CODE OF CONDUCT AND PRIVACY POLICY
1. OBJECTIVE
This Code of Conduct, Ethics, and Information Security Policy (“Code”) defines the rules and principles that guide the conduct of partners, members, directors, board members, and other individuals involved in Koinz Capital Inc. (“Koinz”) activities. This Code establishes guidelines for Koinz’s internal and external relationships, ensuring integrity, transparency, and alignment with best market practices.
1.2. This Code establishes guidelines for internal and external relationships involving Koinz, providing guidance on (i) daily activities; (ii) the provision of data to support Koinz's relationships with third parties; and (iii) the core values and fundamental principles of conduct.
1.3. These guidelines must be strictly followed by all Concordants, who must acknowledge their awareness of all rules and policies outlined herein, affirming that they have no doubts about them and committing to adhere to them at all times while performing their activities.
2. STANDARDS OF CONDUCT
2.1. All Concordants must conduct themselves in accordance with the principles of good faith, loyalty, and truthfulness, following applicable laws, norms, and regulations. They must recognize that transparent, accurate, and timely information is the primary tool available to investors to ensure equitable treatment.
2.2. Koinz and its members must base their actions on thorough market analysis and a commitment to excellence in investment decisions, without ever relying on privileged information.
2.3. Koinz shall act and require Concordants to act in accordance with laws, regulations, and market best practices.
2.4. Whenever required by regulatory bodies for compliance verification with applicable regulatory provisions, Koinz will provide all requested information within the stipulated timeframe.
2.5. The relationship between Koinz, Concordants, and clients shall be conducted transparently and fairly, respecting mutual interests and proactively mitigating risks, including those related to Koinz's reputation.
2.6. Koinz's Compliance or Internal Risk department is responsible for assessing personal and professional attributes of Concordants that could affect Koinz's image and reputation.
2.7. Koinz shall not tolerate or support discrimination in hiring, compensation, or access to training based on color, gender, race, belief, disability, religion, political orientation, union affiliation, financial, social, or intellectual condition, sexual orientation, marital status, or any other form of social exclusion.
2.8. Koinz shall not tolerate sexually coercive or abusive behavior, including gestures, language, or physical contact, by any Concordant.
2.9. Koinz will comply with applicable laws and market practices regarding working hours.
2.10. The provision of confidential information to external parties shall only occur when strictly necessary, exclusively for compliance with industry regulations, fraud prevention, or any suspected illegal activity, and must be subject to confidentiality agreements where applicable.
3. CONFLICT OF INTEREST
3.1. Conflicts of interest include any personal interests of Concordants, whether for personal gain or the benefit of third parties, that are contrary or potentially contrary to the interests of Koinz, investors, or other clients.
3.2. Koinz must act diligently to prevent or manage conflicts of interest, ensuring that its investment decisions align with the best interests of its members and strategic partners.
3.3. The hiring of professionals or service providers, including audit, consultancy, and law firms, follows these mandatory criteria:
a) Evaluation based solely on technical and objective criteria; b) Alignment with Koinz's business needs; c) In cases where a Concordant recommends a candidate, they shall be prohibited from participating in the decision-making process.
3.4. Concordants are prohibited from:
a) Using their position, access to relevant information, or the name of Koinz inside or outside the workplace to obtain personal benefits or advantages of any kind for themselves or third parties;
b) Receiving or making commissions, rebates, or general payments from or to clients and suppliers; and
c) Violating any rules or regulations applicable to their role.
3.5. It is strictly forbidden to conduct transactions on behalf of Koinz with individuals or legal entities related to any of the Concordants or individuals connected to them with financial interest intent.
4. GUIDELINES
4.1. Political Activities:
Concordants are not allowed to:
a) Engage in political activities within Koinz premises; and
b) Use Koinz’s assets or resources for political causes or campaigns.
4.2. Gifts and Presents:
Gifts and/or presents offered to Concordants may be accepted if their value is below US$100.00 (one hundred dollars) and must be raffled among all employees.
4.3. Business Lunches or Dinners:
If a business lunch or dinner is necessary, it must be approved by at least two (2) Koinz directors and comply with the internal reimbursement policy.
5. PREVENTION OF FRAUD, MONEY LAUNDERING, BRIBERY, AND COMBATING TERRORISM
5.1. Koinz implements strict governance measures to ensure compliance with applicable laws, preventing irregular practices in its operations and investments.
5.2. Concordants must pay special attention to operations with the following characteristics and report such situations to Compliance:
a) Transactions with values that are objectively incompatible with the professional occupation, income, and/or financial position of any involved parties based on their registration information;
b) Transactions designed to obscure the identification of actual participants and/or beneficiaries;
c) Transactions evidencing repeated action on behalf of a third party;
d) Transactions between the same parties with successive gains or losses for certain participants;
e) Transactions with significant fluctuations in volume and/or frequency;
f) Sudden and unjustified changes in usual operational modalities;
g) Transactions aimed at generating loss or gain without a clear economic rationale;
h) Transactions involving entities located in jurisdictions with inadequate anti-money laundering and counter-terrorism financing measures;
i) Cash-settled transactions, where permitted;
j) Unexplained private transfers of funds or securities;
k) Transactions of excessive complexity or risk for the investor’s technical qualification;
l) Deposits or transfers from third parties for client transactions or guarantees in future markets;
m) Payments to third parties for transaction settlements or withdrawals from guarantee deposits in client accounts;
n) Inability to maintain up-to-date client records;
o) Situations where the final beneficiary cannot be identified;
p) Transactions involving:
i) Non-resident investors, particularly those structured as trusts or bearer share companies;
ii) High-net-worth individuals managed by private banking services;
iii) Politically exposed persons (PEPs).
5.2.1. The above-listed operations must be analyzed together with other related transactions that may be part of a broader pattern of activity.
6. INFORMATION SECURITY POLICY
6.1. Company Assets:
Koinz’s assets—including facilities, equipment, and information—are provided to Concordants exclusively to serve Koinz’s legitimate business interests.
6.1.1. Concordants are responsible for protecting and maintaining these assets in accordance with IT procedures.
6.2. Information Systems:
Concordants with access to Koinz’s information systems must take necessary precautions to prevent unauthorized access, safeguarding passwords and other access credentials.
6.2.1. Information should not be disclosed to unauthorized individuals unless necessary for professional duties. If in doubt, Concordants must consult Compliance before sharing any information.
6.2.2. Any information regarding Koinz’s activities, Concordants, clients, and investors may only be disclosed to the public, media, or other entities with Compliance approval.
7. TRADING WITH MATERIAL INFORMATION
7.1. All Concordants must handle, disseminate, and use material information in accordance with regulations and this Code’s principles.
7.2. Koinz members, their spouses, partners, and dependents are prohibited from conducting financial transactions based on material non-public information, ensuring that all transactions comply with applicable regulations and are conducted ethically.
7.3. Concordants must not disclose material information unless strictly necessary for business purposes. If disclosure is required, the recipient must be informed that the information is confidential and cannot be used for trading.
7.4. If in doubt about the handling of certain information, Concordants must consult Compliance.
7.5. Even after public disclosure, Koinz and Concordants must continue treating information as non-public until the market has had reasonable time to process it.
8. ORGANIZATIONAL CULTURE
8.1. Concordants must:
a) Stay updated on relevant laws, regulations, contracts, and instructions, and participate in internal training when required;
b) Ensure the confidentiality of sensitive information;
c) Identify and manage potential conflicts of interest;
d) Be cautious when discussing business matters in public places;
e) Protect Koinz’s reputation by avoiding inappropriate behavior, including:
Excessive alcohol consumption; Gambling; Illegal drug use; Discrimination based on gender or LGBTQIA+ identity; Other behaviors incompatible with their role at Koinz.
8.2. Violation of this Code may result in disciplinary measures, including termination, in accordance with applicable laws, as well as civil and criminal penalties.
9. KOINZ WHISTLEBLOWER SYSTEM
Koinz maintains an anonymous whistleblower channel on its website for employees and third parties to report violations of this Code and relevant regulations.
