Ethics and Integrity

PayBrokers Compliance Program

Since its foundation, PayBrokers has conducted its business ethically. As a payment facilitator (eFx), trust is a fundamental element for us to continue operating in an increasingly competitive market.

Code of Ethics and Conduct

PayBrokers’ Code of Ethics and Conduct is the document that establishes the guidelines and rules of conduct to be followed by everyone associated with the company, including employees, suppliers and business partners. The main objective of the Code of Ethics and Conduct is to ensure integrity, transparency, and ethics in the company’s activities.

The Code establishes prohibited and encouraged conduct in four basic environments of PayBrokers’ relationships: internal relations, customer relations, external relations, and end-user relationships. In the document, each environment has specific guidelines to be followed.

PayBrokers’ Code of Ethics and Conduct is an instrument designed to ensure ethics, transparency, and respect in the company’s business relationships. Everyone involved must follow the guidelines established in the code to promote a healthy and ethical work environment, ensuring customer trust and satisfaction.

How PayBrokers’ Compliance Program works?

Compliance communication channels:

PayBrokers provides the e-mail compliance@paybrokers.com.br as a reporting and communication channel for anyone, including administrators, employees, suppliers, customers, and third parties. The same e-mail can be used for inquiries, suggestions, or recommendations to enhance the Compliance Policies. The main goal of the Compliance Program is to provide a secure and accessible means for contributions, inquiries, and reports of non-compliance.

Anonymity and confidentiality guarantee:

PayBrokers allows everyone to make reports or contributions to the Compliance Program anonymously, without the need for identification. Ensuring anonymity and confidentiality throughout the contribution process is crucial to maintain security and trust in Compliance activities.

PayBrokers’ Compliance and Risk Prevention Committee:

The Committee is responsible for the direct application of Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) policies.

Its functions include supervising and monitoring situations that require direct action from the Committee, supporting and advising the Board in defining and evaluating the Compliance Program, and addressing reports of potential violations of the Code of Ethics and Program policies.

Policies adopted by PayBrokers

1. PayBrokers’ Anti-Money Laundering and Counter-Terrorism Financing Policy:

Our policy aims to prevent money laundering acts, which involve hiding the origin of assets or values derived from criminal activities. It also defines the roles and responsibilities of PayBrokers’ internal bodies to ensure ongoing compliance with prevention mechanisms and establishes essential governance requirements.

Fundamental principles of this policy include:

  • prevention of financial crimes: We are constantly cautious to prevent financial crimes.
  • risk-based approach: We make decisions based on a consolidated corporate risk policy.
  • protection of PayBrokers’ image: We aim to avoid undesirable risks that could harm corporate integrity and the company’s reputation in the market.
  • appropriate internal procedures: We pay attention to internal procedures for preventing money laundering and terrorist financing, ensuring their compatibility with the volume of operations.

For more details on the functioning of our Anti-Money Laundering and Counter-Terrorism Financing Policy, please consult the specific document prepared by the company. Prevention of these practices is a fundamental pillar of PayBrokers’ operations, and it is crucial to immediately report any indication or suspicion of hidden origins of values.

In addition to AML/CTF, PayBrokers adopts the following policies:

2. Privacy and data protection policy:

The Privacy and Data Protection Policy aims to protect personal data and information entrusted to the company. The policy establishes various measures to ensure the security and proper handling of personal data processed by PayBrokers.

3. Anti-corruption, anti-bribery, and relationship with public authorities policy:

This policy seeks to regulate transparent relationships with public administration by establishing various rules of engagement between public officials and PayBrokers’ stakeholders.

4. Due diligence policy:

The due diligence procedure aims to ensure the integrity of clients, employees, suppliers, and business partners by verifying reputation, legal compliance, and compatibility with the contractual scope.

5. PayBrokers’ product policy:

The Product Policy of PayBrokers seeks to regulate the proper functioning of the offered products and services, as well as ensuring a standardized communication language with customers.

6. Supplier Policy:

PayBrokers’ Supplier Policy sets forth mechanisms for maintaining a good relationship with service providers, including the establishment of anti-corruption clauses in contracts and the need for full compliance with contractual provisions.

FURTHER DETAILS ABOUT THE POLICIES INCLUDED IN PAYBROKERS’ COMPLIANCE PROGRAM CAN BE FOUND IN THE FOLLOWING DOCUMENTS: