This Code of Conduct applies to all employees, officers, managers, contractors, consultants and other individuals working for or representing Blunative Corp. (“Employees”).
Employees must act with integrity, care and professionalism in all Company-related activities.
Employees are expected to comply with applicable laws, this Code and Company policies; protect Company assets, information and reputation; make decisions in the Company’s best interests; communicate honestly; seek guidance when requirements are unclear; and report suspected misconduct in good faith.
Managers must support ethical conduct, address concerns appropriately and avoid encouraging Employees to act inconsistently with this Code.
Employees must not use fraud, concealment, deception, misrepresentation, manipulation or improper pressure to achieve business goals.
Employees must not offer, promise, authorize, give, request or accept bribes, kickbacks or improper benefits. This applies to dealings with clients, vendors, financial institutions, platforms, public officials, intermediaries and other third parties. Improper benefits may include gifts, money, travel, entertainment, meals, donations, discounts, job opportunities or personal favors.
Employees may give or accept gifts, meals or hospitality only where they are lawful, modest, infrequent, transparent and not intended to influence a decision. Cash or cash equivalents, benefits requested as a condition for business, improper hospitality during sensitive negotiations, benefits involving government officials without required approval, and anything that could damage the Company’s reputation if disclosed are prohibited.
Employees must avoid actual, potential and perceived conflicts of interest. Conflicts may involve financial interests, outside roles, family or personal relationships, use of Company opportunities, or relationships with clients, vendors, competitors or partners. Employees must not proceed with a conflicted matter until guidance is provided.
Employees must protect non-public Company information and use it only for legitimate business purposes.
Confidential information may include financial institution collaboration materials, payment management information, compliance monitoring materials, KYC-related documents, client and platform information, pricing, commercial terms, internal systems, workflows, reports, business plans, personal data and intellectual property.
Employees may share confidential information only with persons who have a legitimate business need to know. Confidential matters must not be discussed in public places, unsecured channels or with unauthorized persons.
Employees must handle personal data lawfully and only for approved business purposes. Employees must collect only necessary data, use data only for authorized purposes, protect it from unauthorized access or disclosure, respect applicable privacy rights, avoid retaining or sharing data without a legitimate business reason and report suspected data incidents promptly.
Employees must use Company assets responsibly and only for authorized purposes. Company assets include devices, accounts, systems, software, documents, data, branding, trademarks, content, work product and intellectual property. Employees must not misuse Company systems, access data without authorization, remove Company materials improperly, use Company branding without approval or infringe third-party rights.
Employees must not make commitments, guarantees, discounts, approvals, side arrangements or changes to contractual terms unless properly authorized. Material business commitments must follow the Company’s approval process.
Employees must comply with applicable sanctions, export control, trade and anti-boycott laws. Employees must not knowingly involve the Company in dealings with sanctioned persons, restricted territories or unlawful transactions. Higher-risk jurisdictions, unclear counterparties, unusual structures or restricted activities must be escalated for review.
Employees must help prevent money laundering, terrorist financing, fraud, tax evasion and other financial crime. Warning signs include forged or inconsistent documents, unrelated third-party payments, suspicious counterparties, unusual payment routes, overpayments or transactions without a clear business purpose.
Company records, invoices, reports and expenses must be accurate, complete and not misleading.
Employees must comply with competition and antitrust laws. Employees must not agree with competitors to divide markets, fix prices, allocate customers, restrict capacity, coordinate employment terms or exchange sensitive competitive information unlawfully. Marketing, sales and public communications must be accurate, supported and not misleading.
Employees may use AI tools only in an approved and responsible manner. Employees must not enter confidential information, personal data, client materials or proprietary content into AI tools unless the tool and use case have been approved. AI outputs must be checked for accuracy, bias, confidentiality, intellectual property risk and suitability before business use.
Employees must treat colleagues, clients, partners and business contacts with dignity and respect. Blunative does not tolerate discrimination, harassment, bullying, intimidation, retaliation, forced labor, child labor or human trafficking.
Employees must follow applicable health and safety requirements, report unsafe conditions and avoid working while impaired by illegal drugs, controlled substances or alcohol where this affects safety, performance or judgment. Employees should use Company resources responsibly, reduce waste where practical and follow applicable environmental requirements.
Employees must report suspected misconduct, legal violations, policy breaches or material risks through a manager, HR, Compliance, Legal or another appropriate channel. The Company does not tolerate retaliation against Employees who raise concerns in good faith or cooperate with a review.
Violation of this Code may lead to training, corrective measures, disciplinary action, termination of employment or cooperation, reporting to authorities or legal proceedings.
Knowingly false or malicious reports may also result in disciplinary action.