nealthy - digital asset management

Code of Conduct and Ethics

Version: 1.2
Last revised: 24. October 2023

1. General

nealthy (hereinafter referred to as the “Company”) were founded and operate on the simple but fundamental principle that we envision a future where investing is accessible, inclusive and empowering for all. As nealthy continues to build tools to increase economic freedom, we are committed to ensuring our Code of Conduct and Ethics.

2. Purpose

This Code of Ethics underscores the commitment of our Company and its employees to uphold the highest standards of ethical behavior, especially in the realm of Transaction Monitoring. While our focus is on identifying Virtual Assets Red Flags indicative of Money Laundering and Terrorist Financing, it's paramount that we, as a collective, approach this responsibility with integrity, transparency, and diligence. By adhering to this code, we not only aim to conduct Anti-Money Laundering/Counter-Terrorist Financing (AML/CFT) risk assessments but also ensure that our interactions with Virtual Asset (VA) activities reflect our dedication to ethical conduct.

3. Objective

The objective of this Code of Ethics is more than just monitoring for suspicious activities. It's about instilling a culture where every employee understands the importance of ethical behavior in preventing money laundering or terrorist financing. We are not just complying with laws and regulations, but we are also reinforcing our commitment to act with honesty, integrity, and in the best interests of society. Every employee is expected to internalize these values and reflect them in their daily operations and interactions.

4. Supplier

In order to protect and uphold the fundamental rights and dignity of individuals providing services to nealthy, we require our vendors to adhere to the same principles. It is expected that all providers will operate in full compliance with applicable laws, rules and regulations, both for themselves and for nealthy. Central to this compliance is strict adherence to our Code of Conduct and a robust ethical framework that prohibits bribery, corruption, trade violations, slavery, human trafficking, and ensures whistleblower protection and safeguards against retaliation. nealthy has a zero-tolerance policy toward illegal tax evasion. Providers are expressly prohibited from directly or indirectly engaging in, or facilitating others to engage in, the fraudulent diversion of funds from tax authorities. Suppliers must implement and maintain reasonable procedures to prevent such conduct.

5. Whistleblowing

‍nealthy employees are strongly encouraged to report potential violations in a manner that facilitates effective investigation and remediation. Generally, this will involve open or confidential reporting rather than anonymous reporting. nealthy is committed to maintaining confidentiality not only with respect to the identity of the whistleblower, but also with respect to any "identifying information". It is important to recognize that when facts are known to only a few people, those details can often be traced back to the source and serve as a de facto signature.

If an employee chooses to make an anonymous report, he or she must provide sufficient information about the basis of the allegations, along with appropriate details or supporting evidence, to allow the matter to be responsibly pursued. Otherwise, it may not be possible to proceed with an investigation. Furthermore, even if anonymous allegations are sufficiently detailed or supported to permit a responsible investigation, no final determination of misconduct will be made solely on the basis of such anonymous allegations without independent corroboration.

6. Zero Tolerance

We are committed to conducting our business with integrity, transparency, and in full compliance with all applicable laws, rules, and regulations. We maintain a zero-tolerance approach towards bribery and corruption in all forms, whether direct or indirect.

nealthy has no current conflicts of interest. In addition, we are committed to industry-leading compliance standards and full transparency. These practices are regularly reviewed as part of our risk assessment and internal audit. There are no past convictions or prosecutions of any member(s) of our Senior Management or Board.

7. Competition

We are committed to competing ethically, fairly, and robustly. Our products and services stand out due to their inherent merit, exceptional quality, functionality, and competitive pricing. Our pricing and marketing decisions are made independently, ensuring we never engage in inappropriate collaborations or alignments with competitors.

8. Environmental Responsibility

Our commitment to environmental stewardship drives us to minimize and mitigate the environmental impact of our business operations. As such, we hold our service providers and ourselves accountable for developing, implementing and maintaining environmentally responsible practices. These practices include actively seeking ways to conserve natural resources and energy, reducing waste generation, and striving to minimize adverse environmental impacts.

By adhering to these principles, we collectively contribute to a more sustainable and environmentally conscious business landscape.

9. Respect for the individual

We prioritize the holistic well-being, dignity and respect of every team member. Our success is intertwined with the health and inclusivity of our workplace. As a committed equal opportunity employer, nealthy has zero tolerance for discrimination or harassment. We actively protect the mental and physical health of our employees. Any nealthy team member who encounters issues related to well-being in the workplace is encouraged to report them to their manager or Human Resources.

Our expectations of all nealthy employees are

- Consistently uphold dignity, respect and well-being

- Address and report any discriminatory or offensive behavior

- Value diversity and promote inclusive teamwork

- Communicate clearly and avoid potentially misunderstood language

- Support flexible work arrangements to meet diverse needs

- Challenge decisions or behaviors based on bias

The Company’s commitment to a healthy, inclusive and respectful environment is unwavering. Our goal is clear: a thriving team leads to unparalleled success.

10. Open and Honest Communication

At nealthy, we encourage open dialogue and value the insights of each team member. We believe in fostering an environment where everyone feels empowered to speak up, especially on ethical issues.

Leaders have a critical role in fostering a supportive atmosphere where raising concerns is welcomed. The collective strength of our company is enhanced when employees proactively address potential issues by asking timely and relevant questions.

11. Uphold the Law

The Company’s foundation of integrity is built on adhering to all relevant laws, rules, and regulations wherever we operate. Every employee is expected to be well-versed in the policies, laws, and regulations pertinent to their role. Should there be any uncertainty about the legality or policy-compliance of an action, it's essential to consult the Compliance team for clarity. We hold ourselves accountable for preventing any legal infringements or rule breaches and are proactive in voicing concerns if potential violations are observed.

12. Upholding Integrity

To ensure the safety, security, and trustworthiness of our platform and services, our code of conduct grants us the following rights and/or authorities:

  1. To issue warnings to any party that may be in potential or actual breach of our policies.
  2. To administer reprimands for any violations observed.
  3. To mandate training sessions to ensure all parties adhere to our standards.
  4. To establish qualification minimums, ensuring the quality of service remains uncompromised.
  5. To devise and enforce remediation plans for those found in non-compliance.
  6. To carry out compliance audits, ensuring continuous adherence to our guidelines.
  7. To seek restitution in instances of financial or reputational harm caused to our platform or its users.
  8. To impose contractually agreed penalties for any breaches.
  9. To set specific conditions on trading to maintain market integrity.
  10. To prohibit trading for parties in severe violation of our guidelines.
  11. To enforce suspensions and restrictions on trading for those found in breach.
  12. To expel parties that consistently or egregiously violate our standards.
  13. To cancel a client’s orders and any outstanding instructions from that client if deemed necessary for the greater good.
  14. To report any breaches to VARA (Virtual Asset Regulatory Authority), ensuring we remain in line with industry-wide compliance.
  15. To make criminal referrals in situations where violations may warrant legal repercussions.

13. Potential Abuse

If we suspects potential abuse affecting the market we provide VARA with the following information:

a. Details of a participant’s positions, in particular details of any large positions held, including      on-exchange, related “over-the-counter” derivatives and physical market positions;

b. Virtual Asset inventory levels;

c. delivery mode and forms of service;

d. action taken to implement position management powers;

e. changes to position limits;

f. additional Margin calls; and

g. other action taken by us.

14. Conduct

nealthy upholds the highest standards with regards to Conduct. As such, we have instilled the rights and power to implement disciplinary actions against clients/participants on the nealthy platform, where the clients/participants breach any Regulations, Rules or Directives. The company has implemented the following powers/rights when dealing with clients/participants:


  • We reserve the right to issue warnings to users or entities that do not adhere to our set guidelines or display questionable behaviour that may go against our standards or regulations.


  • In situations of non-compliance or misconduct, formal reprimands may be issued, highlighting the specific discrepancies and expected rectification.


  • We may mandate specific training sessions to ensure that our users are well-informed and act in accordance with our guidelines and regulatory requirements.

Qualification Minimums:

  • Users and entities may be required to meet certain qualification standards or criteria before engaging in specific activities or accessing certain services on our platform.

Remediation Plans:

  • In instances of breaches or non-compliance, affected parties may be provided with, or required to develop, a remediation plan to address and correct the identified discrepancies.

Compliance Audits:

  • We retain the right to conduct compliance audits periodically or based on triggers to ensure adherence to regulations and our guidelines.


  • In cases where a user's action has resulted in financial or reputational harm, we may require restitution to make whole any aggrieved parties.

Contractually Agreed Penalties:

  • Breach of our terms and conditions may result in penalties if outlined in our agreement with the user or entity.

Conditions on Trading:

  • We reserve the right to impose specific conditions on trading, which may pertain to volume, frequency, or type of assets traded.

Trading Prohibitions:

  • Certain actions or breaches may result in temporary or permanent trading prohibitions for offending parties.

Suspensions and Restrictions to Trading:

  • We may suspend or place restrictions on trading activities for users or entities based on their behaviour or as deemed necessary for regulatory or security reasons.


  • Severe or repeated breaches may lead to the expulsion of a user or entity from our platform.

Cancellation of a Client’s Orders and Outstanding Instructions:

  • In the interest of platform integrity and user protection, we retain the right to cancel a client's orders and any outstanding instructions if deemed necessary.

Reporting Breaches to VARA:

  • Any breaches that are identified and fall under VARA's purview will be promptly reported to VARA in line with regulatory requirements.

Criminal Referrals:

  • In cases where misconduct may be of a criminal nature, we will make the necessary referrals to appropriate legal or law enforcement agencies.

All users and entities engaged with our platform are expected to be familiar with and adhere to these provisions. Our commitment is to maintain a secure, transparent, and compliant platform for all our stakeholders.

15. Responsibilities

The Company will ensure that all staff are provided with the time, training and support to learn, understand and implement this policy and any related regulatory requirements. All staff are responsible for understanding the obligations under the regulatory system and for ensuring that they know, understand and comply with the Company’s objectives.