FinTrU Code of Conduct

Message from FinTrU CEO Darragh McCarthy

I am delighted to share with you our updated FinTrU Code of Conduct for 2026.

Our Code is more than a set of rules; it is a reflection of our values, our culture and the standards we hold ourselves to as professionals and as people.

At its core, the Code is designed to guide us in making decisions that are consistent with our commitment to integrity, respect and accountability. It outlines expectations for how we should treat one another, how we engage with our clients and stakeholders, and how we represent our company in the wider community.

The Code is not meant to restrict you, but to empower you. It provides clarity and acts as a moral compass when facing difficult decisions and reinforces the trust that our stakeholders place in us. 

Each of us plays a vital role in upholding these standards, and together we want to ensure that FinTrU remains a place where people are proud to work and do business.

I encourage you to read the Code carefully, reflect on its meaning, and take personal ownership by incorporating its principles into your daily work. 

Thank you for your dedication and for living our values every day. By embracing this Code of Conduct we strengthen FinTrU and the positive impact it makes.

Darragh
CEO and Founder, FinTrU

Contents

• Our Code of Conduct
• Accountability
• The Code and Our Culture
• Living the Code
• Speaking Up
• Empowering Our People
• Protecting Our Organisation
• Delivering for Our Clients
• Supporting Our Communities
• The FinTrU Core Values
• Appendix - Portugal

Our Code of Conduct

FinTrU’s Code of Conduct (“Code”) is designed to help and protect us and sets out the ground rules for everything we do at FinTrU. It is a statement of FinTrU’s commitment to integrity and the highest ethical standards that are expected from all of our employees. It should guide us to make the right decisions when performing our roles.

The Code will be reviewed and updated on an annual basis, or more regularly when necessary changes are required to be made. The Code is distributed to all employees annually and is published both on FinTrU’s internal policy portal accessible to all employees and externally on our company website. Compliance with the Code will be monitored by the Risk & Compliance Manager.

All FinTrU employees, interns, trainees and contractors (collectively referred to as “employees”) in all jurisdictions in which we operate are responsible for understanding and abiding by the Code. Training on key aspects of the Code will be provided to all employees at various intervals.

Whenever an expectation in the Code is unclear, employees should speak with their manager. If employees are uncomfortable speaking with their manager, they can contact Human Resources or the Risk & Compliance Manager for guidance.

Accountability

All employees have a responsibility to maintain the trust of our clients and stakeholders and to comply with all applicable laws and regulations.

We expect all employees at all levels within FinTrU to:

• Act with integrity and be accountable, committing to upholding the Code and making sure that you can answer for your acts or omissions.
• Show respect to everyone, promote equality, diversity and inclusion and communicate in an open and effective way.
• Build trust by making honest, ethical and transparent decisions, seeking advice when things are unclear.
• Understand the risks associated with your role and how to manage them effectively.
• Promptly complete all ethics and compliance training assigned to you.
• Speak up – understand that it is your duty to report any suspected breaches of the Code.

As leaders, we expect all managers and supervisors, irrespective of corporate level, to:

• Lead by example, demonstrating and reinforcing the Code.
• Commit time to nurture your team to fulfil their ambitions and accomplish their goals within the remit of the Code, boosting our high-performing culture.
• Help employees understand how the Code applies to them and actively support employees to ensure adherence.
• Query, challenge, and/or use reporting mechanisms, as appropriate, when you suspect or become aware that colleagues may not be adhering to the Code and/or company policies, regardless of whether they are in your line management.
• Ensure that members of your team have time to complete mandatory ethics and compliance training.
• Foster a work environment where employees feel comfortable speaking up without fear of reprisal.
• Be alert to breaches of the Code and report concerns as soon as possible with appropriate confidentiality.

The Code and Our Culture

The Code and our company culture, which is grounded in our core values of Partnership, Passion, People and Professionalism, guide all our actions.

FinTrU’s Mission statement reinforces the Code and our core values and demonstrates further what we do, how we do it and why we do it. It makes us what we are: 

“Empowering our people to drive industry-disrupting, innovative solutions within financial services, making a positive contribution to global clients and local communities.”

We believe that this mission should be conducted in a unique way for us to look after our colleagues, provide outstanding service for our clients and safeguard our reputation. We call it FinTrU Business in a FinTrU Way.

Our Code illustrates what it means to live this mantra with every decision we make and action we take. We want everyone to enjoy coming to work each day – to have fun, get involved, nurture themselves and others, win together as a team, respect everyone and, of course, be unique. Ultimately, how we do business at FinTrU is built on a foundation of honesty, integrity and respect. The Code outlines how you can meet these key behaviours.

Living the Code

Every employee has a responsibility to read the Code, understand it and put it into action. By adhering to the Code and doing FinTrU Business in a FinTrU Way, together we are:

EMPOWERING OUR PEOPLE
PROTECTING OUR ORGANISATION
DELIVERING FOR OUR CLIENTS
SUPPORTING OUR COMMUNITIES

Decision Making

When we experience a moral dilemma at work, there may be times when the correct course of action is unclear or is challenging to follow.  Sometimes, deciding what is the right thing to do is not an easy task and may test you. 

FinTrU employees make decisions each day, and we must evaluate whether those decisions align with the Code. If the answer to any of these questions is no, then do not proceed:

Questions to ask:

• Is it legal?
• Does it comply with FinTrU’s Code of Conduct and policies?
• Does it align with our obligations to our clients, stakeholders and colleagues?
• Are you comfortable if your decision is made public?
  

Whilst our Code may not provide all the answers to every possible scenario, it should guide decision making. In the absence of a particular policy or procedure, you have a responsibility to use good judgement, comply with the spirit and intent of the Code and seek help from your manager, where appropriate.

Integrity and Ethics

The Code sets out rules and principles which broadly reflect the values and expectations of society. This means acting ethically, with integrity, in a non-discriminatory manner and within the law. It also means treating each other with respect. The Code goes beyond the law and our company policies – it highlights the expectations around your professional integrity and ethical behaviour and acts as a moral compass when faced with difficult situations.

FinTrU is committed to ensuring that all employees, regardless of your role in the Company, act with honesty and integrity, treat clients fairly and exercise sound judgement. Personal accountability and ownership are priorities, and we expect you to hold yourself to the highest standards.

You are an ambassador for FinTrU both inside and outside the workplace. You must refrain from engaging in behaviours that could negatively affect your reputation and/or that of FinTrU, so that your conduct aligns with the principles of this Code. This expectation applies during working hours and in your personal time where your behaviour could impact the reputation of FinTrU. Your conduct should reflect FinTrU’s culture of integrity, dignity and respect, and you should uphold the standards of behaviour that our clients and stakeholders would expect.

Always deal fairly and in good faith with our clients, suppliers, competitors, business partners, regulators and colleagues. Never take advantage of anyone through manipulation, concealment, abuse of privileged or confidential information, misrepresentation of fact or other unfair dealings or practices.

FinTrU’s competitive advantage comes from the services and products we offer, our unique culture and you, our people. Never compromise FinTrU’s reputation by engaging, or appearing to engage, in any form of corruption or unethical and/or corrupt business practices.

FinTrU has a zero-tolerance approach to illegal and unethical business practices and rejects the creation or development of business opportunities, revenue or profit based on, or assisted by, such practices. By operating ethically and within the law, our business benefits through positive impact to our reputation and enhanced confidence from clients and business partners.

Be alert and escalate activities that are designed to hinder or prevent the detection of improper or illegal activity, such as money laundering, tax evasion, fraud or bribery.

When you act with our Code in mind we earn the trust of our clients, stakeholders, colleagues and the public. Trust is more than just a value; it’s the foundation upon which FinTrU was built. By building trust today, we can inspire global trust in tomorrow.

Speaking Up

You are responsible for seeking guidance and asking for help if you become aware of potential misconduct, including violations of the Code. This includes wrongdoing within FinTrU or by an external party linked to FinTrU.  FinTrU is committed to fostering an open, safe and transparent workplace where all staff feel comfortable to approach their line manager or a member of senior management to discuss issues openly and candidly. Allegations of misconduct are investigated and managed in an objective, thorough, consistent and timely manner with the goal of understanding and resolving concerns. Confidentiality will be honoured at every stage.

Reporting Channels

Employees are expected to report concerns to their manager. If they are uncomfortable doing so, they can report through the other channels listed below, depending on the specific circumstances of the case:

• Executive or Managing Director
• HR Business Partner
• Risk & Compliance Manager
• Via our Whistleblowing service

Our Whistleblowing service is provided by our external, independent partner, Safecall. Reports can be made by current employees, ex-employees or third parties such as suppliers or external stakeholders. Reports to Safecall can be made anonymously. They will be fully investigated internally, and a response will be provided to the person reporting. Details of how to make a report are contained in our Whistleblowing Policy.

A genuine, honest and well-founded concern about wrongdoing or misconduct should be reported. Employees who make malicious or unfounded reports may be subject to disciplinary action.

Investigations

We investigate all reports of suspected breaches of our Code or policies thoroughly, promptly and confidentially.  Where required, all parties involved in an investigation will get a fair hearing to explain the circumstances and present their side of the story.

FinTrU employees are expected to fully cooperate in any internal or external investigation that is being conducted or directed by FinTrU. Employees must not withhold or tamper with information, or in any way attempt to influence others participating in the investigation.

If an investigation reveals that a breach of the Code has occurred, then a disciplinary process may begin in accordance with our Disciplinary Policy. The outcome of this process may involve disciplinary sanctions such as, but not limited to:

• a verbal warning
• a written warning
• suspension, or
• termination of employment

The extent of sanctions will depend on the severity of the offence, the offender’s guilt, the background and the circumstances of the violation.  If a breach is of a criminal nature, it may also be reported to relevant law enforcement authorities, which could lead to legal action being instigated.

Commitment to Non-Retaliation

Retaliation will not be tolerated in any way against any employee who reports misconduct or speaks up in good faith about breaches of this Code, company policies or potential non-compliance with the law.

Where possible, FinTrU will keep the information it receives and the identity of those who report violations of our Code confidential. FinTrU strictly prohibits any retaliation or intimidation against anyone who, in good faith, shares a potential or actual violation of our Code or assists with an investigation or inquiry. Similarly, FinTrU does not tolerate any attempt to bully or threaten anyone into not speaking up. These behaviours are a serious breach of our Code and could result in disciplinary action, potentially leading to dismissal.

EMPOWERING OUR PEOPLE

Our people are at the centre of everything we do. FinTrU's success is built upon the strength, professionalism, knowledge and resilience of our employees.

We want our employees to nurture themselves and others, ensuring that they value their differences and are all treated fairly and respectfully.

These behaviours will help to create and build strong partnerships within teams whilst promoting a joyous and inclusive workplace.

Respecting Human Rights

• At FinTrU, we invest heavily in our people as part of their professional careers and continue to support our employees on an ongoing basis. We consider ourselves to have a fundamental social purpose to create high-quality professional employment.
  
• FinTrU respects the rights and dignity of everyone with whom we do business. This begins with our daily interactions with one another and our clients, promoting an environment that welcomes people from different backgrounds and with different experiences.
  
• We seek to work with third parties who share our values and commitment to integrity. In selecting our contractors and suppliers, we undertake due diligence to make sure that they embrace transparent procurement processes, sustainability, fair trade and employment best practice.
• We have direct control and oversight over our recruitment practices and working conditions and comply with all relevant employment and labour laws. We support efforts to prevent human rights abuses including modern slavery and human trafficking and we consider the risks of modern slavery and human trafficking within our workforce and our supplier base to be extremely low.

 Embracing Diversity, Inclusion and Equality

• All employees and applicants for employment are guaranteed the same fair treatment. We recognise the value of different cultures, backgrounds, and perspectives, which we believe contributes to FinTrU's continued success. The Code requires you to embrace our differences and treat each other with dignity, respect and fairness at all times. We acknowledge that when people feel happy, safe and secure at work, they can reach their full potential.
  
• Meritocracy is important at FinTrU. The Company adopts recruitment practices in line with applicable legislation and treat all applicants in a fair and equitable manner. We recruit and promote employees based on individual ability and experience regardless of race, gender, culture, sexual orientation, religion or other protected characteristics. Basing our decisions on merit helps us to attract and retain the best talent we need to deliver exceptional service to our clients.

Promoting a Safe and Healthy Workplace

• We make the safety and wellbeing of everyone who works with us a key priority. Maintaining a safe and healthy workplace is the responsibility of all employees. By doing so, we create an environment where people can thrive.
• To perform at our best every day, all employees must perform their duties unimpaired by illegal drugs, alcohol, or by the improper use of legal substances.
• Acts of violence, threats and physical intimidation will not be tolerated at FinTrU. Such actions can result in immediate disciplinary action, up to and including termination of employment.
  
• FinTrU complies with legal directives on occupational health and safety, equipping our offices with all necessary safety equipment, providing training to our employees, and implementing practices that raise awareness of the importance of observing health and safety regulations.

Fostering a Respectful and Professional Workplace

• All our employees deserve to be treated with respect and dignity in the workplace. Inappropriate behaviour, including discrimination, harassment and bullying, has no place in the FinTrU culture. We want everyone to interact with empathy and understand the perspectives of others, creating a positive and cooperative environment. 
• We expect our managers and leaders to create and maintain a positive working environment where all employees are inspired to excel and are comfortable asking questions and raising concerns.
• We encourage employee participation in off-site events which further FinTrU business objectives and core company values. Whilst we respect employee privacy and personal freedom, you are all ambassadors of FinTrU with individual responsibility for your actions. You should refrain from any act, on or off premises, that threatens the reputation of you, FinTrU or any of its clients.
• It is important to remain objective in your role. Personal relationships with those inside or outside of work can create, or appear to create, a conflict of interest. Whilst we do not wish to interfere unnecessarily, it is required that employees behave in a professional manner, do not abuse positions of power and do not allow close friendships or personal relationships to cause perceived or actual conflicts of interest. 

PROTECTING OUR ORGANISATION

Our long-term success depends greatly on safeguarding and protecting our company and its assets. We do this by ensuring a right-first-time approach, identifying risks, applying appropriate controls in our daily roles, acting with integrity and always abiding by relevant policies and legislation to protect our company from risks.

Protecting Personal Information

• Protecting the confidentiality of employee, supplier and client information is of the utmost importance. You must safeguard and maintain the confidentiality of information and use it only for legitimate business purposes.
• The loss or unauthorised disclosure of confidential information may harm FinTrU and can result in disciplinary action being taken. Incidences of data loss must be reported immediately.

Internal Information Controls

• As a company, we are committed to implementing and maintaining a robust Information Security Management System and hold the ISO27001:2022 security standard. Our aim is to protect the confidentiality, integrity and availability of the data employed within our company.
• FinTrU has strict rules which employees must follow regarding management of computer and printer workstations. This ensures that all sensitive and confidential information, whether it be on paper, a storage device, or a hardware device, is properly locked away or disposed of when a workstation is not in use. This also applies for working at home workstations.
• All employees must follow password management best practices as detailed in our Password Security Policy and must never share passwords with anyone. Where you suspect passwords have been compromised this should be reported immediately.
• FinTrU has robust security controls to ensure that confidential information is not transferred outside of the FinTrU network, including to personal email addresses, or to non-company devices or storage locations. You must immediately report any leakage of confidential information.

Awareness

• Cybercrime has become more organised and sophisticated than ever before, with the increasingly serious threat posed by malicious hackers and cybercriminals of significant concern to our company.
• Phishing remains the number one form of attack due to its high success rate, and fraudsters are using a range of social engineering tactics to manipulate employees into handing over data. It is your responsibility to educate yourself, in addition to the training provided by the company, on information security and follow applicable policies. Stay alert and guard against scams and phishing alerts.

Protecting Our Assets

• The resources we use to conduct company business must be used for legitimate business purposes and should be appropriately safeguarded against cyber-related risk and attack, theft, loss, waste and abuse. You have a responsibility to care for all the assets entrusted to you by FinTrU at all times.
• Any FinTrU equipment provided to you is your responsibility and should primarily be used for business purposes. Where damage to equipment occurs through negligence or carelessness you may be required to reimburse FinTrU of the value of the item.
• You may have access to e-mail, cloud-based applications, computers, server networks and other communication platforms.  You must never use these company systems or devices for activities that are illegal or that violate our policies and values.  Communications on company and client systems should always remain professional. There is no tolerance for bullying, profanity, discrimination or derogatory language. Such occurrences may result in disciplinary action.

Intellectual Property and Proprietary Information

• FinTrU proprietary information and Intellectual Property (IP) are valuable assets and are critical to our business success. We have great ideas and technology, which we all need to protect.
• FinTrU IP includes ideas, processes, trade secrets, technology, software, proprietary know-how, inventions, designs, marketing materials, pricing methods, brands and other creations protected by law.
• We respect the intellectual property rights of others and ensure that our innovations do not infringe on existing patents, copyrights, or trademarks. We also protect our own intellectual property to maintain our competitive edge.
• We make significant investments in the development of IP and will fully enforce our rights should the need occur. All IP provided by our employees (unless otherwise provided by law) during the period of their employment must be disclosed and is the property of FinTrU.
• You must always safeguard proprietary information that you help develop or to which you have access to as part of your role.

Accurate Records and Disclosures

• FinTrU and its employees must follow applicable accounting standards, policies, procedures, internal controls and legal requirements. We will make accurate, timely and clear disclosures to regulatory authorities, clients and the public.
• Employees must never falsify or maintain inaccurate information or data.
• All payments to, and business transactions with, third parties must be accurately recorded.
• Records retention guidelines and legal hold notices must be complied with.
• Employees must ensure that all expenses are submitted accurately through required channels and with proper approval according to policies.

Preventing Bribery and Corruption

FinTrU has strict policies, procedures and controls in place concerning bribery, corruption and related offenses. We do not tolerate bribery or corruption in any form.

You must not:

• offer, promise, give – or authorise others to offer, promise or give – anything of value, either directly or indirectly, to any party in order to gain an unfair or improper business advantage.

• receive, or agree to receive, anything of value that may improperly influence your duties as a FinTrU employee.

Actual or suspected instances of corruption or bribery must be escalated immediately to the Risk & Compliance Manager or reported via our Whistleblowing service. Where appropriate, it may also be necessary to report instances of bribery, corruption and other related offences to the appropriate regulatory and/or law enforcement agencies.

If an employee bribes, attempts to bribe, or receives a bribe intended to obtain or retain an advantage in the conduct of FinTrU business, this will be considered to be an act of gross misconduct. FinTrU’s Gifts & Hospitality Policy and Gifts register supports business transparency and provides a mechanism for recording business-related gifts to deter such unethical and corrupt activities.

Anti-Money Laundering

• FinTrU conducts business through lawful commercial activities and with funds from legitimate sources. Money laundering occurs when the proceeds of crime are hidden in legitimate business dealings, or when legitimate funds are used to support criminal activities.
• All companies are at risk of being exploited in this way and you must be on your guard to help protect our reputation and ensure we comply with the law in this area. You must avoid knowingly assisting in any form of tax evasion, including providing advice on how to avoid tax obligations.
• Be alert and report any unusual activity, as outlined in our Anti-Money Laundering Policy.

Fraud

• Fraud is any intentional act or omission designed to deceive others in a way that is illegal or dishonest, resulting in the victim suffering a loss and/or the perpetrator achieving a gain. This can include theft or the misappropriation of company funds, information or assets. You are responsible for ensuring that any suspicions of fraud you are aware of are reported promptly for investigation, as detailed in our Anti-Fraud Policy.
• Employees engaging in fraudulent activities, who help others to engage in fraud, or elect to ignore while others engage in fraud, will be subject to disciplinary action, including dismissal with just cause. Law enforcement agencies will be engaged where it is suspected that criminality has taken place.

Political Activities

• In the workplace, freedom of expression plays a fundamental role in establishing a healthy and productive environment. This is essential to ensure that employees can freely express their opinions and ideas, promoting diversity of thought. 
• It is also necessary to find a balance between freedom of expression and individual responsibility, to ensure that the working environment is respectful and non-discriminatory. In this sense, FinTrU respects the personal and voluntary right of its employees to participate in political activities in their own free time and with their own resources, outside of the workplace. However, you must make clear that your external political views and actions are your own and are not linked to FinTrU.
  
• Political activities may give rise to a potential conflict of interest. The remit of such activities should be discussed in advance with the Compliance Department.
  
  

Communicating Responsibly

• FinTrU is committed to making sure that communications about our company and its business are accurate and made by employees who are authorised to speak on our behalf. Consistent, accurate and professional communication with the media and others outside our company is important and can have an impact on our business reputation.
• Only officially designated spokespersons may provide comments to the media or other third parties. Employees who are unauthorised to make such statements must refer all enquiries to their manager and the Marketing Manager.
• FinTrU respects your right to engage in social, professional and political dialogue outside of work. You must use good judgement, including on your personal social media accounts, and carefully consider the impact that your use of this media may have on FinTrU and our clients.
  
• Use of social media or messaging platforms by employees to share disparaging or negative comments, or views that could affect the reputation or standing of FinTrU and/or its employees or stakeholders, is not acceptable. This does not reflect the standards or expectations that FinTrU has of its employees and may lead to disciplinary action.
  
• Confidential information about FinTrU business, performance, financial conditions or legal issues must never be discussed on social media, as doing so may damage the company and breach legal or contractual obligations. Also use care in internal communications and be responsible with your comments on the internal FinTrU-approved social media platforms.