Code of Ethics

Title I – Introduction 

Article 1 – Recitals 

This Code sets forth the commitments and the ethical responsibilities for the conduction of business and professional activities undertaken by ExoLegal OÜ and ExoBooks OÜ (jointly, “FinTech Legal Center” or “FLC” or the “Firm”), their Associates, employees and collaborators. 

FLC affirms that it carries out its internal and external activities under the principles outlined in this Code, believing that it is crucial for the Firm’s success. 

Article 2 – Mission statement 

FLC’s mission is to efficiently provide high-quality legal, corporate and accounting services to the market to develop and enhance the Associates’ professional value, satisfy the clients’ needs, and endorse all the people working here. 

Article 3 – Aims and Values 

In the achievement of such a mission statement, FLC inextricably adheres to the following principles of conduct: 

1. to condemn and reject any unlawful or dishonest behaviour (with regards to the community, public authorities, clients, workers, investors and competitors) in the achievement of its economic aims; 

2. to provide organisational measures to prevent any violation of the principles of lawfulness, transparency, correctness and honesty by its employees and collaborators and to monitor their compliance and correct implementation; 

3. to undertake to promote fair competition; 

4. to pursue excellence and market competitiveness, offering its clients high-quality services which effectively meet their needs; 

5. to safeguard and endorse its human resources. 

Title II – Principles of conduct 

Article 4 – Dialogue and transparency 

FLC believes that clients should always be the centre of its attention and that only a continuous dialogue will permit it to understand their real expectations and maintain a high level of excellence. 

In particular, through dialogue with its clients, the Firm can accurately identify their real needs and assistance, knowing that it plays a key role in providing professional services. 

The Firm believes that the basis of a lasting relationship is trust and communication, which allow the client to understand the nature and the value of all of the services offered. 

FLC also believes that our services must be accessible to all and therefore: 

1. not to discriminate clients based on their nationality, religion or gender, gender or sexual orientation; 

2. to formulate its offer so that all of the social classes can find a response to their needs; 

3. to operate to apply a pricing policy that is in line with the services offered. 

Article 5 – Respect for people 

FLC believes that respect for the personality and dignity of each employee and collaborator is the basis for the development of a work environment permeated by mutual trust, loyalty and enriched by the contribution of each person: 

1. by adopting recruitment and management of employees and collaborators that are based on fair and consistent behaviour, preventing favouritism, abuse and discrimination based on gender, ethnicity, religion, sexual orientation, political and trade union affiliation, language, age or disability; 

2. by ensuring equal development and professional growth opportunities, providing access to training and professional updating initiatives; 

3. by allowing all employees and collaborators the opportunity to express their individuality and professional creativity, valuing the diversity and the uniqueness of each person as an innovative drive and essential contribution to the growth of the Firm; 

4. by taking the utmost care in setting goals, fostering understanding and sharing, to promote correct and transparent conduct in the relationships with clients; 

5. by establishing objective and transparent incentive systems, providing for realistic, attainable goals; 

6. by promoting policies that facilitate the balance between personal and professional life, favouring forms of flexibility and carrying out initiatives to reconcile professional and private commitments by recognising that a person’s private life is fundamental. 

Article 6 – Listening and dialogue 

FLC believes that listening and dialogue are the foundation of relationships that generate trust. To this end it: 

1. promotes the strategic role of internal communication to enable people to participate with more awareness in the Firm’s activities; 

2. bases communication on correctness, completeness, simplicity and transparency criteria; 

3. develops tools for sharing information and the exchange of experiences, which will also facilitate the comparison and integration among the different business areas and departments of the Firm. 

Article 7 – Duties of employees and collaborators 

Employees and collaborators must act honestly to comply with the obligations stipulated in the employment contract and the provisions of this Code, ensuring the required services. 

Employees and collaborators should know and implement the provisions of the Firm’s policies on information security to ensure its completeness, confidentiality and availability. It is required to draft its documents using clear, objective and comprehensive language and allowing any checks performed by colleagues, managers or authorised external parties. 

All employees and contractors are required to avoid situations that may give rise to conflicts of interests and refrain from having any personal benefit in business opportunities of which they become aware during the performance of their functions. 

Each employee or collaborator must work diligently to protect the Firm’s assets by acting responsibly and in line with the established operating procedures to regulate their use. In particular, each employee must use with care and prudence the assets entrusted to them and avoid improper use of firm assets that may cause damage or reduce efficiency or otherwise be contrary to the Firm’s interest. 

FLC reserves the right to prevent the incorrect use of its assets and infrastructure through the use of accounting, reporting, financial control and analysis and risk prevention while complying with the provisions of the applicable law. 

Article 8 – Choice of suppliers 

Procurement processes are based on the search for maximum competitive advantage for FLC and equal opportunities for all suppliers. 

In particular, employees and collaborators of FLC involved in such processes must: 

1. not preclude anyone with the requirements from being able to compete for the signing of contracts, adopting objective and documented criteria in the shortlist; 

2. ensure sufficient competition in tenders; for example, by considering at least three companies in selecting the supplier; any exceptions must be authorized and documented. 

3. In any case, if the supplier, in carrying out its activities, adopts conduct not in line with the general principles of this Code, FLC is entitled to take appropriate measures to preclude any further collaboration. 

Article 9 – Gifts, presents and benefits 

No gift is permitted that could even be interpreted as exceeding regular business or courtesy practices or aiming to obtain favourable treatment in the conduct of any activity relating to FLC. 

In particular, any gift to public officials or their family members which might influence their independent judgment or induce them to grant any benefit is prohibited. 

This rule concerns both gifts which are promised or offered and received. 

Any FLC’s gifts are intended to promote the brand image of the Firm. 

Partners, employees or collaborators of the Firm who receive gifts or benefits which do not fall under those permitted are required, according to established procedures, to notify the person responsible in the Firm who will assess the appropriateness of such gift or benefit and will inform the sender of the relevant policy of FLC. 

Article 10 – Relationships with institutions 

The Firm’s relationships with Estonian and or foreign public institutions are aimed exclusively at forms of communication for assessing the implications of legislative and administrative activities of the Firm and its clients. They are also necessary for responding to requests and inspections by competent authorities or making known the firm’s position or its clients on significant issues.