ElementPay Code of Conduct

1. Introduction and Purpose

This ElementPay Revised Code of Conduct (“Code”) establishes the fundamental principles, ethical standards, and behavioral expectations for all individuals engaging with the ElementPay ecosystem, including but not limited to users, employees, contractors, partners, and stakeholders. As a Virtual Asset Service Provider (VASP) operating within the Republic of Kenya, ElementPay is committed to fostering a secure, transparent, and compliant environment that adheres to the highest standards of integrity, professionalism, and legal probity.

This Code is designed to complement and reinforce ElementPay's commitment to all applicable laws and regulations, including the Virtual Asset Service Providers Bill, 2025 (the “VASP Bill”), the Proceeds of Crime and Anti-Money Laundering Act, 2009 (POCAMLA), and the Data Protection Act, 2019 (DPA).

By accessing, using, or otherwise interacting with ElementPay's platform and services, all individuals are deemed to have read, understood, and agreed to abide by the provisions of this Code. Adherence to this Code is paramount for maintaining the trust and confidence of our community and regulatory authorities.

2. Core Values and Principles

ElementPay's operations and interactions are underpinned by the following core values, which guide our conduct and decision-making:

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  Integrity and Ethical Conduct: Upholding the highest standards of honesty, transparency, and accountability in all dealings. This includes a steadfast commitment to preventing and reporting illicit activities, such as money laundering, terrorism financing, and fraud.
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  Compliance with Law and Regulation: Strict adherence to all applicable local, national, and international laws, regulations, and guidelines governing virtual assets, financial services, data protection, and anti-financial crime measures.
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  Respect and Non-Discrimination: Treating all individuals with dignity, respect, and fairness, irrespective of their background, role, or perspective. ElementPay is committed to an inclusive environment free from harassment, discrimination, or any form of inappropriate behavior.
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  Transparency and Accountability: Operating with openness and clarity, particularly concerning our services, fees, risks, and data handling practices.
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  Security and Privacy: Prioritizing the security of our platform and the protection of user data. This involves implementing robust technical and organizational measures to safeguard information and respecting individual privacy rights.
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  Innovation and Responsible Growth: Encouraging creativity and the pursuit of technological advancements while ensuring that innovation is balanced with robust risk management, consumer protection, and regulatory compliance.
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  Customer Focus and Service Excellence: Prioritizing the needs and interests of our users, striving to provide seamless, secure, and reliable services.

3. Expected Behavior and Professional Standards

All individuals engaging with the ElementPay ecosystem are expected to conduct themselves in a manner that reflects positively on ElementPay and its community. This includes, but is not limited to:

3.1 Compliance with Legal and Regulatory Obligations

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  Adherence to KYC/AML/CTF Procedures: All users must fully cooperate with ElementPay's Know Your Customer (KYC) and Customer Due Diligence (CDD) procedures.
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  Prohibition of Illicit Activities: Engaging in, facilitating, or attempting to facilitate any illegal activities is strictly prohibited.
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  Data Protection and Privacy: Handling all personal data in strict accordance with the DPA and ElementPay's Privacy Policy.
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  Sanctions Compliance: Adhering to all applicable national and international sanctions regimes.

3.2 Ethical Conduct and Professionalism

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  Honesty and Integrity: Acting truthfully and with integrity in all interactions.
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  Fair Dealing: Engaging in fair and ethical practices in all business dealings.
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  Confidentiality: Protecting ElementPay's proprietary information, trade secrets, and user data.
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  Respectful Communication: Engaging in open, honest, and constructive communication.
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  Responsible Use of Resources: Utilizing ElementPay's resources responsibly and only for authorized purposes.

4. Unacceptable Behavior

The following behaviors are strictly prohibited and constitute a material violation of this Code:

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  Harassment and Discrimination: Any form of harassment, bullying, intimidation, or discrimination based on race, ethnicity, gender, sexual orientation, religion, disability, age, or any other protected characteristic.
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  Fraudulent or Deceptive Practices: Engaging in any activity intended to defraud, deceive, or mislead ElementPay, its users, or any third party.
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  Violation of AML/CTF Laws: Any act or omission that violates anti-money laundering or counter-terrorism financing laws.
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  Unauthorized Access or System Interference: Attempting to gain unauthorized access to ElementPay's systems, user accounts, or data.
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  Intellectual Property Infringement: Unauthorized use, reproduction, or distribution of ElementPay's intellectual property or the intellectual property of third parties.
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  Retaliation: Any form of retaliation against individuals who report concerns or violations in good faith.

5. Reporting Violations

ElementPay encourages all individuals to report any suspected violations of this Code, ElementPay policies, or applicable laws and regulations. Reports can be made through the following channels:

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  Designated Reporting Channels: Specific reporting mechanisms will be provided within the ElementPay platform or on its official website.
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  Email: Reports can be sent to elementpay.info@gmail.com

All reports will be handled with strict confidentiality and investigated promptly and impartially. ElementPay prohibits any form of retaliation against individuals who make good faith reports of suspected misconduct.

6. Enforcement and Consequences

ElementPay is committed to the rigorous enforcement of this Code. Violations will be addressed promptly and may result in a range of disciplinary actions, depending on the severity and nature of the misconduct. Consequences may include, but are not limited to:

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  Warnings and Remedial Actions: Formal warnings, mandatory training, or requirements to rectify non-compliant behavior.
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  Suspension of Services: Temporary suspension of access to ElementPay services.
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  Termination of Access: Permanent termination of access to ElementPay services and account closure.
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  Legal Action: Pursuit of civil remedies or referral to relevant regulatory and law enforcement authorities for criminal prosecution.
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  Forfeiture of Funds: In cases of illicit activities, ElementPay reserves the right to freeze and/or forfeit funds in accordance with legal mandates and regulatory directives.

All reported incidents will be reviewed by ElementPay's designated compliance team or legal department, ensuring fairness, objectivity, and adherence to due process.

7. Review and Amendments

ElementPay reserves the right to review, update, or amend this Code of Conduct periodically to reflect changes in legal and regulatory requirements, industry best practices, or ElementPay's operational needs. Any revisions will be effective immediately upon posting the updated Code on our official platforms. Users and stakeholders are encouraged to review this Code regularly to stay informed of their obligations. Continued engagement with ElementPay's services following any amendments constitutes acceptance of the revised Code.

8. Contact Information

For any questions or clarifications regarding this Code of Conduct, please contact ElementPay's Compliance Department at:

Email: elementpay.info@gmail.com