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PAA CAPITAL – Code of Ethics

Last Updated: 10 November 2025

Ethics Are the Foundation of Trusted Financial Stewardship

At PAA CAPITAL GROUP (“PAA CAPITAL”), ethics are at the heart of how we operate.
This Code of Ethics sets out the moral and professional principles that guide our decisions, shape our culture, and underpin our obligations to clients, partners, regulators, and society.

Our commitment is simple: we do what is right, not only what is required.

This Code applies to all employees, officers, directors, contractors, and representatives of PAA CAPITAL across all jurisdictions.

1. Client-Centric Responsibility

Our clients place significant trust in us. We honour that trust by:

  • Acting with loyalty, honesty, and due care

  • Avoiding practices that may mislead or disadvantage clients

  • Providing transparent, fair, and responsible financial services

  • Prioritizing clients’ interests above short-term commercial gain

We measure success not only by outcomes, but by how ethically those outcomes are achieved.

2. Integrity Without Exception

Integrity is non-negotiable. It guides our behaviour even when no one is watching.

We commit to:

  • Acting truthfully and consistently

  • Avoiding deceptive or manipulative conduct

  • Upholding ethical standards in every business decision

  • Setting an example for responsible behaviour within the financial sector

Integrity is the cornerstone of our license to operate.

3. Responsible Innovation

As a regulated VASP, payment provider, and emerging global fintech, innovation is central to our mission.
We embrace new technologies—blockchain, digital assets, AI, and advanced payments—responsibly.

We ensure that innovation:

  • Aligns with legal and ethical expectations

  • Protects clients, markets, and financial stability

  • Considers long-term societal impact

  • Advances transparency, efficiency, and financial inclusion

Innovation must serve people, not the other way around.

4. Ethical Risk Management

Strong ethics and strong risk management are inseparable.

PAA CAPITAL commits to:

  • Identifying and mitigating risks that may harm clients, communities, or financial systems

  • Rejecting excessive or reckless risk-taking

  • Ensuring decisions are balanced, informed, and evidence-based

  • Embedding ethics into AML/CFT, compliance, cybersecurity, and operational frameworks

Ethical choices safeguard our clients and our future.

5. Environmental Stewardship

Finance and sustainability are no longer separate. PAA CAPITAL recognises our responsibility to support the planet.

We commit to:

  • Reducing our operational carbon footprint

  • Supporting reforestation and environmental restoration initiatives

  • Developing blockchain-enabled carbon credit solutions via Afriverde and related ventures

  • Promoting climate-resilient finance and sustainable investment principles

Ethical finance includes caring for the world we leave behind.

6. Social Responsibility & Inclusion

We believe financial institutions must contribute positively to society.

We support:

  • Economic inclusion for underbanked communities

  • Fair access to financial infrastructure

  • Programs that promote equality, education, and opportunity

  • Ethical partnerships aligned with our values

Our role extends beyond financial services—it includes uplifting the communities we serve.

7. Transparency & Honest Communication

Ethical behaviour depends on clear, truthful, and responsible communication.

We commit to:

  • Transparent disclosure of information

  • Avoiding misleading statements or omissions

  • Communicating respectfully and professionally with clients and regulators

  • Ensuring financial products are marketed responsibly

Trust is built through clarity.

8. Confidentiality & Ethical Data Use

Handling sensitive financial and personal information is a profound responsibility.

We ensure:

  • Strict data protection and confidentiality

  • Ethical handling of digital assets, financial records, and client data

  • Compliance with GDPR and other international privacy laws

  • Responsible use of AI and automation technologies

Data must be protected, respected, and used only for legitimate purposes.

9. Continuous Ethical Development

The financial and digital asset landscape evolves rapidly.
We ensure our people are prepared.

PAA CAPITAL commits to ongoing ethical education through:

  • Mandatory training programs

  • Guidance on emerging ethical challenges

  • Regular policy updates

  • Encouraging a culture of questions, learning, and accountability

Ethics are strengthened through awareness and continual improvement.

10. Reporting Ethical Concerns

Upholding this Code is everyone’s responsibility.
Any concerns, unethical behaviour, or suspected violations must be reported in good faith.

Employees, partners, and clients may report through:

  • Our secure encrypted whistleblowing portal

  • Internal compliance channels

  • Regulatory authorities if appropriate

Retaliation against individuals who report in good faith is strictly prohibited.