory requirements and we must comply with them. It is our responsibility to make sure we have the relevant licenses, registrations and certificates that we need
• Understand the legal and regulatory requirements involved in cross-border activities and keep to these requirements
WadzPay is committed to complying with all applicable sanctions laws and regulations in the jurisdictions in which we operate, subject to the primacy of local laws and regulations.
Financial crime has an enormous global impact. It can negatively affect society at all levels – from ruining the lives of people to threatening the global economy.
Financial crime allows drug and human trafficking to take place, supports the smuggling and counterfeiting of goods, underpins illegal gambling and financing terrorist activity and tax evasion, among other criminal acts. We have a duty to protect the communities that we work in from the damaging effects of financial crime.
We are committed to preventing the laundered proceeds of crime (including those from tax evasion) and financing terrorism from being a part of the financial system. We are committed to preventing ourselves, our staff (and other associated people) from the criminal facilitation of tax evasion by our clients. Bribery and corruption cannot be tolerated. We are also committed to keeping to all legally binding sanctions, including measures against people and organisations and measures against specific countries (or nationals or residents of those countries).
We must play a strong and effective role in the fight against financial crime. We owe this to our stakeholders as well as to the global financial system in which we operate. We must cooperate fully with governments, regulators and other financial services providers to protect all stakeholders from fraud and to help tackle organised financial crime. We also must act with diligence in the ongoing development of financial crime compliance programmes. We must apply the Group’s standards on financial crime compliance as well as any local anti-money laundering laws and regulations. We all have a very important role to play in the fight against financial crime.
Bribery and corruption are illegal, dishonest and extremely damaging to the countries and communities where they take place. We must actively reject bribery and corruption in all its forms.
When someone gives a benefit to someone else in order to influence that person’s behaviour, that is a bribe. When someone takes improper advantage of their position to make a gain for themselves, they are acting corruptly. We must not give or accept bribes or take part in, or enable, any forms of corruption. And we must go further than this, to make sure that our actions do not create the perception of bribery or corruption. It’s vital that we stay vigilant because the risk of bribery can arise in any of our operations, at any time where we are dealing with a third party. Bribery and corruption can take many forms – through procurement decisions, expenses, gifts and entertainment, hiring decisions, sponsorships, donations, the actions of our customers and so on.
We must take the time to consider how day-to-day business activities might encounter or create the risk of bribery and corruption. This will help us to be better positioned to identify possible bribery and corruption. We must make sure that the transactions and activities we take part in are not, and cannot be perceived as, an improper inducement for business.
Managing conflicts of interest effectively allows us to act fairly, avoid legal and regulatory risks, and protect our brand, reputation, and our own personal integrity.
Conflicts of interest fall into two broad categories – business and personal. If you identify any actual or potential conflicts of interest, you must act immediately to deal with them openly, honestly and effectively.
Business conflicts of interest can arise in the following situations:
• Between the Group and its clients, suppliers or other third parties including general users of the markets in which we operate
• Between clients and other third parties
• Between different businesses within the company
Personal conflicts of interest may arise when you put your personal interests ahead of those of client, supplier, other third party. This would include instances where you have an interest or association (an outside business interest) that may interfere with our interests or the interests of our stakeholders. They may also arise where you have close personal relationships or close financial relationships with other colleagues.
As part of delivering services, we receive confidential information which may be about organisations, markets and us, as well as personal data of clients, colleagues, and other individuals. It is critical that how we use confidential information, including personal data, instils trust and confidence, not only in those directly affected, but in the broader community in which we operate. We are committed to handling confidential information, including personal data, respectfully and appropriately in line with our responsibilities in terms of bank secrecy and confidentiality, as well as privacy law.
To continue to operate we must maintain strong and effective relationships with regulators and governments to keep our licences and gain new ones. If we fail to meet our commitments, our regulators may lose confidence in us and take action against us. This action could include substantial financial penalties and revoking our licences, which will damage our brand and reputation as well as our capabilities.
We must interact with government officials and regulators in a responsive, open, honest and co-operative way, and freely give them information that they would reasonably expect.
We must:
• Immediately refer enquiries we have received from regulators to Compliance and not discuss the enquiry with the regulator unless you have been authorised to do so by Compliance
• Contact Compliance if you have any questions about how to respond to a regulatory enquiry or relationship
• Never mislead regulators or cover up a problem
Subject to certain regulatory exceptions, in an investigation, all Directors and employees are required to co-operate with any legitimate and lawful government, regulatory or internal investigation. They must tell the full, complete truth in such inquiries and are expected to provide the maximum level of cooperation by, among other things, being available to those conducting the investigation and by providing any materials requested by those conducting the investigation in a timely manner. A lack of co-operation with an investigation may lead to sanctions, including termination of employment.
We believe it is important that everyone can work in a fair, safe, inclusive and enjoyable place that encourages creativity, collaboration and continuous improvement. These things are essential to our core valued behaviours.
Managing risk is a central part of our daily activities. We create value and produce long-term returns for shareholders by taking and managing risks in line with our strategy and within our risk appetite. Risk management is the set of end-to-end activities through which we make risk-taking decisions and control and optimise our risk-return profile. Everyone make sure they manage risks effectively as part of their organisational responsibilities.
It is important that every aspect of our business is carried out within a framework of delegated authority that flows down from the board. Delegated authority is designed to protect you as well as us. Understanding which limits and policies apply to you means you are not put in a position where you are unaware of the risks for which you are responsible, and do not take more risks than appropriate for your role or seniority.
This Code, our policies and procedures give you detailed requirements to follow as you go about your daily activities. However, these resources do not cover everything. You may face situations which are challenging and unfamiliar. We trust you to use your good judgment in these situations, although you must remember to stay within your delegated authority. You should feel comfortable that you can support the decisions or action you take in light of the difficult situations you face. Being methodical and informed when considering solutions will help to deliver a positive outcome. Acting hastily, without involving your manager and any other relevant colleagues, exposes you to poor decision-making and negative consequences.
We must maintain a culture of strong ethics, integrity, transparency and openness. By speaking up you help us to identify issues and deal with them. Misconduct is damaging for everyone. It can damage our financial performance, reputation and the trust of everyone who has an interest in our business. Each one of us has an important role to play in protecting our reputation. WadzPpay promotes open and honest communication, supporting people in raising concerns about anything that goes against our values, breaks the law, breaches regulations or policies, or that simply feels wrong. WadzPay does not condone or tolerate any acts of retaliation against those who speak up.
Employees are encouraged to report actual or suspected wrongdoing. If a colleague is asked or ordered to participate in, or otherwise becomes aware of, any violation of the Code, policies, or applicable laws and regulations, there are several reporting channels, including an option to report concerns anonymously.
Depending on the allegation, HR, Compliance, Legal, Audit, or another objective party will investigate complaints of unlawful activity or violation promptly and thoroughly. Issues that may result in fines or reputational damage must be escalated to Compliance for assessment and recording, and considered by Legal teams. We will attempt to protect the privacy of the complainant to the maximum extent possible and be consistently objective and thorough in any investigation.
Based on that investigation, a decision will be made as to whether or not wrongdoing occurred, and appropriate action taken including, if necessary, disciplinary action and potentially reporting any unlawful activity to external authorities. All information regarding any specific incident will be kept confidential to the extent possible, within the necessary boundaries of the fact-finding process.
In addition to the internal reporting options, employees are free to report violations of law or regulations to any government, regulatory or self-regulatory agency in accordance with law; provide them with truthful information and make other disclosures that are protected under any applicable law or regulation; and participate in any investigation they conduct.