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LATOKEN Code of Business Conduct and Ethics


The LATOKEN Code of Ethics and
the Principles
⁠
embody the firm’s commitment to benefit the society by adopting the decentralised technology to make investments, trading, payments and money management as a whole available worldwide at a fraction of costs. Access to investments makes people global stakeholders learning how the world works and empowers them to influence the future. Access to money makes people freer to choose how to grow by buying products and services.
Our mission is to put financial life at fingertips.
So people can use money to bring ideas into life and become stakeholders of a better future.

Why do we need the Code

The Code sets the basic and powerful rules such as prevention of conflicts of interests. The Code is the fundament for more sophisticated principles and the culture needed for exceptional performance to achieve the core mission. The Code empowers the team to make the right choices and to overcome hurdles and “impossible” things and ensures they are done with joy and courage. This firm’s commitment implies a combination of vision coupled with hard work and ethics leading to extreme performance needed to make a structural change in the way people fundraise, invest and manage money.
The capital market manages the planetary resources and mankind's future. The structural changes here mean intensive conflicts between those who benefit from the change and those who lose. It is the matter of our viability to build the team which is capable of overcoming such conflicts, to structure the support base, and to minimize costs for those who lose (Uber transformed taxi business and had scandals and scrutiny across the world..). Furthermore, we shall be prepared for hurdles coming from the regional political risks, devastated local capital market expertise and the short-sighted rent-seeking cultural patterns dominating the local labour market.
Additional layers of cultural complexity come from the infant stage of the decentralised industry lacking regulations and practices needed to evolve to meet modern ethical standards and regulation. We acknowledge that some of the industry business practices can not be avoided by the industry players as such avoidance significantly impairs their market position. In this way, collective behavioural change is required and could be achieved with the help of regulation. We are committed to develop the industry rules and practices and call for regulation where necessary. We are committed to meet the highest ethical standards and be in compliance with all applicable laws, rules and regulations.
The Code applies to all of our teammates.

Reporting Issues under the Code

It is critical that you strive to identify and escalate potential issues before they lead to problems. When in doubt, you should ask questions about the potential application of this Code to your supervisor or senior management and the CEO.
Should you become aware of any existing or potential violation of this Code, promptly notify senior management or the CEO of the firm.

Violations of the Code

We take this Code and your obligations under it very seriously and will take any disciplinary or preventive action deemed appropriate to address existing or potential violations of the Code, up to and including termination of contract, stock bonuses/options or legal actions. Violations of the Code may also constitute violations of law, which may result in criminal or civil penalties for you and the firm.

Put interests of the firm and its clients ahead of personal interests

Put interests of the firm and clients ahead of personal goals - that is a fundamental cooperation basis to build trust, stellar performance and great product, and, as a result, sustainable growth of your character and career. We do not tolerate short-sighted sighted strategies designed to look better or avoid responsibility or to protect the comfortable status quo at the expense of the company performance and clients. You must detect and prevent behavioral patterns such as: faking work and results, hiding mistakes or weaknesses to look better, defending yourself to avoid responsibility and effort, sabotaging those who come to fix something which you failed to do, involving others into negative back talk against peers, supervisor or the firm.
Your leadership role is to inspire teammates and to align them with our common goal, with our mission. You do it by showing your commitment, hardworking and goal-oriented spirit. You set the bar and raise it constantly for yourself and teammates. The dedication of our teammates to the firm and clients, the intense effort they do is greater than one finds in most other organizations.

Prevent talking behind one’s back, impose constructive problem solving

You must immediately stop negative back talking when you witness such behavior and request to invite the named colleague to participate in the discussion. An exemption is the discussion involving a supervisor of the person. Discussions of colleagues’ mistakes and their personalities in their absence allows a person to take an unfair advantage over such colleagues and get short term benefits while causing extensive damage to the morale and career of teammates and performance of the firm. The same applies to any propagation of negative information or talk against the company in the absence of the CEO.

Personal Conflicts of Interest

A personal conflict of interest occurs when your private interest improperly interferes with the interests of the firm. Actions or relationships that create personal conflicts of interest are prohibited, unless approved by the firm in written form. It is important that you carefully consider whether any of your activities or relationships, including volunteer positions outside the firm, could cause a conflict (or the appearance of a conflict) with the interests of the firm. Even if an activity seems unrelated to your role at the firm, you may be required to obtain pre-approval before engaging in it. Additionally, personal gain and advantage must never take precedence over your obligations to the firm. You must never use or attempt to use your position at the firm to obtain any improper personal benefit for yourself, family member(s) or any other individual or group. If you are aware of a transaction or relationship that could give rise to a conflict of interest or perceived conflict of interest, you should discuss the matter promptly with the CEO. When in doubt, raise the question for appropriate consideration.

Business Opportunities

You are prohibited from taking for yourself (or directing to any other person) a business opportunity that is discovered through the use of corporate property, information or position at the firm, unless the firm explicitly in written form approves such use of the opportunity. More generally, you are prohibited from using corporate property, information or position for personal gain or competing with the firm. The prudent course of action is to obtain pre-approval from the CEO for any use of firm property or services that is not solely for the benefit of the firm.

Non Solicitation

Any solicitation to work outside of the firm mission must be prevented and reported. Such solicitations include discussions of job market opportunities, personal startup ideas, introductions to head hunters or any person for a hiring reason.

Compliance with Laws, Rules and Regulations

You must comply with all applicable laws, rules and regulations, including those related to insider trading, financial reporting, money laundering, fraud, bribery and corruption.
Generally, if you are aware of material nonpublic information relating to the firm, any of our clients or any other private or governmental issuer of securities, you cannot buy or sell any securities of those issuers or recommend that another person buy, sell or hold the securities of those issuers. Questions regarding the purchase or sale of any firm securities or any securities of issuers that you are familiar with by virtue of your role at LATOKEN should be directed to an appropriate ethics contact prior to any purchase or sale.

Protecting Confidential Information

In the course of business, our people often have access to confidential or proprietary information about the firm, our clients, prospective clients or other third parties. Our business and reputation depend on the commitment of each of you to protect this information. You must maintain the confidentiality of the information with which you are entrusted, including complying with information barrier procedures applicable to your business. The only exception is when disclosure is authorized or legally mandated. Confidential or proprietary information includes, among other things, any non-public information concerning the firm (including its businesses, financial performance, results or prospects) and any non-public information provided by a third party with the expectation that the information will be kept confidential and used solely for the business purpose for which it was conveyed.

Equal Employment Opportunities and Commitment to Diversity

Concern for the personal dignity of each individual is an indispensable element of the standards we set for ourselves at LATOKEN. We focus our personnel decisions on merit and contribution to the firm’s success. The firm affords equal employment opportunities to all qualified persons without regard to any impermissible criteria or circumstances. We do not tolerate any type of discrimination prohibited by law, including harassment. We value diversity as an important asset that enhances our culture, helps us serve clients well and maximizes return for shareholders. For us to excel, we must create for our people an inclusive environment that welcomes and supports differences and encourages input from all perspectives.

Protecting and Properly Using Firm Assets

You should protect the firm’s assets and ensure their efficient use. All firm assets should be used for legitimate business purposes only.

Business Principles

We stress creativity and imagination in everything we do. While recognizing that the old way may still be the best way, we constantly strive to find a better solution to the client’s problems. We pride ourselves on pioneered many of the practices and techniques that will become standard in the industry. We make an unusual effort to identify and recruit the very best person for every job. In a service business, we know that without the best people, we cannot be the best firm. We offer our people the opportunity to move ahead more rapidly than is possible at most other places. Advancement depends on merit and we have yet to find the limits to the responsibility our best people are able to assume. For us to be successful, our men and women must reflect the diversity of the communities and cultures in which we operate. That means we must attract, retain and motivate people from many backgrounds and perspectives. Being diverse is not optional; it is what we must be.
We stress teamwork in everything we do. While individual creativity is always encouraged, we have found that team effort often produces the best results. We have no room for those who put their personal interests ahead of the interests of the firm and its clients. The dedication of our people to the firm and the intense effort they give to their jobs are greater than one finds in most other organizations. We think that this is an important part of our success. We consider our size an asset that we try hard to preserve. We want to be big enough to undertake the largest project that any of our clients could contemplate, yet small enough to maintain the loyalty, the intimacy and the esprit de corps that we all treasure and that contribute greatly to our success. We constantly strive to anticipate the rapidly changing needs of our clients and to develop new services to meet those needs. We know that the world of finance will not stand still and that complacency can lead to extinction.

Additional Procedures

All of our employees are required to affirm that they have reviewed the Code and will comply with it. Our clients’ interests always come first. If we serve our clients well, our own success will follow. Our assets are our people, capital and reputation. If any of these is ever diminished, the last is the most difficult to restore. Despite the infant industry development stage, regulation and common business practices, we are dedicated and we will do all we can to comply with the letter and spirit of the laws, rules and ethical principles that govern us. Significant employee stock ownership aligns the interests of our employees and our shareholders. We take great pride in the professional quality of our work. We have an uncompromising determination to achieve excellence in everything we undertake. Though we may be involved in a wide variety and heavy volume of activity, we would, if it came to a choice, rather be best than biggest.

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