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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
To ensure the safety, security, and trustworthiness of our platform and services, our code of conduct grants us the following rights and/or authorities:
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.
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:
Warnings:
Reprimands:
Training:
Qualification Minimums:
Remediation Plans:
Compliance Audits:
Restitution:
Contractually Agreed Penalties:
Conditions on Trading:
Trading Prohibitions:
Suspensions and Restrictions to Trading:
Expulsions:
Cancellation of a Client’s Orders and Outstanding Instructions:
Reporting Breaches to VARA:
Criminal Referrals:
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.
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.
