TroqPay Code of Business Conduct and Ethics

1. Why this Code exists

TroqPay was created to help companies grow and operate beyond borders.

We also want to grow. We want to build a relevant, sustainable company that creates results for customers, business partners, team members and owners.

But we do not want to grow at any cost.

How we build matters. This Code sets out the principles that guide our decisions, our professional relationships and the way we choose to do business.

It exists to make clear what customers, suppliers, business partners, team members and other people can expect from TroqPay, as well as the relationship standard we expect when working together.

It was not created to anticipate every possible situation or to turn trust-based relationships into bureaucracy.

We also do not expect every company to think like us or adopt our principles as its own internal policies.

This Code is, above all, a statement about how we choose to work and an invitation to reflect on how we build professional relationships and business.

2. Who this Code applies to

This Code guides the conduct of owners, directors, officers, employees, contractors, service providers and other people acting on behalf of TroqPay.

We also expect customers, suppliers, business partners and other third parties to respect these principles in their interactions and activities related to TroqPay.

We do not expect third parties to adopt this Code as an internal policy, reproduce our values in their own organizations or submit all their activities to our rules.

Each organization has its own culture, policies, priorities and responsibilities.

However, when working, negotiating, collaborating, representing or interacting with us, we expect respect for the principles set out in this Code.

This Code complements TroqPay contracts, Terms of Use and other applicable policies. When specific rules or stricter legal obligations exist, they must be observed.

3.1 We grow with integrity

Growth, results and revenue matter. But none of them justifies fraud, corruption, abuse of trust, discrimination, disrespect or other practices that are incompatible with the way we choose to build TroqPay.

We pursue opportunities, negotiate, compete and defend our commercial interests in a legitimate and responsible way.

3.2 We honor our commitments

Our word matters. We seek to honor contracts, commercial commitments and the responsibilities we assume with customers, suppliers, business partners and each other.

We also know that business changes. Deadlines may need to be reviewed, conditions may stop making sense and problems may happen.

In those cases, the expectation is simple: communicate, explain and seek a new solution instead of ignoring what was agreed.

Likewise, we expect companies and people who work with us to communicate limitations, changes, risks or relevant problems when they may affect commitments made.

3.3 We act when something is wrong

Problems happen, but how we respond to them is a choice.

When we identify an error, risk or conduct incompatible with our principles, we seek to understand what happened and act quickly.

We do not believe in indefinitely ignoring problems, hiding relevant situations or maintaining relationships that no longer have the trust needed to continue.

Depending on the situation, we may discuss, correct, renegotiate, restrict an operation or reassess a relationship.

In some cases, we may immediately end a partnership, engagement or commercial relationship. Not every situation requires multiple warnings or a mandatory sequence of measures before a decision.

4. How we do business

We want to build commercial relationships in which the parties can defend their interests without compromising the trust required to work together.

We expect equivalent conduct in relationships with us. We believe disagreements are part of professional relationships and can be firm and direct.

What we do not consider acceptable is turning disagreements into humiliation, intimidation, discrimination, personal attacks or abusive conduct.

A commercial relationship may also stop making sense for strategic, technical, financial, operational, reputational or risk reasons. Ending or not renewing a relationship for those reasons is part of business, and termination by itself does not represent a breach of this Code.

• Negotiate in good faith.
• Provide truthful and relevant information for the relationship.
• Clearly present prices, conditions and responsibilities applicable to the party we are contracting with.
• Communicate relevant problems when we become aware of them.
• Respect commitments made.
• Preserve confidential information.
• Respect third-party intellectual property.
• Comply with applicable law.
• Treat customers, suppliers, business partners and colleagues professionally and respectfully.
• Recognize functions, responsibilities, competence and professional authority regardless of gender, race, ethnicity, nationality, disability, sexual orientation, religion, age or other personal characteristics.
• Avoid practices deliberately intended to mislead another party.
• Do not represent as existing a partnership, authorization, role or professional relationship that does not exist or has already ended.

5. Conflicts of interest, gifts, travel and commercial relationships

Commercial relationships are part of business.

Meetings, events, meals, gifts, travel, lodging, invitations, sponsorships and other legitimate forms of relationship building may be part of TroqPay's activities.

TroqPay may also participate in referral programs or enter into agreements involving commissions, rebates, referral fees, revenue share, sponsorships, discounts, incentives or other legitimate forms of commercial remuneration and benefit.

This Code does not prohibit these practices.

What we do not accept is gifts, travel, payments or other benefits being used as an undue advantage, hidden personal consideration or condition for a decision to be made.

A supplier does not need to offer a gift, trip, commission, personal benefit or any other advantage to be hired by TroqPay.

When a personal interest may materially influence a decision made on behalf of TroqPay, that potential conflict must be disclosed.

6. What we do not accept

Some behaviors are incompatible with a relationship of trust with TroqPay.

Anyone who receives access to data, systems, credentials, documents, commercial information, APIs, technology environments or other assets related to TroqPay must use them only for authorized purposes and protect them appropriately.

When identifying a flaw, leak, fraud, improper access or other event that may affect TroqPay, its customers or business partners, we expect prompt communication and cooperation to understand and resolve the issue.

Situations related to anti-money laundering, counter-terrorist financing, sanctions, fraud, privacy and security are also subject to TroqPay's specific policies.

• Corruption, bribery or payment of an undue advantage.
• Fraud or deliberate attempt to deceive TroqPay, its customers or business partners.
• Forgery of documents, records or information.
• Misappropriation of money, assets, data or third-party property.
• Hidden personal benefit intended to influence a professional decision.
• Misuse of confidential information.
• Unauthorized access to systems, accounts, code, data or infrastructure.
• Deliberate maintenance of unauthorized access after a relationship ends.
• Deliberate violation of security controls.
• Intentional concealment of relevant incidents.
• Misuse of TroqPay's name, brand or representation.
• Harassment, discrimination, intimidation, humiliation or abusive conduct.
• Inferior professional treatment, disqualification or assignment of roles based on gender, race, ethnicity, nationality, disability, sexual orientation, religion, age or other personal characteristic.
• Retaliation against anyone who raises a concern in good faith.
• Knowingly using TroqPay for unlawful activities.
• Deliberate attempt to bypass compliance, fraud-prevention or risk-management controls.
• Other serious conduct that represents a breach of trust or risk incompatible with continuing the relationship.

7. When something does not seem right

Questions, concerns or possible breaches of this Code may be reported to TroqPay at help@troqpay.com.

The channel may be used by employees, customers, suppliers, business partners or other people with a legitimate concern related to TroqPay's conduct or the conduct of someone acting on its behalf.

Information will be handled responsibly and, when possible, with confidentiality compatible with the need to assess the situation.

A good-faith report does not need to be proven true at the end of the review. What is not acceptable is deliberately using the channel to make false accusations, threaten or harm third parties.

8. How we respond to breaches

There is no single response for every breach of this Code.

Depending on the case, TroqPay may request clarifications or corrections, review commercial conditions, restrict access or operations, suspend relationships, require corrective measures, terminate contracts, end partnerships or take other appropriate measures.

TroqPay is not required to adopt progressive measures before ending a relationship.

Serious situations, especially those involving fraud, corruption, misappropriation, serious discrimination, harassment, unauthorized access, intentional security violation, unlawful activity or relevant breach of trust, may justify immediate measures.

When necessary or required, TroqPay may also cooperate with business partners, competent institutions or authorities.

• The severity of the situation.
• The impact caused or potential impact.
• The existence of intent or bad faith.
• Recurrence.
• Cooperation by the people involved.
• Possibility of correction.
• Legal, financial, regulatory, operational, technology or reputational risks.
• The trust required to continue the relationship.

9. A reciprocal commitment

This Code does not exist only to state what we expect from others. It also represents the standard we seek to apply to our own decisions.

We expect integrity from those who work with us, and we accept being held to the same standard.

We expect commitments to be respected and seek to respect ours.

We expect professional and respectful treatment and assume the same commitment in our relationships.

We expect problems to be communicated and take responsibility for acting when we identify something wrong.

We want to build long-term commercial relationships, but not at any cost.

We believe that growth also means taking responsibility for the world we help build. We do not expect perfection. We are people, and people make mistakes. We expect responsibility to acknowledge our mistakes, empathy to understand others and willingness to do better. We all have rights, duties and impact on the relationships we build. This is how we want TroqPay to grow.

• We grow with integrity.
• We honor our commitments.
• We act when something is wrong.

Related policies

This Code should be interpreted together with the other applicable TroqPay documents and policies, including, when relevant:

• Terms of Use.
• Privacy Policy.
• AML/CFT, Sanctions and Fraud Prevention Policy.
• TroqPay security guidelines and information.
• Contracts and specific conditions applicable to each relationship.