Coinify legal information

This page provides you with all legal information and resources related to Coinify products and services.

Click on the tabs below to view the different legal areas.

Associated documents (Terms of Service, AML/KYC Policy, Privacy Policy, and Virtual Currency Risk Warning) govern the use of the products, services, platforms, websites or any other features, technologies or functionalities provided by Coinify or as part of the Coinify brand, through Coinify’s website(s) (including mobile services), API or through any other means (collectively the “Services”).

For legal inquiries ie. police requests, governmental requests etc. please contact legal@coinify.com

Ethics Policy

This policy shall be implemented in all parts of Coinify ApS (the “Company”), taking local rules into account, when relevant. The Company’s products and services may only be used for lawful purposes. In addition, we want to prevent our products and services from being used in an unethical way.

Principles for Ethical Behaviour and Practices

All actions and decisions within the Company shall meet high requirements with regard to ethical behaviour. This will inspire confidence in the Company among the general public, customers and others. In certain cases, this may mean that the Company must live up to higher requirements than those prescribed by laws and other rules.

The Company’s corporate culture is based on the following common core values:

1. The Company shall comply with relevant external and internal restrictions (observing transparency and appropriateness) regarding giving and receiving gifts as well as unacceptable benefits, in order to avoid any allegation of bribery or corruption.

2. The Company shall at all times conduct its business in such a manner as to enhance the reputation and credibility of the Company and the Payments Platform. The Company shall:

- Refrain from participating in any unlawful, unfair, deceitful or immoral practice and refrain from selling the Payments Platform to any other partner, customer, or organisation, which has recourse to such practices.

- Present the Payments Platform in a fair and appropriate manner. For such purpose, the partner and customer shall not disparage the Company and the Payments Platform and shall not make statements concerning the characteristics or capabilities of the Payments Platform which may not be in accordance with those described in this documentation; nor shall the partner and customer market the Payments Platform by correspondence.

3. Each action or decision in the Company shall be carried out in such a manner that it can be scrutinised by others.

Blockchain and Virtual Currencies Working Group Ethical Guidelines

Furthermore, Coinify adopts and complies with the high ethical standards that are put forward by the Blockchain and Virtual Currencies Working Group. The code of conduct for these ethical standards is as follows:

1. Protect the consumer by law

All member companies comply with the law, specifically with the European law provisions regarding consumer protection in distance contracts, the GDPR, as well as with specific regulations relating to their offered products and/or services.

2. Protect the consumer by contract

All member companies will take all the necessary measures to protect the consumer by contract, providing (where applicable) :

- Clear Terms and Conditions (T&Cs) on their website or in clients’ contracts;

- Clear information about ICOs for investors;

- Smart contracts clear enforcement rules and T&Cs;

- Risk disclosure and awareness, disclosing risks in cryptocurrencies to investors and traders.

- Duty of care towards the clients;

- Clear services access conditions;

- Clear and accurate information on their regulatory/licensing status, where relevant.

3. Protect the consumer via clear wording

The member companies take the necessary measures in order to ensure that all communication regarding their products and services towards consumers is transparent and unambiguous.

4. Protect the industry's reputation

The member companies refrain from any sort of behaviour which could damage the blockchain and virtual currencies industry reputation in any way. In the same way, they will take reasonable measures to cooperate with regulators when approached.

5. Oppose financial crimes

The member companies, in cooperation with other WG members, will take reasonable measures to prevent and oppose virtual currencies related to financial crimes, including but not limited to:

- money laundering

- terrorist financing

- fraud

- market manipulation

- bribery and corruption

- tax evasion

- sanctions evasion

6. Do not accept cash without appropriate controls

The member companies will only accept cash when exchanging Euro or other fiat currencies for virtual currencies if they have appropriate AML controls in place to mitigate the risk of exposure to financial crime.

7. Quality assurance

The member companies pursue systematic security and quality assurance, with due regard for their legal obligations.

8. Share

Each member company will inform its employees, as well as anyone who may request a copy of the Code of Conduct, of this Code of Conduct. This Code of Conduct is also available online.

Policies, instructions and routines that supplement and clarify the principles of this Ethics Policy. Sanctions. If the Company’s partners or a customer fails to comply with this Ethics Policy, the Company shall terminate the cooperation. The Company may give the partner or customer an opportunity to improve if no immediate improvement is recognised the policy is to terminate with zero tolerance.

Procedure. Coinify will examine the products and services within three months after the first transaction of new merchants through the Coinify Website. PSPs ́s will be asked to verify that their products and services are neither unlawful, unfair, deceitful or immoral. Each Merchant will be re-examined within 15 months from signup and after the elapse of each 12 months period. Each PSP will be asked to repeat their verification that their products and services are neither unlawful, unfair, deceitful or immoral, within 12 months after signup and after the elapse of each new 12 months period.

Methods and Practices

The Company shall not cooperate with partners and customers, which sell products or carry out services with means and methods that can be regarded as intrusive, misleading, abusive, and disadvantageous to end-customers or in any other way unethical. Examples of unethical Methods and Practices are below:

1. Marketing, distribution, or other handling of illegal products or services.

2. Products that encourage crime or may provide support to illegal activities.

3. Unlicensed copies and other products infringe intellectual property rights.

4. Sexual or pornographic services, including:

a. Prostitution

b. Live webcam

c. Sale of patently offensive content without serious artistic value (e.g., non-consensual sexual behaviour, sexual exploitation of a minor, non-consensual mutilation, bestiality).

5. Illegal substances, such as drugs, and products typically used for manufacturing or using such.

6. Content encouraging or inappropriately related to hate, violence, racism, or discrimination.

7. Jailbreaker equipment and software.

8. Hacking and cracking materials.



Anti-Bribery and Corruption

At Coinify ApS (‘Coinify’), we are committed to operating lawfully, ethically and with integrity in all business activities. As part of this commitment, Coinify will not tolerate any form of bribery or corruption in our business or in those we do business with.

As an organisation, we strive for the highest level of compliance with respect to all legislation. To that end, Coinify will uphold all anti-bribery and corruption laws and regulations in all the jurisdictions in which we operate. As a Danish company with operations throughout the EU and beyond, Coinify is bound by the Danish Criminal Code legislation and wider European Union best practices related to bribery and corruption.

Coinify would rather walk away from a business opportunity than be involved in any activity that could be construed to be a bribe. We expect all contractors, suppliers, counterparties, agents and others associated with Coinify (“Business Partners”) to adopt a similar zero-tolerance approach to bribery and corruption.

This ethos is endorsed by Coinify’s management team and board. We expect that a similar commitment is taken by our Business Partners to mitigate the risks of bribery and corruption in Denmark, the EU and overseas.

All forms of bribery are strictly prohibited, including facilitation payments.

Countering the Risks of Bribery & Corruption

Coinify mitigates bribery risks by adhering to a control framework and maintaining an awareness of higher-risk activities to help identify areas of potential concern. This approach is based on a framework outlined by the European Union and known as ‘Adequate Procedures’, they are summarised below:

1. Risk assessment

2. Communication and training

3. Tone from the top

4. Due Diligence

5. Monitoring and review

6. Proportionate procedures

We expect Business Partners to have adopted this approach, regardless of their jurisdiction and document their risk-based controls and procedures accordingly. Business Partners based overseas are also encouraged to adopt a similar framework to ensure their governance framework contains suitable bribery prevention measures. We recommend the following are recorded as risks and managed accordingly with adequate controls.

Third-party intermediaries (TPIs)

Many companies use an agent, finder or consultant to help them identify, win or retain business in certain countries in which they operate. TPIs can carry bribery risks, often because of personal connections with local officials or the government of that country. TPIs have also been used to facilitate payments of bribes.

Foreign Public Officials (FPOs)

FPOs represent a heightened risk of bribery, with public records revealing instances of bribes made or received both in the EU and abroad. Coinify operates controls to mitigate our exposure to this risk, which includes a restriction on the giving or receiving of gifts or hospitality without senior management approval.

Overseas payments

When a bribe is made through a financial institution, this can involve monies going to an overseas jurisdiction with weak financial controls. Many organisations operate in multiple jurisdictions and this creates the legitimate need to make overseas payments. However, particular attention should be paid to transactions in overseas and high-risk jurisdictions.

Sponsorships and donations

Coinify only makes charitable donations which are ethical and legal under local laws and practices. We do not make payments to political parties, organisations or their representatives. Additionally, no sponsorship or charitable donation will be made if it could be perceived to be a bribe and we have similar expectations of our business partners.

Gifts & Hospitality

Coinify recognises that giving and receiving gifts or hospitality can be part of building normal business relationships or maintaining cordial relations. The problem arises when the gifts or hospitality are considered to be disproportionate, unduly lavish, extravagant, or could be seen as an inducement or reward for preferential treatment (e.g. during contractual negotiations or a tender process). To avoid any uncertainty all gifts and hospitality (except low-value items such as corporate promotional items), including any offers which are declined are entered on a Gift Register and regularly reviewed.

Facilitation Payments

A facilitation payment (or grease payment) is a sum of money typically paid to an FPO or another person to expedite a routine or necessary administrative process. It’s generally a small sum used to speed up a process such as goods through customs. Although a facilitation payment is legal in some jurisdictions, European legislation takes precedence and classifies them as a bribe. Facilitation payments must not be paid on Coinify’s behalf unless refusal to pay creates a health and safety situation.

Slavery

Modern slavery is criminal activity and a violation of human rights. The deprivation of a person’s liberty by another in order to exploit them for personal or commercial gain is unacceptable. Coinify recognises it has a responsibility to take a robust approach to slavery and human trafficking and has zero tolerance for this activity from any staff, or suppliers of the group.

Training

We encourage our Business Partners to identify employees working with Coinify who may benefit from anti-bribery training. Coinify has designed an anti-bribery awareness module that can be made available to the employees of its Business Partners in the event they do not have their own.

Speak-Up

Coinify operates with transparency and encourages its own employees to report improper behaviour or suspicions of impropriety. We have an independent and confidential reporting hotline which can also be used by our Business Partners to report suspicious activity. We would encourage our Business Partners to have a similar policy for their employees to report suspicions of actual or potential bribery or other dishonest behaviours to their management.

Certification

Suppliers will certify compliance with this policy and their adherence to the relevant human trafficking, slavery, anti-bribery and corruption laws in the jurisdictions in which they operate. Suppliers who are found to be engaged in any of the activity prohibited in this policy or who refuse to cooperate with Coinify in auditing their compliance with this policy will be liable to have any supply agreement, arrangement or other contracts with Coinify terminated immediately with no notice or compensation. Coinify has zero tolerance.

Any questions regarding this policy should be emailed to compliance@coinify.com.

*Last modified in March 2023.