Code of Ethics

General rules and principles of conduct

This principle guides every activity of REAL MONEY EUROPE, from commercial communications to document management, from relationships with partners to compliance checks.

Principles governing relations with third parties

2.1 · Clients and prospective clients

Relationships with clients and prospective clients must be based on fairness, clarity, helpfulness, confidentiality and professionalism. Information provided must be understandable, not misleading, and consistent with the actual nature of the services offered by REAL MONEY EUROPE.

2.2 · Business partners and parties acting on behalf of the Company

Business partners, including external support structures, must operate in accordance with the values and principles of this Code, with particular attention to transparency, confidentiality, the prevention of conflicts of interest and the protection of the Company's reputation.

2.3 · Suppliers and consultants

The selection of suppliers and consultants is based on criteria of competence, quality, reliability, fairness, cost-effectiveness and regulatory compliance. Relationships must be managed objectively and in a documentable manner, avoiding undue pressure or favouritism.

2.4 · Refineries, supply chain operators and counterparties

In its dealings with refineries, specialised operators, depositaries and other counterparties in the supply chain, REAL MONEY EUROPE applies criteria of reliability, trustworthiness, traceability and consistency with the risk level of the relationship. Every relationship must be supported by adequate documentation and proportionate checks.

Reliability, traceability and clarity are the guiding criteria in every relationship with external parties.

Anti-money laundering, economic legality and traceability

REAL MONEY EUROPE attaches particular importance to preventing money laundering, terrorist financing, the use of resources of unlawful origin, and any transaction that is not transparent or adequately justified. All addressees must contribute, within their respective areas of responsibility, to the correct application of the identification, verification, traceability and record-keeping rules set out in the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010-2021 and internal procedures.

Accounting, record-keeping and internal controls

REAL MONEY EUROPE ensures that every transaction is properly authorised, recorded, verifiable, lawful, consistent and documented. Accounting records, administrative documentation, information flows and all corporate records must be complete, truthful, accurate and timely.

The Company promotes a system of internal controls appropriate to the nature of its activities, with the aim of preventing errors, irregularities and abuse, ensuring the traceability and verifiability of processes, and managing operational, reputational, legal and compliance risks.

Data processing and confidentiality

REAL MONEY EUROPE safeguards personal data, corporate information and any confidential information of which it becomes aware in the course of its activities. Addressees must treat such information confidentially, in compliance with the GDPR, the Data Protection Act 2018 and internal procedures, avoiding unauthorised access, improper use, undue disclosure or processing that exceeds the permitted purposes.

Company resources and IT tools

Company resources, both tangible and intangible, must be used properly, responsibly and consistently with work-related purposes. IT tools, communication systems, access rights and credentials must be used in accordance with security rules, internal procedures and applicable legislation.

It is prohibited to use company resources for unlawful purposes or purposes unrelated to the business, to compromise the security of systems, to install unauthorised software, or to disseminate offensive, discriminatory content or content contrary to company values.

Conflicts of interest, gifts and benefits

Addressees must avoid situations, even merely potential ones, in which personal interests or those of third parties could interfere with those of REAL MONEY EUROPE or compromise the objectivity of decisions. Any conflict of interest, even merely potential, must be promptly reported to the competent company contacts.

Relations with staff and the working environment

REAL MONEY EUROPE recognises the central value of people and promotes a working environment based on respect, dignity, collaboration, accountability and the recognition of merit. The Company opposes all forms of discrimination, harassment, abuse, intimidation or conduct harmful to personal dignity.

Relations with authorities, bodies and supervisory institutions

In its dealings with supervisory authorities, public bodies, institutions and public administration, REAL MONEY EUROPE acts with the utmost fairness, transparency, cooperation and respect for the rules. The Company also operates in compliance with the safeguards and controls falling, as applicable, within the remit of the Anti-Money Laundering Compliance Unit (AMLCU) and FIU Ireland.

It is not permitted to provide false, incomplete or misleading information, to conceal data or documents, to promise or offer improper benefits, or to exert undue pressure on officials, authorities or persons performing a public service.

External communication and protection of the Company's image

External communications must be fair, consistent, truthful and authorised in accordance with company procedures. No addressee may disclose externally any statements, data, documents or confidential information relating to REAL MONEY EUROPE without prior authorisation.

The Company's name, trademark and image may be used solely for lawful purposes and in the Company's interest, in a manner consistent with REAL MONEY EUROPE's institutional and reputational positioning.

Reporting, oversight and implementation of the Code

REAL MONEY EUROPE promotes the dissemination and effective application of this Code of Ethics and encourages the prompt reporting of conduct contrary to its principles, applicable legislation or internal procedures, through the Company's Whistleblowing System (the MITWhistle platform). Reports must be handled confidentially and seriously, and free from retaliation against anyone making a report in good faith, in accordance with the channels and procedures adopted by the Company.

Violations and disciplinary system

Violation of the principles and rules contained in this Code constitutes a breach of the obligations assumed towards REAL MONEY EUROPE and may result in the application of the measures provided for by applicable legislation, applicable contracts, internal procedures and any disciplinary system adopted by the Company.

Any disciplinary measures shall be applied in accordance with the principles of proportionality, consistency and the right to be heard, taking into account the severity of the violation, the intentionality of the conduct and the circumstances of the specific case.

Dissemination, updates and approval

This Code of Ethics is brought to the attention of its addressees through means suitable to ensure its effective dissemination and awareness. REAL MONEY EUROPE reserves the right to update its content in light of regulatory, organisational or operational developments.

REAL MONEY EUROPE promotes a business model founded on legality, transparency, traceability, professional fairness and the protection of client trust.