PAA CAPITAL – Code of Conduct

Last Updated: 10 November 2025

Our Commitment to Integrity, Professionalism & Responsible Conduct

At PAA CAPITAL GROUP (“PAA CAPITAL,” “we,” “us”), we are committed to conducting our business with integrity, transparency, and respect. This Code of Conduct outlines the ethical foundations that guide our decisions, behaviours, and interactions with clients, partners, regulators, and colleagues across all jurisdictions in which we operate.

This document applies to all employees, directors, contractors, consultants, and service providers acting on behalf of PAA CAPITAL.

1. Professional Integrity

We act with honesty, fairness, and professionalism in every aspect of our work.
All personnel are expected to:

• Exercise sound judgment and act in the best interest of clients and the company

• Avoid conflicts of interest or situations that may appear to compromise impartiality

• Communicate clearly, accurately, and without misleading information

• Uphold the reputation and trust placed in PAA CAPITAL as a licensed and regulated financial services provider

2. Compliance with Laws, Regulations & Internal Policies

As a multinational financial institution, we comply with all applicable laws, including:

• Banking, payments, and financial-services regulations

• AML/CFT and sanctions obligations

• Data protection and privacy laws (incl. EU GDPR and local jurisdictions)

• Tax compliance and cross-border reporting obligations

• Licensing requirements and supervisory expectations

All employees must follow our internal policies, including AML/CTF, KYC, information security, and risk management standards.

3. Respect, Inclusion & Fair Treatment

We are committed to maintaining a professional environment where:

• Every individual is treated with respect and dignity

• Diversity is valued as a driver of innovation and better decision-making

• Harassment, discrimination, bullying, and retaliation are strictly prohibited

• Equal opportunities apply to all employees, regardless of background or identity

A respectful workplace is a shared responsibility.

4. Confidentiality, Privacy & Data Protection

Client trust is essential to our mission.
We protect all confidential information entrusted to us, including:

• Personal data

• Financial information

• Business records

• Access credentials and internal documents

Data must only be accessed or shared on a need-to-know basis and in accordance with our Privacy Policy, Information Security Policy, and regulatory obligations.

5. Zero Tolerance for Fraud, Corruption & Unethical Behaviour

We maintain strict standards against misconduct, including:

• Fraud, bribery, or corruption

• Money laundering or sanctions evasion

• Market abuse, insider dealing, or misuse of confidential information

• Facilitating criminal activities or illicit transactions

• Manipulating records, data, or reports

Any suspicion of unethical or illegal behaviour must be reported immediately using approved reporting channels.

6. Responsible Use of Company Assets & Technology

Employees must use PAA CAPITAL systems, devices, and resources responsibly.
This includes:

• Protecting passwords and access credentials

• Following cybersecurity protocols

• Avoiding unauthorized software or tools

• Ensuring that company devices are used for lawful and approved purposes

Cybersecurity is a shared responsibility.

7. Accountability & Transparency

Each team member is personally responsible for:

• Their actions and decisions

• Following company policies

• Raising concerns when something appears irregular, unsafe, or unethical

• Cooperating fully with regulatory or internal investigations

We operate transparently and expect the same from everyone representing PAA CAPITAL.

8. Reporting Concerns (Whistleblowing)

PAA CAPITAL maintains a secure, confidential, encrypted reporting mechanism to allow good-faith reporting of:

• Compliance concerns

• Fraud or misconduct

• Regulatory breaches

• Data-protection or security incidents

• Harassment or unethical behaviour

Employees, clients, and partners may report anonymously without fear of retaliation.
For details, see our Whistleblower Policy.

9. Enforcement & Consequences

Violations of this Code may result in:

• Disciplinary action

• Suspension or termination of employment or business relationships

• Regulatory reporting

• Civil or criminal penalties

We take all breaches seriously and act accordingly.

10. Continuous Improvement

The Code of Conduct evolves with our business and regulatory requirements.
We periodically review and update this document to ensure alignment with:

• International best practices

• Regulatory expectations

• Emerging risks and technological changes

Feedback from employees and clients is welcomed.