Code of Conduct

As a company we are committed to conduct business with integrity and fairness, with respect for law and regulation, our values and our Code of Conduct. We do not underestimate the importance of our conduct, and always take personal responsibility for our actions This Code explains what we stand for and what is expected from all of us – individually and as a team. It is our shared commitment to operate with the highest level of integrity and ethical conduct.


Our purpose and values are at the base of our culture – a culture that is rooted in integrity, honesty and delivering the best service we can.

Serve Our Clients

It is important that our users look at our company as one they can trust. The trust our users put in us, is our most valuable asset, and it is up to all of us to make sure that we continually earn their trust. All of our actions and communications as well as other interactions with our users should increase their trust in us. We treat our customers as we would wish to be treated.

We must strive to be continually relevant for our users and add value to them. As a company we must keep asking ourselves: ‘Are our services and products (still) useful for our customers?’

Obey The Law

We adhere to laws and regulations relevant to our business. We do not want our business to be used by others for the purposes of money laundering, terrorist financing or any other criminal activities. In order to prevent any violation of anti-money laundering laws, it is very important for us to know our customers, suppliers and other business partners.

If you have any concerns about money laundering activities or other activities that could breach laws or regulations, please speak up.

Trust And Support The Team

We believe that the best outcomes are achieved when people work together. We believe great teams are built on mutual trust, honesty, shared ownership and accountability. We are one team and believe when we work together, we best meet the full needs of our customers.

We believe in the importance of treating each client and teammate as an individual. We support our team members and employees to reach their full potential. We believe that diverse backgrounds and experiences make us stronger. We respect every individual and value our differences — in thought, style, sexual orientation, gender identity, race, ethnicity, culture and experience.

Be Honest And Act With Integrity

We all must follow the law, act with integrity and honesty in all matters, and be accountable for our actions.

Business Conduct

We believe in clear, fair and responsible decision-making. By acting with integrity, we reflect positively on the values and reputation of our company. In certain situations the right decision is clear, but in many situations the right decision is less clear-cut or there may be other factors impacting your decision-making. Regardless of the nature of a particular decision, keep the following in mind to help you make informed and responsible decisions:

  • Ensure you have all the relevant facts
  • Take into account relevant laws, regulations and policies
  • Identify potential options and their potential outcome and impact
  • Adhere to our Company values

It’s important to use good judgment in everything you do and to ask for help if you’re ever unsure about the right course of action.

Business and Financial records

Ensure the accuracy of all Company business and financial records. These include not only financial accounts, but other records such as user numbers, account owners and other management information. Ensuring accurate and complete business and financial records is the responsibility of all of us, not just a role for accounting and finance personnel. Accurate recordkeeping and reporting reflects on the Company’s reputation and credibility, and ensures that the Company meets its legal and regulatory obligations.


Our reputation is an important asset, therefore we need to ensure that we always communicate in the right way. We make sure that information shared about our company is consistent, accurate

and complete. Part of this is that employees should not disclose Company information to anyone internally or externally unless that individual has the right to know.

When using social media, please state that your opinions or statements about our Company are your own and not that of the Company and don’t disclose confidential information about the Company or any of our partners or suppliers

Gifts, Entertainment, and Other Business Courtesies

An occasional gift or offer of entertainment is often viewed as a normal part of doing business. However, accepting gifts, entertainment and other business courtesies from a competitor or business partner can create the appearance of a conflict of interest, especially if the value of the item is significant. Gifts or entertainment given should be nominal in value, infrequent, never be in cash or a gift card, check, loan or stock. All gifts, courtesies and entertainment given should be recorded accurately in our financials and records.

Safeguard Our Assets

Use of Company Resources

We must properly care for and look after our Company property and assets, which should be used in the manner intended. Do not use Company assets for your personal benefit or the benefit of anyone other than the Company.

We must not:

  • Steal, misappropriate money, funds or anything of value from the Company. Doing so subjects us to potential disciplinary action.
  • Use the Company assets for personal gain or advantage.
  • Misuse your phone, email or internet privileges. During their non-work time, employees are permitted personal use of the internet, email and any other of the Company’s electronic tools.

Privacy and Data Protection

We respect and protect the privacy of all individuals. We protect the privacy and personal data of our employees, clients and business partners. We are committed to comply with all relevant data privacy requirements of the countries in which we operate. Employees who handle the personal data of individuals must:

  • Act in accordance with applicable privacy and data regulation;
  • Collect, use and process such information only for legitimate business purposes;
  • Limit access to the information to those who have a legitimate business purpose for accessing the information; and
  • Take care to prevent unauthorized disclosure.

Intellectual Property and Confidential Information

We respect and protect our intellectual property and confidential information. Our brands (e.g. OuroX, Ouro, Fuente) are our most important assets. We must take all necessary actions to protect our intellectual property. All (future) brands, products and innovations are subject to this. Be aware of intellectual property rights and respect the intellectual property rights of third parties.

Each of us encounters confidential information on daily basis. Think of forecasts, audit reports, (draft) contracts and deals, designs, strategies, innovations etc. It is of great importance that we respect the confidentiality of such information and only share and use to the extent allowed.



What are your responsibilities?

We expect you to always act in accordance with both the law and our Code. In the event that regulations or self-regulatory agreements are more restrictive, they prevail. We expect all of us to live and breathe the Company’s values and to promote a culture which is inclusive and open. Everyone should feel comfortable to raise questions, dilemmas and concerns. Especially management is expected to lead by example.

If you’re approached with a question or concern related to the Code, listen carefully and give the employee your complete attention. Ask for clarification and any helpful additional information. If you’re able to answer any questions please do, but do not feel that you must give an immediate response. Seek help if you need it. If an employee raises a concern that may require investigation under the Code, contact your senior finance personnel or company legal counsel.

What to do in case of doubt?

Not all specific situations are covered by the Code as not every circumstance can be addressed. If you are unsure of what to do, please consider the following questions:

  •       Does it feel like it’s the right thing to do?
  •       Is it legal and is it in line with our values and our Code?
  •       Is it good for OuroX and for my coworkers?
  •       Would I still feel ok about it if people (e.g. media, coworkers) found out?

If the answer is ‘no’ to any of these questions or if you are uncertain, please ask for guidance. You can seek help from your senior finance personnel or company legal counsel.

Speak Up!

What if something doesn’t feel right? What if you have questions that lead to more difficult questions? If you observe behavior that concerns you, or that may represent a violation of our Code, please raise the issue promptly. Remaining silent can only worsen the situation and undermine trust. When you honestly and truthfully raise a concern, you help to protect our Company, your workplace, and ultimately your colleagues and yourself


The Company values the help of employees who identify potential problems that the Company needs to address. Any retaliation against an employee who raises an issue honestly is a violation of the Code. Please feel confident that no one will be penalized for raising concerns in good faith about suspected misconduct.

If you work with someone who has raised a concern or provided information in an investigation, you should continue to treat the person with courtesy and respect. If you believe someone has retaliated against you, please report the matter to senior finance personnel.


Our culture comes from how we run the company every day, like acting responsibly, acting with integrity, our commitment to ethical behavior and complying with laws and regulations and policies that reinforce such behavior. Our success relies on our teamwork, the skills and mindset, intellectual curiosity and sound judgment of our team.

At OuroX we care about having an open, free and happy workspace as, in our view, this leads to a productive atmosphere for everyone.

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