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.