Code of Conduct & Ethics

Our Commitment to Integrity

At Unicorn Currencies, integrity is the foundation of everything we do. Our Code of Conduct & Ethics sets the standard for how we conduct business, interact with clients, and uphold our responsibilities as a trusted financial services provider.

Core Principles

Integrity and Honesty

We conduct all business activities with honesty, transparency, and fairness. We never compromise our ethical standards for commercial gain, and we expect every member of our team—along with our partners and representatives—to act with unwavering integrity.

Anti-Bribery and Corruption

We have zero tolerance for bribery and corruption in any form. In accordance with the UK Bribery Act 2010 and Canada's Corruption of Foreign Public Officials Act (CFPOA), we strictly prohibit:

• Offering, giving, requesting, or accepting bribes, kickbacks, or improper payments
• Making facilitation payments to expedite government actions
• Providing gifts, hospitality, or entertainment that could improperly influence business decisions
• Political contributions intended to secure business advantages

Our comprehensive Anti-Bribery and Corruption Policy provides detailed guidance: www.unicorncurrencies.com/abc-policy

Conflict of Interest Management

We identify, disclose, and manage conflicts of interest to ensure client interests always come first. Our employees and partners must: promptly disclose any actual or potential conflicts of interest; avoid situations where personal interests could compromise professional judgment; refrain from engaging in activities that compete with or undermine Unicorn's business; never misuse confidential information for personal gain.

Zero Tolerance for Financial Crime

We are committed to preventing and detecting financial crime, including: money laundering and terrorist financing; fraud and misrepresentation; market abuse and manipulation; sanctions violations; tax evasion. We implement rigorous KYC procedures, transaction monitoring, and suspicious activity reporting in compliance with FINTRAC (Canada) and FCA partner requirements (UK). Any involvement in financial crime will result in immediate termination and referral to law enforcement.

Regulatory Compliance

We comply with all applicable laws and regulations in every jurisdiction where we operate, including financial services regulations (FINTRAC, FCA), data protection and privacy laws (UK GDPR, PIPEDA), AML/CTF requirements, consumer protection standards, and employment and human rights legislation.

Respect and Fair Treatment

We treat all clients, colleagues, partners, and stakeholders with dignity and respect. We do not tolerate discrimination, harassment, or bullying of any kind. We are committed to creating an inclusive workplace and providing equitable access to our services.

Confidentiality and Data Protection

We protect the confidentiality of client information and personal data in accordance with our Privacy Policy. We use client data only for legitimate business purposes and implement robust security measures to prevent unauthorized access or disclosure.

Accountability

Every employee, officer, director, and third-party representative of Unicorn Currencies is required to:

• Read, understand, and comply with our Code of Conduct & Ethics
• Complete mandatory ethics and compliance training
• Report any suspected violations or concerns without fear of retaliation
• Cooperate fully with internal investigations

Violations of this Code may result in disciplinary action up to and including termination of employment or contract, as well as potential legal action.

Speaking Up

If you become aware of conduct that may violate this Code, our policies, or applicable laws, you have a responsibility to report it. We provide multiple reporting channels including our confidential Whistleblower Policy and anonymous ethics hotline.

Key Questions