Business code of conduct and ethics

[Company legal name] ("Zero Entry", "we", "us") Effective date: [effective date] Version: 1.0 (draft for legal review)

1. Purpose

This code sets out the standards of behaviour Zero Entry expects of everyone who works for or represents it. It protects our customers, our people and our reputation, and it supports the trust that a financial platform depends on.

2. Who it applies to

This code applies to all directors, employees, contractors and agents of Zero Entry. Following it is a condition of working with us.

3. Integrity and honesty

We are honest in our dealings with customers, partners, regulators and each other. We do not misrepresent our product, our prices or our capabilities. We do not make claims about the platform that we cannot support.

4. Customer trust and confidentiality

Customer financial data is confidential. We access it only where necessary to provide or support the service, never for personal benefit or curiosity, and we never disclose it except as allowed by our privacy and data protection policies or required by law. This duty continues after the working relationship ends.

5. Data protection

We handle personal information in line with the Zero Entry data protection policy and the Data Protection Act. We collect only what is needed, protect it, and do not use it for purposes the individual would not expect.

6. Conflicts of interest

We avoid situations where personal interests conflict, or appear to conflict, with the interests of Zero Entry or its customers. Any actual or potential conflict must be disclosed to management so it can be managed.

7. Anti bribery and corruption

We do not offer, give, request or accept bribes, kickbacks or improper advantages, whether to win business, influence a decision or for any other reason. Reasonable and transparent business courtesies are acceptable only where they could not be seen as an attempt to improperly influence.

8. Anti money laundering

We follow the Zero Entry anti money laundering and counter financing policy. We report suspicious activity internally and never assist, or turn a blind eye to, the misuse of the platform.

9. Fair dealing and competition

We compete on the merit of our product. We do not make false statements about competitors and we do not obtain confidential information by improper means.

10. Respect in the workplace

We treat colleagues, customers and partners with respect. We do not tolerate harassment, discrimination or bullying. We support a safe and inclusive environment.

11. Company assets and information

We protect the company's assets, systems and information, and use them for legitimate business purposes. We do not misuse access, credentials or intellectual property.

12. Accurate records

We keep honest and accurate business, financial and customer records. We do not falsify records or accounts.

13. Speaking up

Anyone who becomes aware of a breach of this code, or of the law, should raise it with management or the Compliance Officer. Reports made in good faith are taken seriously and treated in confidence, and we do not retaliate against anyone for raising a genuine concern.

14. Consequences

Breaches of this code may lead to disciplinary action up to termination, and where the law is broken, to legal consequences.

15. Review

This code is reviewed at least annually.

Acknowledgement: I have read and agree to follow this code of conduct.

Name: _______________________ Signature: _______________________ Date: __________