Code of Conduct
UnitedCrowd’s Code of Conduct
AIMS OF THE CODE OF CONDUCT
The very foundation for the business of UnitedCrowd is trust. The trust of our clients, business partners, shareholders and investors as well as the trust of our team members. This Code of Conduct aims to preserve and strengthen the trust placed in us. The purpose of the Code of Conduct is to guarantee the high level of professionalism and integrity of our corporate activity.
All team members and corporate bodies of UnitedCrowd must be oriented towards each and every standard determined by this Code of Conduct. The Code of Conduct should provide an environment where all members of UnitedCrowd refrain from illegal and doubtful actions, but also be more sensitised to ethically and morally questionable business practice.
The basic attitude of UnitedCrowd, which already is in instructions, internal guidelines and manuals, reflects in the following values and principles.
We are committed to democracy, tolerance and equal opportunity across all boundaries.
BEHAVOUR ACCORDING TO LEGAL REQUIREMENTS AND ETHICAL PRINCIPLES
It goes without saying that we comply with the laws and official regulations applicable in the jurisdictions in which we do our business. Our team members are instructed to act legally correct, and in a honest and ethical manner.
CORRUPTION AND BRIBERY
The international efforts to combat corruption and bribery are being fully supported by UnitedCrowd. For both our business partners and team members we resolutely counter any attempt of bribery and corruption in all countries. All our operations have to be conducted in a legal, proper and efficient manner. UnitedCrowd team members do not offer or accept bribes.
MONEY LAUNDERING AND TERRORIST FINANCING
The goal of combating money laundering and terrorist financing is being supported by UnitedCrowd. We expect a critical analysis of the underlying transactions of our engagement from our team members. Any suspicion of money laundering shall be documented and reported. We demand, of course, the same of our business partners.
Our compliance standards shall ensure operations affected by honesty, fairness and trust in our team members, business partners and the UnitedCrowd as a whole and shall minimise risks. Any violation of the internal policy, laws or official regulations by our team members will result in disciplinary action and possibly consequences under
the employment law. Therefore, it is recommended to contact the Compliance Officer in the course of every project or plan and in the case of uncertainty or general questions bout the issue.
CONFLICTS OF INTEREST
UnitedCrowd takes all necessary measures to avoid any conflict of interest between clients and the UnitedCrowd, clients and individual team members or organisational members and between departments as far as possible. If conflicts of interests should still arise, all necessary measures are taken to solve them. Our leaders are expected to serve as positive role model. All investments generated by our platform are being kept separately from cash flow from operating activities.
INCORRUPTIBILITY AND INDEPENDENCE
Business decisions must be made independently. This means they must only be based on economical, legal and ethical aspects.
Loans and shares of family members or relatives of dependents of the UnitedCrowd are handled, in principle, by non-family team members if such case should ever occur. Transactions for befriended clients are being conducted neutrally and handed to another colleague or division if necessary. We always ensure, that the degree of a reasonable wage for services is not exceeded by participants and agents.
Internal knowledge must not be used for personal advantage or the advantage of a third party. As well sharing of internal knowledge is prohibited.
GIFTS AND BENEFITS
If the acceptance of gifts or other benefits affects the interests of UnitedCrowd in a negative way or affects the independence of team members it is generally forbidden. This also applies if they may merely create the appearance of a threat.
The acceptance of gifts and benefits shall be permitted under the following preconditions: The value of the gift lies under the benchmark of 40 Euro. In case of doubt it is recommended to consult the Compliance Officer. Should it be impossible in view of the business relationship to refuse a gift with a value over 40 EURO, we recommend a donation to a charitable organisation.
Invitations to business lunches or dinners may generally be accepted. This does not
apply to events of primary entertaining character, such as concerts, theatre, sports or evening events but also seminars and conferences. In this case it must in principle be examined by the team member if the attendance adheres to standard business practices.This usually means that the host is present, this kind of invitation does not occur frequently and neither travel expenses nor accommodation costs are paid by the business partner. The superior has to be informed in any case.
Gifts and benefits received by team members may be subject to personal
income taxation. Care therefore needs to be taken to ensure that gifts and benefits are always compatible with tax legislation and rules of the financial administration. To avoid personal income tax, it may be advisable to immediately pass such gifts on to charity organizations to avoid a tax liability.
The labour of the team members is dedicated to UnitedCrowd. Therefore, every secondary employment without knowledge and consent of the superior/ supervisory board is prohibited. This includes professional services and the activity as dealers
Donations of UnitedCrowd must be legal. There shall be no donations granted to political organizations, parties or individual politicians and organizations.
All business information regarding the UnitedCrowd or its clients shall remain strictly confidential. Utmost care is taken for handling and storage of such data.
This includes the protection of sensitive business data. All information must only be used for its intended business purpose and not for any other purpose.
To the extent permitted by law, as well as official and internal regulations a straightforward cooperation and an open exchange of information takes place. To ensure that information intended for publicity or press are always transparent and conclusive, a special responsibility falls to the members of UnitedCrowd to comply with the communication guidelines as amended and with the legal provisions related to misleading or false information.
Our Terms and Conditions as well as contracts must be drafted comprehensively for companies, interested parties and clients. They explain exactly the investment process and money transfer, clarify our rights and obligations, elucidate our duty of diligence at the examination by us and state clearly which fees have to be paid at which point of time.
The respective laws and regulation apply to our distribution and marketing activities. Our communication is always fair, comprehensive, transparent and in no way misleading. In order to treat our costumers fairly, a balanced presentation of risks and potential returns takes place.
DATA SECURITY AND DATA PROTECTION
The business success of our company and the effectivity of our business activity essentially depends on access to the internet, worldwide electronical exchange of information and dialogue as well as the electronical execution of our operations.
The advantages of electronic communication have to be balanced against the risks of electronic data coming to data security and the protection of personality. Effective foresight with regard to these risks is an important component of IT management, the leadership function, and self-reliable team members.
The collection, processing and utilisation of personal data, is only permitted if clearly and legally required by company agreements. To protect confidential data against unauthorized access and with regard to data quality a high standard must be maintained. The utilization of data always has to be transparent for those concerned and the rights of the latter must be safeguarded with regards to information and correction and, if applicable, to objection, blocking, and deletion.
RESPECT AMONG TEAM MEMBERS AND TOWARDS THIRD PARTIES
Irrespective of their sex, racial or ethnic origin, religion or belief, disability, age or sexual orientation all people are respected by UnitedCrowd. We respect their dignity, their rights and their privacy.
We want to know and understand the ideas and concern of others. Even though we are in a competitive environment, it is our objective to act as a fair partner. We treat external business partners fair, respectfully and for the benefit of our interest groups.
HAMBURG DECLARATION ON TECHNOLOGY
UnitedCrowd fully complies with the Hamburg Declaration of Technology and demand the same from its partners and team members. This includes:
Total rejection of the work with the technology of L. Ron Hubbard. That neither the team members of UnitedCrowd, nor UnitedCrowd itself are trained according to the technology of L. Ron Hubbard and do not attend courses or seminars based on the technology of L. Ron Hubbard. We reject the technology of L. Ron Hubbards for management of our company and do not attend courses or seminars. In addition, we do not knowingly support companies and/or groups that are being managed according to or influenced by L. Ron Hubbard’s technology.
The contractual partner undertakes to ensure that all persons employed by him for the execution of the contract do not use, teach or disseminate technology according to L. Ron Hubbard in any other way. In case of any violation UnitedCrowd is entitled to dismiss the contract-relationship for important reason without observance of a period. Other rights remain unaffected.
UnitedCrowd and its management is committed to a sustainable corporate development, environmental policy and to report the sustainability strategy within the company. The environmental statement serves as a guideline for environmental protection for the company. For instance, UnitedCrowd works continuously to enable almost paperless operations and is always searching for EDV-solutions which bring this goal closer.
Our team members are an important contributing factor to the success of our company. Qualified and motivated team members are a critical factor in making a crucial contribution to our economic efficiency. The responsibility levied to our team members is always taken with the greatest possible level of professionalism and integrity. This means showing respect for the right of other as well as prevent harm for UnitedCrowd.
Any behavior that has a negative effect on the company with regard to its customers, team members or publicity must be avoided since the team members’ behavior does always represent UnitedCrowd itself. This code of conduct is the basis for us to always solve conflicts in a way, that all persons involved are respected and their individual interests and needs are taken into consideration to the highest extend possible.
COMMENTS AND COMPLAINTS
It is open to every team member to make official complaints to his superior, the Compliance Officer or the executive board, or to indicate circumstances which point to a violation of this Code of Conduct.
Every team member and each member of the organisation does independently bear the responsibility for the compliance with this Code of Conduct. The compliance with this rule is supported by UnitedCrowd with internal institutions and guidelines. This especially includes the introduction auf a Compliance Officer. Mangers are obliged to sensitize their subordinates.