Message from the Management of RINTRAL TRADING S.L.U
At RINTRAL TRADING S.L.U., we firmly believe in what we do, focusing all our efforts on doing it differently, safely and efficiently, adapting to the needs of our customers and society itself, whatever they may be. For this reason, we are committed to working with ethics and integrity, which means that all of us who form and collaborate with RINTRAL TRADING are able to create a work environment, services and brand image where honesty, safety, transparency, empathy, trust, commitment, effort and loyalty prevail, as well as respect for human rights, the environment and the legitimate interests of all the people and organisations with whom we interact, maintaining the highest standards of quality and dignity in our work.
Thus, in the context of RINTRAL TRADING's corporate social responsibility, this document represents the main pillar of our internal policies and serves as our guide for conduct.
Sergey Romanovskiy
1. Purpose
This Code of Ethics and Conduct establishes the core values and professional standards that govern the operations of RINTRAL TRADING, S.L.U. (“the Company”). It forms an integral part of the Company’s internal governance and compliance framework and must be interpreted in conjunction with related policies, such as the Suitability Policy, Complaint Resolution Procedure, Corporate Governance Manual, and all regulatory requirements applicable to cryptoasset service providers.
The purpose of this Code is to ensure that all individuals acting on behalf of the Company, including members of the management body, employees, contractors, and stakeholders, uphold the highest standards of integrity, professionalism, and accountability in the performance of their duties. This Code aims to foster a corporate culture rooted in ethical behavior, regulatory compliance, and respect for fundamental rights.
Thus, this Code is mandatory for all members of the Company, regardless of their hierarchical position or geographical location in which they carry out their work. Likewise, members of the Company who act as its representatives shall observe the provisions of this Code in said representation, promoting the values and policies that define the company.
All individuals subject to this Code are expected to understand, apply, and promote its principles in their daily activities and decisions, regardless of their function or seniority. Adherence to this Code is mandatory and forms part of the Company’s overall commitment to building trust, protecting stakeholders, and delivering services with excellence and transparency.
2. Scope
This Code of Ethics and Conduct establishes the standards of behaviour and principles of action of RINTRAL TRADING, establishing a culture of compliance - also within the framework of prevention in the area of criminal liability of legal persons - among its members by promoting good practices, principles and values. Therefore, any internal policy or procedure developed shall be interpreted in accordance with the essence of this Code of Conduct.
Considering ethical behaviour as the basis for all decisions and actions of the organisation, which must be carried out with integrity, this Code provides the basic guidelines for ethical and responsible behaviour for both the members of the Company and its collaborators or other third parties, maintaining a transparent relationship in all cases.
3. Corporate Values
The Company upholds four fundamental values that define its organizational culture and strategic direction:
- Integrity: We act with honesty and ethical purpose in all circumstances. We expect every individual to maintain consistency between words and actions, ensuring that promises made to clients, regulators, and partners are always honored.
- Transparency: We are committed to clear and open communication, both internally and externally. Transparency fosters trust and accountability, particularly in financial services where clients rely on accurate and timely information.
- Responsibility: We accept responsibility for our actions and their impact on customers, partners, and society. This means adhering strictly to our regulatory obligations and acting with diligence and care in every decision.
- Respect: We promote a workplace and business environment where all individuals are treated with dignity. Diversity of opinion, culture, and background is seen as a strength and is protected throughout the organization.
These values are not merely aspirational; they are embedded in the Company’s daily operations, internal controls, and governance policies. They serve as the ethical compass guiding all business conduct and decision-making processes.
4. Commitment to human and constitutional rights
RINTRAL TRADING is firmly committed to respecting human and constitutional rights such as freedom of expression, privacy, personal development, association, image, confidentiality of communications, and dignity. All of these rights shall be understood within the scope and content conferred upon them by the Constitutional Court in the workplace and shall apply to all aspects and stages of the employment relationship, from hiring to termination, including the assignment of tasks, postings, promotion, remuneration, and disciplinary measures, among others.
5. Equal opportunities
The Company is committed to effort, talent, commitment and equal opportunities, carrying out objective personnel selection based on the training, experience and personal merits of the candidates.
Equal conditions and treatment between men and women in terms of access to employment, training, remuneration, mobility and other working conditions are guaranteed.
6. Non-discrimination
Similarly, the Company does not tolerate discrimination of any kind, either among its members or collaborators or with third parties with whom it has relations. Equality and non-discrimination on the grounds of sex, race, origin, nationality, social class, sexual orientation, ideology, religion, political opinions, membership of social groups, health, age, marital status or any other personal, physical or social condition of individuals is actively promoted.
RINTRAL TRADING openly rejects any manifestation of violence, whether physical or verbal, as well as any act of physical, sexual, psychological or workplace harassment, or any other acts that create an intimidating or offensive environment for its members, collaborators and any third parties with whom it interacts.
7. Professional Conduct and Integrity
All persons subject to this Code are required to demonstrate the highest standards of professional conduct, regardless of role or seniority. This includes acting with due skill, care, and diligence; treating others with respect; and upholding the integrity of the Company at all times. Specifically, professional conduct shall include:
- Honesty in communications, ensuring that all representations made to clients, partners, and regulators are truthful and not misleading.
- Fairness in decisions, especially those affecting clients, business partners, or team members, avoiding favoritism, discrimination, or abuse of power.
- Commitment to ethical standards, particularly when dealing with financial transactions, client assets, or sensitive information.
- Zero tolerance for misconduct, including but not limited to fraud, bribery, harassment, market manipulation, or any other behavior contrary to applicable laws or Company values.
Employees and officers are expected to lead by example and to raise concerns promptly when they become aware of any breach of professional ethics. Failure to adhere to these standards may result in disciplinary actions, including dismissal or legal proceedings where appropriate.
8. Compliance with Laws and Regulations
The Company and all individuals subject to this Code shall operate in strict adherence to all applicable laws, regulations, and regulatory guidelines relevant to its business activities. This includes, but is not limited to:
- Financial Services Regulation: Full compliance with the applicable requirements set forth by the Comisión Nacional del Mercado de Valores (CNMV), including those governing cryptoasset service providers.
- Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF): Adherence to both Spanish and EU-level AML laws, including the obligation to report suspicious activities and maintain accurate records.
- Data Protection and Privacy: Respect for data protection principles as established by the General Data Protection Regulation (GDPR), ensuring lawful and secure processing of personal data.
- Consumer Protection: Implementation of fair practices and transparency when dealing with clients, in line with the Ley General para la Defensa de los Consumidores y Usuarios and other relevant consumer regulations.
The Company shall establish and maintain internal controls, training programs, and monitoring systems to ensure ongoing compliance. All staff are expected to be familiar with the legal obligations relevant to their role and to consult the Compliance Department when uncertainties arise.
Failure to comply with applicable regulations may lead to personal and corporate liability, and will be subject to disciplinary measures.
9. Conflict of Interest
All individuals acting on behalf of the Company must avoid situations where their personal interests conflict, or may appear to conflict, with the interests of RINTRAL TRADING, S.L.U. Such conflicts can compromise objectivity and integrity, and undermine trust in the Company’s operations.
Therefore, all members and collaborators of the Company must avoid situations that may involve a conflict of interest, as well as report those that may affect them personally, such as those they may know about third parties with whom they have a relationship.
Examples of potential conflicts include:
- Holding a financial interest in a company that is a client, supplier, or competitor.
- Using Company property, information, or position for personal gain.
- Accepting gifts or favors that could influence professional judgment.
- Engaging in outside employment or advisory roles that may interfere with Company duties.
Action in the event of a possible conflict of interest will be guided by the provisions of the Company's Anti-Fraud, Corruption, Conflicts of Interest and Sanctions Policy.
10. Confidentiality
Confidentiality is a cornerstone of trust and regulatory integrity. All employees, officers, and contractors of the Company are required to safeguard non-public information obtained through their role and to ensure it is used exclusively for legitimate business purposes.
All employees must sign a Non-Disclosure Agreement (NDA) as a condition of their engagement, confirming their legal and contractual obligation to protect confidential information. This obligation continues beyond the termination of their relationship with the Company. Confidential information includes, but is not limited to:
- Client data and financial details
- Internal reports and analyses
- Business strategies and product plans
- Regulatory communications and compliance assessments
- Any other proprietary or sensitive data
The unauthorized disclosure, use, or mishandling of confidential information, whether intentional or accidental, is strictly prohibited and may result in disciplinary action, including termination and legal liability.
The Company implements robust data handling procedures, including access restrictions, encryption, and regular training on data protection and confidentiality. In the event of a data breach or unauthorized access, the incident must be reported immediately to the Compliance Department for appropriate action in line with GDPR and internal protocols.
11. Anti-Corruption and Fair Competition
The Company adopts a zero-tolerance policy towards all forms of bribery, corruption, and unfair business practices. We are committed to conducting business with honesty, transparency, and full adherence to the principles of free and fair competition. Prohibited conduct includes, but is not limited to:
- Offering, giving, soliciting, or accepting any form of bribe or illicit advantage, whether in cash or kind.
- Facilitating payments or informal incentives to influence business decisions or regulatory outcomes.
- Engaging in collusion, price-fixing, or manipulation of market conditions.
- Abusing dominant positions, confidential information, or regulatory loopholes to the detriment of fair competition.
All employees must immediately report any suspected corrupt behavior or unethical business conduct. The Company shall maintain internal controls and due diligence procedures, especially in interactions with public authorities, third-party intermediaries, and procurement activities.
Failure to comply with anti-corruption standards may lead to disciplinary measures and expose individuals and the Company to civil or criminal liability. Training on anti-corruption and fair competition is mandatory and periodically updated to reflect changes in legal and regulatory expectations.
12. Fair competition
The company ensures respect for its competitors by complying with applicable competition and consumer rights laws. Employees and members avoid unfair practices such as misuse of confidential information, fraudulent price-fixing agreements, market sharing, participation in monopolies or abuse of dominant positions, as well as any other conduct that undermines free competition.
13. Recruitment
The recruitment of members and collaborators is carried out in accordance with the candidates' skills.
At RINTRAL TRADING, we defend and guarantee the rights of individuals, applying current regulations on labour matters, employment conditions and occupational health and safety, while also ensuring the integration of all workers and respect for their dignity, values and culture, avoiding any circumstances that could lead to violence or harassment.
14. Relationship with contractors, subcontractors, suppliers and customers
Operations with contractors, subcontractors, suppliers and customers are carried out in accordance with objective, impartial criteria of maximum transparency, quality and suitability, guaranteeing equal opportunities and avoiding favouritism or interference from conflicts in the selection processes.
Suppliers are also required to demonstrate an adequate level of commitment to socially responsible practices that are compatible with this Code of Conduct.
In any case, the Company expects the third parties with whom it interacts to act in accordance with current regulations and with criteria of respect for human rights and the prevention of criminal behaviour.
Relationships with customers shall be conducted in an open, lawful, ethical and respectful manner.
15. Relationships with national and international public officials
Relations with the Public Administration, members of the Judiciary and regulatory bodies are based on the principles of cooperation and transparency. They shall always be governed by the procedures officially established by the public sector, respecting the rules and avoiding any corrupt conduct.
Under no circumstances shall facilitation or expediting payments of any kind be made to any official, authority, public administration or judicial body.
As a general rule, members and collaborators shall refrain from providing information in any type of media on matters directly or indirectly related to the Company and its activities. The information disseminated shall always and in all cases be truthful and transparent, respecting the privacy and confidentiality of the persons involved and human rights.
No false, misleading, anti-competitive or misleading information may be disclosed.
17. Relationship with political parties and other organisations
Except in the case of agreements duly adopted by the Company, respecting in all cases the principles and values contained in this Code, no contributions of any kind shall be made to political parties, organisations, social groups, non-governmental organisations, etc., on behalf of and in the name of the Company.
The association, membership or collaboration of its members or collaborators in any of the above organisations shall be on a personal basis and in their own name, avoiding any association with RINTRAL TRADING.
18. Acceptance and giving of gifts and invitations
RINTRAL TRADING does not tolerate any type or form of bribery or corruption, whether with public entities or between individuals. The organisation rejects incentives, gifts and invitations that violate this principle.
Such ‘corrupt’ conduct consists of unjustifiably accepting or offering a benefit or advantage of any kind, for oneself or for a third party, in exchange for unduly favouring another party in the procurement of products or services, in commercial relations or in relations with public authorities.
All members and collaborators acting on behalf of the Company shall interact with public and private entities, and any other third party, in a lawful, ethical and respectful manner. The Company prohibits its members and collaborators from requesting any type of gift, invitation, benefit or advantage from third parties.
In this regard, the provisions of the Company's Anti-Fraud, Corruption, Conflicts of Interest and Sanctions Policy shall be complied with.
19. Financial transparency and honest collection
The company's information accurately reflects its economic, financial and equity situation, in accordance with generally accepted accounting principles. It is prohibited to carry out any action that prevents or obstructs the verification and evaluation of financial statements, as well as to make false or misleading statements and entries.
20. Workplace Environment
RINTRAL TRADING, S.L.U. is committed to fostering a professional, inclusive, and respectful work environment, whether physical or digital. The Company defines the workplace to include any setting, on-site, remote, or hybrid, where professional duties are performed, including virtual communication platforms and collaborative tools.
We believe that a safe and equitable work environment is essential to employee well-being, ethical conduct, and long-term performance. To this end, RINTRAL upholds the following principles:
- Non-Discrimination: The Company strictly prohibits any form of discrimination based on gender identity or expression, race, ethnicity, nationality, age, religion or belief, sexual orientation, disability, neurodiversity, marital status, socioeconomic background, or any other legally protected characteristic.
- Zero Tolerance for Harassment: Harassment of any kind, verbal, physical, sexual, digital (e.g., offensive messages or exclusion from online interactions), or psychological, is not tolerated. This applies equally in digital communications such as emails, chat platforms, and video conferences. All employees are encouraged to report any incidents through secure internal channels, with full protection from retaliation.
- Work-Life Balance: RINTRAL promotes flexible and responsible work arrangements, including remote work and adjustable schedules where operationally feasible. The Company encourages reasonable workload management and respects employees' right to disconnect outside working hours.
- Health and Safety: A safe working environment is ensured in accordance with Spanish labor regulations and internal risk protocols. This includes not only physical safety measures but also support for mental health and well-being. Remote workers must ensure a safe and ergonomically suitable setup and follow applicable home office safety guidance.
- Maintaining a respectful and inclusive culture is a shared responsibility. All employees, managers, and contractors must actively contribute to a workplace environment, physical or virtual, marked by professionalism, dignity, and mutual support.
21. Compliance and Disciplinary Regime
This Code of Conduct is structured as an internal policy that is mandatory for all members and collaborators of the Company, regardless of their functions, position or seniority, and any violation of the provisions of this Code is expressly prohibited.
Thus, the Code of Conduct constitutes the cornerstone of the ethical and respectful principles of conduct that govern the development of both the Company and all its members and collaborators. These principles of conduct will be disseminated so that they are known, accepted and respected by all members and collaborators from the moment they join the Company.
All members and collaborators must comply with and apply this Code of Conduct, as well as the other internal policies that govern the company's actions.
No member of the Company, regardless of their position, may authorise or ask another member to carry out conduct or actions contrary to the provisions of this Code, without ‘ignorance’ of these provisions or ‘due obedience’ to a superior exempting those who contravene the Company's internal policies from liability.
Consequently, the corresponding disciplinary sanctions may be imposed in accordance with the provisions of current labour regulations, without prejudice to any liability that may arise following legal proceedings for non-compliance.
Members and collaborators of RINTRAL TRADING have at their disposal a confidential communication channel through which they must report (either anonymously or by name) any irregular activity that they consider to be a violation of this Code, other internal company policies, or any behaviour contrary to current legislation.
Only the conduct described above, which is detailed in the Internal Information System Policy, shall be communicated through this channel. This channel is not the appropriate channel for information, claims, complaints or suggestions of an organisational or material nature, or those relating to human resources.
23. Prohibition of retaliation
RINTRAL TRADING ensures that no member who has reported a violation or irregularity in good faith is retaliated against in any way for doing so. The imposition of retaliation of any kind for this reason constitutes a violation of this Code and must be reported as soon as possible.
24. Implementation and Oversight
The Compliance Department is responsible for the implementation, supervision, and enforcement of this Code of Ethics. Oversight responsibilities include:
- Ensuring that all new employees and contractors receive and formally acknowledge this Code upon engagement.
- Organizing periodic training sessions and awareness campaigns to reinforce ethical conduct and legal compliance.
- Monitoring adherence to the Code and initiating internal investigations when potential violations are reported.
- Coordinating with the Chief Legal Officer in cases involving legal risk or regulatory exposure.
All individuals subject to this Code are expected to comply fully. Breaches of the Code may result in disciplinary action, including dismissal and legal proceedings, depending on the severity of the offense.
25. Validity, supervision, and review
This Code of Conduct has been approved by the Sole Administrator and will be reviewed and updated annually and, in any case, when legal changes or modifications occur in the company or when suggestions are made by company members who advise it.
Any modifications or revisions shall be communicated to the members and collaborators of the company and shall be made available to any interested person or administration with whom the Company has a relationship.