TO BECOME A CLIENT

CORPORATE CULTURE

This Statement on Corporate Culture delineates basic values, beliefs, practices, ethical norms and principles shared across Veles International Limited (VIL or we) to which VIL adheres to while conducting its business, as well as building and maintaining relationship and communications both internally and with the community and the society as a whole.

INTEGRITY

We always strive to act with integrity as a company and as each and all our directors, managers and employees. This generally implies the following:

Being honest, open, fair and trustworthy in all our activities and relationships;

  • Staying compliant with applicable laws and regulations governing our business observing both the letter and the spirit thereof;
  • Promptly reporting any concerns we may have about compliance with the law and our policies;
  • Being accountable and transparent in our actions both internally and externally;
  • Staying attuned to developments in the financial industry that might impact our business, including client protection, compliance with laws and regulations or our reputation in the marketplace;
  • Being tolerant, cooperative, supportive and friendly in our day-to-day intercompany relations.

THE ROLE OF THE BOARD AND MANAGEMENT

To foster VIL’s adherence to the Integrity principles VIL’s Board of Directors and its Management undertakes to act as follows:

  • Personally set the example for integrity, not just through words, but more importantly, through actions (the tone from the top);
  • Communicate across the company the importance of integrity principles, ethics and compliance with sincerity and conviction at every appropriate opportunity;
  • Establish clear lines of responsibility and a strong system of accountability and performance measurement including into it metrics related to ethical and compliant behavior;
  • Create an open and friendly environment in which every employee feels comfortable raising concerns;
  • Ensure the integrity of VIL's accounting and financial reporting systems, including related financial and operational controls and compliance with the regulatory system;
  • Oversee the process of timely and complete disclosures and transparent communications with all relevant regulatory authorities and the public.

THE CULTURE OF PARTICIPATION

  • Our corporate goals and objectives are being clearly communicated across the company and their interdependence especially stressed and exemplified by the Board and Senior Management;
  • We strive to act as the unified real team whose members share a common goals that they pursue collaboratively;
  • Our Board of Directors fosters and adheres to facilitating leadership style and strictly opposed to the authoritarian one;
  • All our employees are encouraged to participate in discussions on strategy, company policies and procedures creation and processes improvement, as well as to highlight possible deviations and breaches thereof;
  • Every employee whose proposal, or initiative, or whistleblowing activity brought any benefit  or advantage to the company is subject to a respective and fair reward;
  • Our Board’s independent directors and their commitment to the principles of diversity are there to prevent the trap of group thinking and escalation of commitment.

FAIR EMPLOYMENT PRACTICES

  • We base employment decisions on job qualifications and merit which include education, experience, specific professional skills, ability, performance and communication skills;
  • Employment decisions are always made without considering a person’s race, color, religion, national or ethnic origin, sex (including pregnancy), sexual orientation, gender identity or expression, age, disability, veteran status or other characteristic protected by law;
  • We create a work environment free from harassment on the basis of any protected characteristic, and free from bullying;
  • We never disclose employment data to a person who does not have a legitimate need, the authority, or, where required, the subject’s consent;
  • We strive to build and maintain diversity in constitution of management bodies and respective departments;
  • We take affirmative action where required by law to increase opportunities in employment for women, minorities and people with disabilities;
  • We respect human rights everywhere we work and do business with others.

TREATING CLIENTS FAIRLY

Treating clients fairly is central to our corporate culture. We always strive to ensure that we know our clients, will look out for their individual needs, take into account their personal circumstances and will ultimately and fairly reward them for their business. In pursuing these goals we, as a daily routine, make the following steps:

  • Provide clients with clear, fair and misleading information, including that on the products and services clients are interested in or in the process of receiving form the company;
  • Present all the regulatory and product related information to customers in full but concise form using plain language and avoiding unnecessarily complex terminology, small fonts or sophisticated disclaimers;
  • Do not create, even indirectly, financial or other barriers (e.g. extra fees, onerous paperwork, time frames, etc.) for customers to exit the onboarding process, switch to different products or services VIL offers or close their account at any time;
  • Recognize the challenge to balance the requirement for collecting more insight on customers with the need to simplify the account opening process for an enhanced customer experience.

ZERO-TOLERANCE TO CORRUPTION

  • We take a zero-tolerance approach to bribery and corruption and are committed to acting professionally, fairly and with integrity in all our relationships and business dealings and to implementing and enforcing effective systems to counter bribery;
  • We prohibit any member of our staff and associated person from, directly or indirectly, offering, promising, soliciting, requesting, receiving or agreeing to receive bribes including facilitation payments, kickbacks, advantage or other inappropriate inducements in any form. It also prohibits the use of other routes or channels to provide or receive improper advantages to/from clients or other third parties;
  • It is our policy not to engage any third party who we know or reasonably suspect of engaging in bribery or corruption practices. We complete sufficient due diligence on third parties to ensure that they are not acting corruptly;
  • It is our policy not to make donations or contributions to politicians, political parties or campaigns. Employees are not permitted to make any political contributions on VIL’s behalf. Any charitable donation is a subject of special scrutiny;
  • We realize that gifts, hospitality and entertainment may, in certain circumstances, represent a bribe. Therefore, all such payments and benefits are subject to comprehensive scrutiny;
  • We undertake appropriate anti-bribery and corruption training and awareness-raising upon induction of new members of staff and on ad-hoc basis tailoring the respective programs to the specific risks associated with particular posts and functions.

ENVIRONMENT, HEALTH AND SAFETY

  • We comply with all environmental laws and regulations that may be applicable to our business;
  • We view waste as a measure of inefficiency and strive to minimize waste in our operations;
  • We do our best to use electricity, water and heat supply in minimum amounts needed for business and safety of our staff;
  • We dispose of our used electronics and supplies using specialized contractors;
  • We commit to the principles of Environmental Preferable Purchasing;
  • We follow safe work procedures to ensure workplace safety and prevent injuries.