CVR # 36052236
Address: Ny Carlsberg Vej 82, 1799 København, Denmark
Start date: 24.07.2014
Activity code: 643030
Secondary activity: 642020, 643040, 649100
The object of the Company is to carry on investment and financial activities in all kinds of monetary products and services, including electronic trading in currency and trading in precious metals including digital gold and other digital assets, all the above either under the auspices of the Company or through the formation of and/or participation in other companies or responsible partnerships and/or limited partnerships, provided, however, that only the services authorised by the Danish FSA may be offered to the public.
Supervision by the Danish FSA:
Lending, including (consumer credit, mortgage-credit loans, factoring and discounting, financing of commercial transactions, forfeiting).
Guarantees and collateralisation.
Trading for own account or for account of customers in:
- money market instruments (cheques, bills, certificates of deposit, etc.)
- the foreign exchange market
- financial futures and options
- currency and interest rate instruments, and
Participation in issuing securities and provision of related services.
Advice to undertakings on capital structure, industrial strategy and related questions and advice, and services relating to mergers and the acquisition of undertakings.
Portfolio management and advice.
Providers of exchange between virtual currencies and fiat currencies.
Providers of virtual wallets.
Custodian wallet providers.
Issuers of a virtual currency.
Providers engaged in exchange services between one or more types of virtual currency.
Providers engaged in transfer of virtual currency.
Safekeeping and administration of securities.
Company development plan
The company is focused on the implementation of The Global Socio-Economic Viability Project and meets all the requirements, which arise from the essence of the project.
The company has all necessary licenses, and the initiators of the Project have sufficient knowledge and experience for its successful implementation.
Given that the Project contains elements of know-how, it is subject to comprehensive registration as intellectual property of the company.
UniFin ApS mission - To reformat the ideology of commercialization and incline it to the format of prioritizing social principles through the creation, implementation and improvement of new monetary policy by introducing high-tech fundamentally new solutions, which will provide an opportunity for:
- Society - to improve the quality of people's lives by setting new standards of social responsibility for business;
- Our clients - to participate in the building of a new highly social society by means of doing business in the turnover of new modern financial instruments;
- To partners - to build long-term, reliable and open relations;
- To the Staff - to develop constantly, participating with the team of like-minded persons in the Company's life and getting a deserved appreciation of personal contribution;
- To shareholders - to have moral and material dividends from ownership of the best social and financial company in the world, which will become a world leader in terms of accounting and turnover of funds corresponding to their actual functions.
Strategic purpose - to create a single adequate equivalent of value and to introduce in the world turnover of money secured against the influences of business environment, secured by the highest value - the viability of civilization.
Tactical purpose - to create mechanisms of counting factors of Civilization vitality, to express them in the format of financial instruments and offer their market turnover to the community in the framework of its own e-commerce portal.
Operational goal - to prepare and announce to stakeholders The Socio-Economic Viability Project.
Technological purpose - to form a single e-commerce portal in all spheres of life with new money turnover and quotation of assets value in relation to the new Equivalent Value.
An economic purpose is to get commission participation in the maximum possible quantity of performed operations in the international financial space.
Administrative purpose - to exclude the influence of human factor in the part of personnel's performance of their functions.
Marketing purpose - to popularize the results of company's activity to the level of constant need of all participants of money turnover.
Social purpose - to provide investment attractiveness of social needs of the society. A unified corporate requirement for goal setting:
- Clearly Express the Mission and Vision of the company.
- Conform to the general structure of the organization's goals.
- Have the right wording - specific and not allowing for ambiguous interpretation.
- Be understandable to each person on whom its realization depends.
- Have a specific time frame.
- Have a unit of measurement expressed as a number, fraction, percentage, or a certain status.
- To be documented - on paper, in an electronic document or on the task board of the organization.
- Have an implementation plan with defined intermediate and final control points.
The most important challenge of the company is to generate revenue from The Global Socioeconomic Solidarity Project.
Satisfaction of social needs from realization of the company's entrepreneurial initiatives.
Effective use of the company's intellectual property.
Development of a strategy and tactics of the company's behavior on the market.
Not to compete with the company's own developments and to maintain the company's high image.
Improvement of the company's goals in a high-tech way.
Developing and maintaining the international social value of the company.
Corporate strategy - CS.
Business strategy - BS.
Functional strategy - FS.
Creation of Indices of the three influence factors and putting them into market bidding.
Connection of information data to a single server of information processing and creation of open online Registers of the three influence factors to calculate their Indices.
Coordination with the holders of the underlying assets of the three influence factors in terms of their accounting, as well as monitoring the actual state and ensuring the maintenance of their quality
Ensuring, maintaining and regulating the turnover of digital settlement funds between participants.
Issuing, distributing and maintaining the circulation of digital settlement funds between their holders.
Calculation of the total mass of digital means of settlement.
Creation of the Viability Index as a Single Equivalent of Value and its placement in market trading.
Calculation of the Viability Index with subsequent transfer of its value to trading platforms.
Entering information data on the status of the three influence factors on the information processing server.
Creating a single e-commerce portal and popularizing it in the community.
Introducing tendering platforms in the Single portal of electronic commerce and ensuring their proper functioning.
Development of the functionality of tender platforms and preparation of regulatory and normative requirements.
UniFin ApS Code of Ethics
Address by the Managing Director
As a global social and financial company that connects people around the world, we have tremendous knowledge and technology. But none of this is as important as our reputation.
Our success is directly tied to the trust people have in our mission - their confidence that our mission is inherently socially responsible and that we won't let them down.
The trust placed in us is a credit to each of you, and each of us is responsible for maintaining it.
In fact, we are all representatives of our brand and slogan, SOL LUCET OMNIBUS. After all, what we do and how we do it defines UNIFIN's reputation. Our self-awareness and all our actions must be guided by an internal priority of ethical behavior and a subtle sense of fairness, which cannot but affect the quality of our services.
The purpose of the UNIFIN Code of Ethics is to point us in the right direction. The Code is based on the core values of the company - trust, partnership, dynamism, and initiative - and it is an important basis for good decisions and good action. I am proud to represent UNIFIN and I ask you to do the same. With that in mind, please take the time to read the code, and most importantly, apply it to not only what you do, but how you do it.
VISION. MISSION. VALUES.
Our vision – SOL LUCET OMNIBUS.
The pernicious commercialization of society does not presuppose the primacy of social principles. It is what has led to the imbalance of morality and vitality. However, we are all equal. We are only differentiated by our life goals and methods of achieving them.
Our mission is to reformat the ideology of commercialization and bend it to the format of prioritizing social principles by creating, implementing, and improving a new monetary policy through the introduction of high-tech fundamentally new solutions.
In other words, we create a fundamentally new model of investment approach that ensures the global interest of each and every one to promote social sectors.
- Social equality;
- The viability of civilization;
We act responsibly
At UNIFIN, we believe that acting ethically and responsibly is not only the right thing to do, but also good for business. Every day, we interact with a variety of individuals and organizations, including our customers, competitors, employees, shareholders, suppliers, and government and regulatory agencies, in the course of our work. We strive to ensure that our interactions with these broad audiences are conducted with respect and in accordance with business ethics and all applicable laws and regulations.
This Code of Conduct applies to UNIFIN employees worldwide (including employees of our subsidiaries) and members of the UNIFIN Board of Directors when they perform their administrative functions; all of these individuals are referred to in this code as employees. Contractors, UNIFIN employees on a temporary or part-time basis must be familiar and fully comply with the provisions of this code when acting on behalf of UNIFIN.
The Code complements the values of UNIFIN and contains basic standards of conduct to which all employees must adhere. However, it is not an exhaustive expression of UNIFIN policy and does not cover all possible scenarios. When faced with issues not covered in the code, employees must follow the style and guidelines laid down in the code itself, as well as the company rules applicable to the situation. Adherence to the standards and procedures set forth in the code and related UNIFIN policies is a condition of continued employment with the company. Our Code is not a contract of employment, does not give any specific employment rights and does not guarantee employment for any specific period of time.
Employees are free to consult with a lawyer from the company's legal department regarding this code. All information obtained in consultation with the company legal department or with lawyers outside the company but working for the company under contract is confidential. In addition, employees should keep in mind that the company's lawyers must act exclusively on behalf of UNIFIN and may not act as personal representatives of employees.
If you have any questions regarding the Code or possible unethical conduct as an employee acting on behalf of the company, you should consult with your manager, a member of the Business Ethics Department, the General Counsel, or another lawyer in the Legal Department immediately.
If you are a manager at UNIFIN, you have a higher responsibility as an example to your subordinates. We expect managers to serve as role models and inspire other employees to abide by our code by committing to:
- Correctly and actively practice ethical behavior;
- Openly discuss and emphasize the importance of business ethics and integrity;
- Maintain and foster a work environment in which frank discussions of ethics are encouraged;
- Never make excuses for violating integrity principles, even if it helps "in the long run";
- Ensure that there are no negative consequences for openly expressing an opinion;
- Seek help as needed to clarify and resolve emerging issues.
We have a responsibility to uphold the Code
At UNIFIN, we believe that all employees should be aware of their right and obligation to speak up, especially on ethical issues. You must promptly report possible and actual violations of this code, company policies and the law. In addition, the responsible managers of UNIFIN must promptly and appropriately handle reports of ethical violations. UNIFIN will investigate all reports of questionable or unethical behavior. The investigation will be conducted with a degree of confidentiality that is possible and reasonable under the circumstances.
"I think my manager is doing something that, according to the corporate code of ethics, is considered improper. I am afraid to report this misconduct because it could make my job more difficult. What should I do?"
If you don't think you can talk directly with your manager about it, try one of the many resources available for appropriate statements. It is also an ideal situation to call the Ethics Hotline. UNIFIN will not tolerate any form of retaliation against you for reporting an ethical concern in good faith.
You should answer the following questions when deciding whether or not a code violation has occurred or is about to occur:
- Could the conduct be considered dishonest, unethical or illegal?
- Could the behavior harm UNIFIN? Could it lead to a loss of trust in UNIFIN by customers, service providers or investors?
- Could this behavior harm others - employees, investors, or customers?
If you answered "yes" or at least "maybe" to any of these questions, a potential problem has been identified and should be reported to those in authority. By reporting the issue and expressing concerns, we embody UNIFIN's values, protect UNIFIN and each other, and simply do the right thing. To raise your concerns, contact your manager or any of the employees listed below:
- Business Ethics or Global Investigations Officer
- A lawyer from the Law Department
- The person responsible for business ethics and anti-corruption
- General Counsel and Executive Director
- HR department (if the situation relates to potential harassment, unfair treatment by management or personal conflicts among colleagues)
- The Ethics Help Desk, which accepts anonymous reports.
In addition, the Audit Committee has established a whistleblowing procedure for receiving, storing and resolving complaints from employees, shareholders and others. The whistleblowing procedure is described on the company's website in the Corporate Ethics Handbook. Officers, directors or employees of UNIFIN who receive a report of an incident listed in the information procedure must immediately report it to the General Counsel. You may file a complaint under the information procedure or use the Ethics Hotline (either anonymously or not, at your discretion).
We do not tolerate retaliation
The Company strictly prohibits retaliation against anyone who asks questions, speaks up, provides information or otherwise cooperates with an investigation or proceeding regarding any conduct that the person reasonably believes violates applicable laws or regulations, this Code or UNIFIN policy. However, an employee who makes a report of misconduct with the knowledge that it contains inaccurate information, or an employee who fails to fully cooperate in an investigation, violates this Code and may be subject to disciplinary action. Reports of retaliation or attempted retaliation may be received by the Global Investigations Officer, General Counsel, a lawyer in the Law Department or through the Ethics Hotline.
We respect each other
At UNIFIN, we take pride in and value our differences in culture, experience and mindset, as well as our differences in religion, ethnicity, race, color, national origin, age, religion, citizenship, marital status, veteran status, alien status, sexual orientation, disability - recognizing that our differences and our commonalities are good for business and make our company stronger.
Every day, we work to create an open, diverse and inclusive culture. We do not tolerate discrimination or harassment.
If any UNIFIN employee feels that he or she has been treated unfairly or that his or her dignity has been violated, he or she should contact his or her business partner in Human Resources, a member of the Corporate Human Resources Department or the employment counselor in the Legal Department. We create an environment in which it is easy for employees to ask questions and actively participate in understanding, discussing and learning from situations that arise.
In this way, we can be confident that problems will be identified and resolved before they escalate into serious difficulties. Working together to maintain a work environment that fosters trust, takes initiative and accepts responsibility is an important part of the UNIFIN culture. The continued success of our individual employees, teams and the company as a whole depends on us treating each other with respect and upholding the highest professional and ethical standards.
What happens if I violate the code?
As UNIFIN strives to keep business moving in the right direction, violations of the code and other company policies may result in disciplinary action, up to and including termination of employment. Violations that lead to disciplinary action include the following:
- Violation of the code, company policy or law, or inciting another employee to violate the above rules;
- Failure to report a known or suspected violation;
- Willful or intentional disregard of the code, company policy or the law;
- Retaliation against another employee for reporting an ethics violation;
- Failure to exercise the leadership and diligence necessary to comply with company rules and the law;
- Reporting knowingly or allegedly false violations.
We avoid conflicts of interest
All employees have a duty of loyalty to UNIFIN and make every effort to avoid conflicts of interest. The success of UNIFIN depends on our ability to make decisions outside of the influence of conflicts of interest. A conflict of interest arises whenever the prospect of direct or indirect personal gain influences or could influence our judgment or actions in conducting company business. An apparent conflict of interest can be just as damaging to UNIFIN's brand and reputation as an actual conflict of interest. That is why we must avoid situations that could compromise our judgment, integrity or objectivity.
When faced with a potential conflict of interest, answer the following questions:
- Will this activity be motivated by my personal gain, or the gain of my friends, family or other business at UNIFIN's expense; might those around me perceive it that way?
- Will it damage my reputation, affect my ability to do my job negatively, or potentially harm UNIFIN?
- Would UNIFIN be embarrassed, would I be compromised if it appeared on the front page of a newspaper or blog?
If the answer to any of these questions is "yes", these relationships or situations create a conflict of interest and you should avoid them.
Some situations in which there is often a conflict of interest that you should disclose in order to conduct a risk analysis are below:
- Receiving gifts or prizes in excess of $300;
- Any travel or hotel stay paid for by a third party;
- Part-time employment, certain management positions or other lawful gainful activity;
- Transactions with third parties with whom you have a personal relationship;
- Relative employment or employment of the person with whom you have a close personal relationship;
- Having a financial interest in an entity that competes with, does business or seeks to do it with UNIFIN (e.g., a customer or supplier);
- Involvement, directly or indirectly, in any other business that competes with activities that actually or believed UNIFIN does.
If you think you may have a conflict of interest, always disclose it as soon as possible using the online form so that we can work together to find an appropriate solution. Also, if at any point your circumstances change, you will need to re-disclose them. Remember, it may not be a violation of the Code to disclose a conflict of interest itself, but rather to refuse to disclose it. For further information regarding conflicts of interest, review the Conflict of Interest Guidelines.
Conflict of interest guidelines for outside managers and directors
It is the duty of every director and officer to the company to act honestly, ethically and openly. This includes dealing appropriately with actual or apparent conflicts of interest between personal and professional relationships, as well as preventing such conflicts. Directors may also have business relationships with UNIFIN partners or competitors, conduct business or have employment relationships outside of the company, and therefore we must take special care to ensure that their obligations to UNIFIN are not breached. An increased risk to the company arises from a potential or apparent conflict of interest where UNIFIN is involved in a transaction, contract or relationship (or sequence of such events) with an "interested party" and the "interested party" has or will have a direct or indirect material interest. "Interested party" may be an executive officer, director, any member of their family, the actual owner of 5 percent or more of the company's securities, or an entity that is substantially owned or controlled by one of the above persons.
Any transaction with an interested party described above in excess of $50,000 (including a debt or debenture) must be promptly disclosed to the General Counsel and must not be executed or continued without the approval or ratification of the Board of Directors or one of its committees consisting of at least three disinterested directors. Conflicts of interest are not always clear-cut, so if a director or executive officer has concerns or becomes aware of personal or professional conflicts, they must promptly disclose the conflict in writing to the General Counsel or the Chief Executive Officer.
We give and receive incentives with common sense
Business gifts and entertainment are dictated by accepted etiquette in many business circles and vary from country to country, depending on the culture. However, they may be inappropriate if gifts or entertainment become too generous or too frequent, are of a sexual nature, or if such courtesies are used to improperly influence a business decision. We all have an obligation to use UNIFIN assets appropriately, including travel and entertainment.
As a general rule, it is acceptable to accept voluntary gifts not exceeding $300. In addition, all gifts from the same individual or entity must not exceed $300 in any one calendar year. Prior approval is required to accept gifts valued in excess of $300. Use the following guidelines regarding the acceptance of gifts:
- Gifts of cash or cash equivalent are not acceptable under any circumstances;
- Gift cards or certificates are acceptable as long as they do not exceed $100 and are not redeemable for cash;
- Gifts from competitors are not acceptable;
- You should not accept anything that could be classified as a bribe in form or content;
You should always carefully analyze the situation when receiving a gift from a supplier, business partner or other organization that actively seeks to cooperate with UNIFIN, is bidding for cooperation with UNIFIN, or whose cooperation contract with UNIFIN is currently up for renewal.
Regarding gift-giving, use the following provisions:
- They must be consistent with accepted business practices;
- They must not contravene the law or violate our company's highest ethical standards;
- They must not violate the recipient's company policies or standards;
- They should not be presented in a way that could be construed as a bribe.
Keep in mind that the rules governing gifts, favors and entertainment for any government official are stricter than those set forth in this section. Therefore, any expenditure for the benefit of a public official that exceeds $150 per person must be approved in advance through an automated anti-corruption pre- approval process.
We do not use corrupt practices
UNIFIN requires that its business is conducted in accordance with the highest ethical standards and applicable anti-bribery and anti-corruption laws and the laws of other countries in which UNIFIN operates.
UNIFIN values honesty and transparency and does not tolerate corrupt activities of any kind by UNIFIN employees or third parties acting for and on behalf of UNIFIN. Unauthorized payments or actions that give the appearance of promising, offering, providing or approving a bribe are prohibited by the anti- bribery and corruption policy and will not be tolerated.
The anti-bribery and corruption policy expressly prohibits:
Making, offering or approving any improper "payment" or giving "any valuable service or gift":
- To a particular person or at the request of a particular person for the purpose of exerting special pressure, in doing or encouraging acts or to ensure the absence of proper acts or decisions for personal gain, to conclude or prolong business relationships
- To a third party (e.g. intermediary, agent) if facts indicate that payments have been directed, offered or given in whole or in part to another person for personal benefit, conclusion or continuation of a business relationship - directly to UNIFIN or for the benefit of UNIFIN
- Receiving any form of bribe, corrupt or improper payment directly or indirectly through a third party. Prohibitions apply to any payment made to or at the request of any third party, but particularly apply to public officials because of the existence of specific anti-corruption laws in the countries in which we operate.
The following individuals and categories are prohibited from accepting bribes and corrupt practices:
- All UNIFIN employees (including temporary and part-time employees) worldwide;
- All third parties acting for and on behalf of UNIFIN (including contractors);
- Payments for existing and planned business dealings;
- Public and private sector transactions.
UNIFIN's anti-bribery and corruption policy prohibits the falsification, alteration, destruction or concealment of any UNIFIN financial documents or accounts, or the making of any false or misleading entries therein. If you have any questions or concerns, please always contact an anti-corruption officer, an anti-corruption official or the Legal Counsel of your business unit or region. Employees should review the Anti-Bribery and Anti-Corruption Policy again for more information.
We comply with economic sanctions and fight money laundering
Money laundering is the conversion of money derived from illegal activities into "clean" money from legitimate sources or transactions. Economic sanctions are financial restrictions imposed by governments or international organizations as an attempt to isolate or impede a particular person or jurisdiction for a particular purpose.
We all play a role in preventing criminals and sanctioned persons from using UNIFIN products and services. Everyone at UNIFIN should be vigilant about possible money laundering or terrorist financing. If you suspect that UNIFIN products or systems are being used for money laundering, you should report your suspicions to an Anti-Money Laundering (AML) employee. Employees may also report suspicious activity or potential violations of this policy to the General Counsel, Global Investigations, any attorney in the Law Department, the Forensic Audit team, or the Ethics Hotline. Employees may obtain additional information from the UNIFIN Anti-Money Laundering Policy.
We promote our products and services fairly
Our success is based on fair business competition. We do not try to gain a competitive advantage through illegal or unethical business practices. Every employee should strive to deal fairly with UNIFIN customers, service providers, competitors and employees. No employee should seek an unfair advantage through manipulation, concealment, abuse of privileged or confidential information, misrepresentation of facts or any unfair dealings or business practices. There are a number of situations that must be avoided in order to comply with competition laws. When dealing with our competitors, you must avoid discussing certain confidential business matters. In particular, you must not do the following:
- Negotiating prices or terms for products and services we sell;
- Agreeing to divide markets, customers or territories;
- Agreeing to ignore customers, suppliers or other competitors.
In general, when in doubt, seek help from a manager, your department or regional legal counsel, any other lawyer in the Law Department or the General Counsel; do not try to speculate about legal provisions. For more information, employees should consult the International Antitrust and Competition Law Policy again.
We keep honest and accurate financial records
We are all responsible for ensuring that UNIFIN's books and records accurately, fairly and reasonably reflect the nature of transactions. UNIFIN's books and records must comply with company accounting policies and internal control requirements, regardless of the size of the transaction.
As we make efforts to close transactions, maintain records, meet deadlines and complete projects, we must remember that accurate and complete accounting records are of paramount importance. Therefore, before finalizing documents, records and reports, we must ensure that they are accurate and that all necessary approvals are in place. Deliberately misrepresenting information or company activities in documents and reports is a serious violation of UNIFIN policy and a possible violation of the law. It can have serious consequences both for you personally and for the company.
Intentional misrepresentation or falsification of records leads to disciplinary action up to and including termination of employment and could potentially result in additional sanctions. When in doubt, it is always best to ask before acting. Employees should not engage in transactions for which there is reason to believe that the purpose of the customer, merchant, business partner or supplier is to make a profit or income, arrange cash flow or make a balance sheet for financial statements fraudulently. If someone asks you for false or inaccurate information, you must refuse and report the incident to your manager, the Business Ethics or Global Investigations Officer, the General Counsel or Lawyer in the Law Department, the CFO or the Corporate Auditor.
We are appropriately involved in the political process
UNIFIN strives to engage in the political process in a way that informs and influences the debate about our business, customers and innovation; we strive to do so in the most responsible and ethical manner. UNIFIN complies with all applicable laws and regulations regarding the company's political activities. Any political activity in which UNIFIN is involved is based solely on the interests of the company and is conducted without regard to the personal political views of company officials and/or executives. UNIFIN's Government Relations Department oversees the company's public policy strategy; political contributions and corporate political expenditures are approved by the head of the Global Public Policy Group.
We use UNIFIN assets wisely and responsibly
Part of the principle of ethical and fair dealing is to protect UNIFIN's physical assets as well as intangible assets, including our brand, reputation and confidential information. UNIFIN's assets must be used responsibly. The personal computer (desktop and/or laptop) provided by UNIFIN, as well as any other UNIFIN devices or systems to which you have access, are primarily for business use. A limited, dictated use of the computer or other UNIFIN-provided devices for personal purposes is acceptable as long as it does not interfere with your work and does not violate UNIFIN rules or standards.
You should never use our company computers or network systems for inappropriate behavior, such as viewing obscene or sexually explicit material, as accessing such sites can be harmful to the UNIFIN culture, workplace, systems and network. UNIFIN's intellectual property is one of the company's most valuable assets. You must safeguard UNIFIN's trade secrets as well as other confidential company information. You must also respect the intellectual property rights of others. Your respect for UNIFIN's property rights, including rights to information, products, software, services and tangible assets such as equipment and office interiors, supplied consumables, is necessary to protect UNIFIN's assets and to conduct business properly.
We handle information discreetly
During the course of your employment, you may receive certain information about UNIFIN, its customers, suppliers, business partners or other third parties that is confidential, concealed from competitors, proprietary and/or that UNIFIN is contractually obligated not to disclose. You must treat information as confidential unless there is evidence that the information has been publicly disclosed or the company has the right to disclose it. Always take reasonable and necessary precautions to protect any confidential information to which you have access concerning UNIFIN or another company. It is forbidden to disclose any confidential information outside of UNIFIN, even to your family members. Even within the company and among colleagues, you must only share confidential information on a need-to-know basis. These obligations remain valid even after you leave UNIFIN.
We protect our information assets
As a global company, UNIFIN collects, processes, uses and creates information assets. UNIFIN defines Information Assets as any intellectual property of UNIFIN and any non-public and/or personal information received, held or transmitted by UNIFIN in any form or medium, including electronic, printed and other data, storage devices and equipment, computer programs and electronic data transmission.
Information assets include, but are not limited to, the following:
- Aggregate Indicators
- Anonymized transaction data
- Business contact data
- Company performance data • Competitor data
- Sensitive transaction data
- Customer data
- Customer reports data • Employee data
- Vendor data
Proper use of our information assets is important to protect the UNIFIN brand and reputation, as well as to comply with legal and regulatory requirements.
The Global Privacy and Data Protection Policy provides guidance to employees on the collection, use and retention of UNIFIN's information assets and ensuring that UNIFIN complies with legal, contractual and ethical requirements for the management and protection of such information assets. If you have access to personal or confidential data related to customers, consumers, our employees, board of directors, our vendors, contractors or data storage systems, you must comply with all applicable laws and regulations regarding the collection, use and disclosure of that data.
- Collect only data that is required for a specific business activity;
- Use access to personal information only for legitimate business purposes;
- Store and delete personal information in a secure manner;
- Transmit - securely, through encryption - personal information only to authorized individuals who have a duty to protect its confidentiality;
- Promptly report any potential privacy breach or security risk to the Global Privacy Office or the Legal Department.
If you have questions, contact the person responsible for Global Privacy and Data Protection or a member of the Global Privacy and Data Protection team. For more information, employees should review the Global Privacy and Data Protection Policy again. We are all responsible for identifying the level of confidentiality of information, assigning personal responsibility and determining appropriate data protection.
All employees must exercise care to ensure that confidential information, whether customer, employee or other personal or confidential business information, is handled appropriately and in accordance with established policies and in compliance with applicable laws, regulations and the Clear Desk Policy of the Information Security Policy. Particular care should also be taken when handling information that could have an impact on the securities market.
Government agencies or lawyers representing third parties may contact you directly for reports, audits, investigations or claims against UNIFIN. All such inquiries must be referred to the Legal Department before any response is made or any information is disclosed. In addition, you may receive requests from various government agencies, lawyers or third parties for access to data on UNIFIN transactions or other information assets. All requests concerning UNIFIN information assets must be directed to the Data Privacy Officer before any information or response is provided to the requesting authority. This ensures that such requests are handled in accordance with legal and data protection requirements.
We do not misuse information
In the course of your work, you may become aware of certain confidential information that qualifies as "material, inside information" about UNIFIN, one of its customers, suppliers, business partners or other third parties. Disclosure of material non-public information can have serious consequences for UNIFIN and for you personally. Accordingly, you must not disclose such information to anyone outside our company, including family and friends. You may only provide such information to UNIFIN on a need-to- know basis.
Information is considered "material inside information" if it:
- is not widely disseminated and
- is information that a reasonable investor would consider important in deciding whether to buy or sell a particular security.
Since UNIFIN is a public company, no employee, regardless of his or her location, shall conduct transactions in securities of UNIFIN or another company affiliated with UNIFIN while in possession of material inside information about UNIFIN or such company. This prohibition applies to all transactions in UNIFIN securities, including the purchase or sale of UNIFIN shares, the exercise of options or the sale of restricted shares subject to exercise.
Employees are prohibited from engaging in transactions in UNIFIN securities that do not involve a long- term investment in UNIFIN. Examples of inappropriate securities transactions include transactions intended to generate profits based on fluctuations in the value of UNIFIN securities, such as "day trading" as well as selling shares without coverage (short sales), selling shares "against the vault", buying UNIFIN shares on margin (except when cash is available to cover margin) and arbitrage trading in securities. In addition, you may not engage in activities that are designed to hedge or offset any decline in the market value of UNIFIN stock (including the purchase of financial instruments such as prepaid variable forward contracts, currencies, stock swaps or short sales). If you have questions about compliance with this section, contact the Corporate Secretary or another SEC lawyer in the Law Department.
We speak with one voice
As a public company, we must speak with one voice outside of UNIFIN. Providing consistent and accurate information to the public, our current and potential customers, business partners and investors is vital for our reputation and is absolutely necessary to fulfill our regulatory and legal obligations. Only authorized representatives of UNIFIN may speak on behalf of UNIFIN in the press or at external events, conferences, trade shows or forums. If you receive a question from the media, you must not answer or provide any information on behalf of UNIFIN without first consulting the International Communications Department. Inquiries from investors should be directed to Investor Relations. Additional details regarding external communications are described in the All Personnel Policy, the Investor Communications Policy and the International Communications Policy. As a company, we communicate with our employees, customers, partners and others through web logs (blogs), social media, forums, wikis, videos and other social media. This can be a great way to support dialogue and discussion. The UNIFIN Social Media Policy establishes guidelines for employee participation in social communities and encourages employees to act responsibly, respectfully and transparently when using these means of communication.
It is especially important to keep the following provisions in mind:
- The UNIFIN Code of Ethics and policies apply to your online behavior (blogging or other online discussions) just as they do to your behavior in real life;
- Refrain from discussing UNIFIN confidential information, such as future product or service offerings;
- Respect the intellectual property rights of others, including copyrights;
- When talking about UNIFIN products and services, identify who you are and where you work;
- Refrain from comments that are vulgar, obscene, threatening, intimidating, harassing, violate UNIFIN equal opportunity policies or are illegal.
If you have any further questions or concerns about any aspect of the social media policy, contact us at
UNIFIN expects every employee, at every level, to behave with integrity and dignity. We hope the code will help you identify potential ethics issues and provide guidance on how to handle such situations. Remember, if you are unsure how to proceed, you should consult with your manager, someone in Business Ethics, Human Resources or a lawyer in the Law Department.