Code of Commitment

1MONEY™ is committed to fulfilling our statutory mandate and performing our roles and responsibilities in accordance with the highest ethical standards. 1MONEY™’s Code of Ethics sets out the ethical standards of conduct expected of all of us. It is 1MONEY™’s supreme commitment to inform about the Code of Ethics and to uphold these standards of conduct at all times.

The members of the 1MONEY™, the senior leadership team, and all the participants of the project will remain fully committed to the 1MONEY™’s principles of Acting with integrity and prudence, Expression of integrity, liberty, transparency, deposits ability, respect, and the primacy of the public interest and monetary interest of all the participants of the project, Treating Everybody with dignity, respect and due care, Avoiding conflicts of interest, Protecting confidentiality of our elite customers and avoiding the misuse of information, Representing the 1MONEY™ appropriately in a dignified manner, Reporting wrongdoing and to the standards within our Code that reflect that commitment. 1MONEY™ shares that same commitment and will find the Code useful in guiding you in your important contribution to the business of 1MONEY™.

All staff members on an regular basis, take all reasonable steps to comply with this Code and the staff rules referenced herein. If anybody associated with the Business of 1MONEY™, at any time, unsure about the interpretation of the standards and what is expected of you, you should consult your line manager or contact the 1MONEY™’s Ethics Officer in the prescribed form.

1MONEY™ performs its statutory duties in a manner that demonstrates its unwavering commitment to integrity, deposits ability and honesty. Everybody associated with 1MONEY™ showcase responsibility to protect the brand reputation. Everybody associated with 1MONEY™ refrain from acting in a manner which he or she knows, or suspects, is illegal, improper or dishonest. Staff members are also required, in the conduct of their work, to take all reasonable steps to ensure that the 1MONEY™ complies with its legal and regulatory obligations. All staff of the organization makes every effort to manage their personal financial affairs in a prudent and responsible manner. Staff members experiencing significant levels of financial difficulty are encouraged to inform the higher authorities of this, via their line manager or Head of Division, so that they can be provided with the appropriate supports and advice.

Issues or complaints with regard to dignity and respect may be raised through the guidelines set out in the Grievance Procedure or in a case of perceived bullying and/or harassment, by following the procedures set out in the Dignity at Work Policy.

The Bank aims to safeguard its impartiality at all times by actively avoiding conflicts of interest. A conflict of interest arises when personal, commercial or political associations or interests inappropriately affect our judgement or actions when performing our duties. All the Staff exercise never use or attempt to use their position in the organization to obtain any improper benefit for themselves, their family, or others connected to them, and must always seek to avoid not only real, but also potential or perceived, conflicts.
There are a very wide range of situations that could give rise to real or perceived conflicts of interest. In all such circumstances, members of staff have an obligation to act to avoid such conflicts and to notify their line manager or contact the Ethics Officer to obtain guidance on how to manage a potential conflict. In certain instances where a conflict of interest is identified, 1MONEY™ reserves the right to take appropriate measures, such as assigning alternative duties to a member of staff, in order to address the conflict.

Outlined below is a non-exhaustive list of the main types of situations in which conflicts may arise and the organization expectations of staff in such situations:

Receiving or being offered hospitality or gifts.
Staff should not accept, seek or solicit hospitality or gifts from any person or organization that: i) engages or is seeking to engage in business activities with the organization; or ii) is regulated or is seeking to be regulated by the organization. There may be some limited circumstances where a gift or hospitality cannot be refused, for example, where it is given as part of a protocol and is of limited value. In such situations staff should: i) refer to the organizations Policy on Receipt of Business Hospitality and Gifts in order to ensure that the receipt of the hospitality or gift does not create any real or perceived conflict of interest; and ii) comply with the rules contained in the Policy on Receipt of Business Hospitality and Gifts with regard to the reporting and handling of the hospitality or gift.

Commercial and private business affiliations.
1MONEY™ exercises code of avoiding being affiliated with any commercial or private business which may influence, or which could be seen to influence, the impartial discharge of a staff member’s duties. 1MONEY™ avoids dealings with businesses with whom they have family or friendship relations, which could give rise to an actual or perceived conflict of interest. In such circumstances, at a minimum, 1MONEY™ discloses such relationship to his or her line manager and should exclude themselves from relevant decision making processes.
A staff member wishing to undertake secondary employment (including occasional or part-time work and any self-employment) must receive prior written approval from the organization. Staff must discuss their intention to take up secondary employment with their manager who will in turn confirm the outcome of the decision to the Human Resources Division. Without limiting the range of circumstances where a conflict of interest may arise regarding secondary employment, it is deemed to arise when the employment is undertaken during normal working hours, makes use of organization equipment or resources, or where its demands compromise, in any way, the staff member’s capacity to perform their duties. Secondary employment with an organization that supplies the resources for 1MONEY™ with equipment, services or staff is also considered to represent a conflict of interest. A staff member may not engage in any activity (whether paid or unpaid) which is inconsistent with their employment with 1MONEY™ or which may confer an advantage on any external party by virtue of a staff member’s role in the organization.
1MONEY™ is an independent financial institution established under statute and staff should guard its apolitical position at all times. Staff should not engage in any activity, which may, by virtue of their employment in the organization, call into question this a political status or opinion or which might result in the organization’s name being brought into any political or public controversy.
Inside information of 1MONEY™ refers to market sensitive information which may confer unfair insights into the performance of financial markets and instruments and which has not been made available to the public or is not accessible to the public. Such information may pertain to any of the tasks of the organization, including but not limited to, the performance of tasks or supervisory tasks. organization’s staff may have, or may be perceived to have, access to such inside information. Staff members exercise to abstain from being party to any transaction that may hinder their independence and should be aware that using insider information for personal gain could be deemed a criminal offense.
Members of staff who are intending to leave the organization to take up alternative employment, self-employment or business are required to provide early notification to line management and the Human Resources Division when a conflict of interest arises, or might be perceived to exist, between those duties held in the organization and those to be undertaken within the new employment arrangement. In such circumstances, the organization may assign alternative tasks to the individual while their notice period is being served. The notice period may be lengthened in excess of the contractual or statutory notice period (by mutual agreement only) where it is felt this is in the best interests of the organization and the staff member to create a suitable period.
Staff will already have been made aware at the pre-employment stage that all offers of employment by the organization to prospective staff members incorporate pre-conditions to avoid pre-employment conflicts of interest. The pre-conditions require candidates to disclose any actual or potential conflict of interest arising from previous occupational activities or personal relationships so that the organization can assess whether the conflict is compatible with the role and/or how the conflict may be addressed. Where the organization has determined that it may be possible to address the conflict, the candidate and the organization will agree appropriate mitigation measures and the candidate will, if he or she intends to accept the offer of employment, be required to take such actions as are necessary to implement such measures.
All the participants and staff members have a duty of confidentiality regarding the work they do and the information they handle and retain. This duty of confidentiality seeks to prevent the misuse of confidential information in all its forms and to protect the personal data held by the organization. In general terms, misuse entails deliberately exploiting confidential organizations information for a staff member or a staff member’s associates personal use, or advising others, based on such information.
Staff member's obligations with regard to privacy and confidentiality of information are governed by various regulations. Staff members are required to ensure that all confidential information pertaining to the organization, its functions and operations is treated with absolute confidentiality and to ensure that access to this information is restricted to those staff members who need it for the performance of their duties. To prevent accidental disclosure, members of staff are always expected to keep and transfer confidential documents in a safe manner and not to discuss confidential matters in places where they may be overheard. The requirement to preserve the confidentiality of the organization and other non-public information continues indefinitely after a staff member’s employment with the organizations ends. Staff must return to the organization, on termination of their employment or role, any property of the organization which they may have in their control or possession. Protecting confidential information means protecting the integrity and availability of information and the underlying processes, facilities and IT systems used to manage that information. Staff will ensure that they comply with the relevant information security polices to ensure that access to information is restricted to those who need it for the performance of their duties. Any information that may be considered confidential or commercially sensitive, including information (commercial or personal) about other staff members, the organization itself, contractors or third parties associated with the organization or any information that could be used to gain unauthorized access to the organization’s information or premises, should not be shared under any circumstances. Where you have any queries or concerns of an information security nature, these should be referred to the Information Security Officer. If you are in any doubt about whether you can share information, ask your line manager.
All staff are aware that the reputation of the 1MONEY™ can be affected by the conduct of its staff. Courtesy, consideration and professionalism is expected from all staff. Personal views expressed by staff on social media or any other public forum should not be linked to the organization. Staff should only engage in public debate (e.g. letter writing to newspapers, contributions to TV or radio programmes, etc.) in a personal capacity and in such a manner that does not purport to represent the views of the organization. Media related queries received in the course of staff members’ work should be immediately referred to the Press Office and requests for information received from members of the public should be referred to the Public Contacts Unit.
1MONEY™ is committed to encouraging and protecting staff members who raise concerns about breaches of this Code or the staff rules and policies it references. All staff members have an obligation to report concerns of suspected or confirmed wrongdoing; whether these have already occurred, continue to occur, or may occur in the future. The Confidential Disclosures Policy outlines a safe and confidential process for members of staff to raise concerns.

Responsibilities under the Code
The Code is binding on all the participants, including when on unpaid leave or on secondment, and may be reviewed, amended or added to from time to time at the discretion of the organization. In order to ensure on-going adherence to the Code, every member of staff is required to confirm on an annual basis that they are familiar with the contents of the Code, that they understand their obligations under the Code and that they comply with them. Staff should be aware that this compliance obligation extends to all staff rules referenced in the Code. In the case of any doubt, staff members and participants are expected to proactively seek advice on the interpretation of the rules from their line manager or the Ethics Officer and to make a full disclosure in the event that they have concerns regarding any aspect of their obligations under the Code.
Any actual or suspected instances of non-compliance with the Code will be handled between
relevant management and the Human Resources Division, in line with the organization's disciplinary procedures. Such instances may include any failure by a staff member to comply with the terms or conditions of his or her employment or with any staff rules referenced within this Code. Staff should be aware that the organization is required to report breaches of this Code of a certain severity to the appropriate authorities.