1. Introduction
This Code of Ethics describes the standards of conduct that govern Maven Pay Inc., the other MavenPay group entities, every member of staff, every contractor, every adviser, and every counterparty that acts on our behalf. It applies to every part of the MavenPay business and is enforced uniformly across the group.
This Code is not a marketing statement. It is a working set of obligations. We measure ourselves against it, we train against it, we investigate breaches of it, and we publish the outcomes of investigations to the extent the law allows.
2. Our Commitments
We are honest with our customers. We disclose what we do, why we do it, and what it costs, before a customer makes a decision. We do not use dark patterns, do not hide material terms, and do not bury risk language.
We are honest with our regulators. We co-operate with valid requests from competent authorities. We narrowly limit our disclosure to what the request requires. We do not obstruct an investigation.
We are honest with each other. We tell each other the truth in good faith, including when the truth is uncomfortable. We disagree in writing, we record the decision, and we move forward together.
We are honest with ourselves. We do not pretend a control works when it does not. We surface defects, we measure their impact, and we remediate them on a published timeline.
3. We Do Not Give Or Accept Bribes
Maven Pay Inc. operates under a separate Anti-Bribery and Corruption policy that binds every member of staff and every counterparty acting on our behalf. The key commitments under that policy are these.
We do not give or accept bribes, secret commissions, kickbacks, or facilitation payments. The relevant statutes that govern us include the Canadian Corruption of Foreign Public Officials Act, the United States Foreign Corrupt Practices Act, and the United Kingdom Bribery Act.
We do not give or accept cash, high-value items, or items for personal consumption.
We may give and accept tokens of business hospitality of a normal and proportionate nature only when the item is not of significant value, is not intended to influence a decision or outcome, and is publicly given or received, and where the relevant internal control requires it, with management approval.
Where a customer, supplier, partner, or other counterparty offers a member of our team a prohibited gift or other inducement, the member of our team reports it to compliance@mavenpay.com.
4. We Protect Customer Money And Customer Data
Customer funds are held in segregated accounts at regulated institutions under the rules that apply to a Canadian Payment Service Provider and a Canadian Money Services Business. Customer balances are not lent, are not rehypothecated, and are not invested.
Customer data is handled under our Privacy Policy, our Data Processing Addendum, and the security programme published on the Maven Pay Trust Center at https://app.vanta.com/mavenpay.com/trust/lyjdri3s8ydg4qnc4uuq1.
5. We Do Not Discriminate
We do not refuse to serve a customer, decline a transaction, set a price, or restrict a feature on the basis of a protected characteristic. The characteristics we protect include race, ethnicity, ancestry, place of origin, citizenship, religion, creed, age, sex, sexual orientation, gender identity, gender expression, marital status, family status, disability, genetic information, political belief, and the other characteristics protected by the law of the jurisdictions where we serve.
We may decline to open an account, decline a transaction, or close an account on the basis of identity-verification, sanctions-screening, fraud, anti-money-laundering, counter-terrorism-financing, jurisdictional acceptance, or contractual grounds, as described in our Terms of Service, our Acceptable Use Policy, and our Country Acceptance framework. These grounds are not protected-characteristic grounds.
6. We Do Not Tolerate Harassment Or Retaliation
Every member of staff has the right to work free from harassment and discrimination. Every member of staff has the right to raise a concern without retaliation. A member of staff who raises a concern in good faith is protected against any adverse action that is connected to the act of raising the concern.
7. We Separate Duties
No single member of our team can take a customer through the full life cycle of the relationship without independent oversight from another member of the team. We segregate sales, onboarding, transaction monitoring, money movement, and customer-facing decisions across distinct roles. Privileged access to systems and data is granted on a need-to-know basis, is recorded, and is reviewed.
8. We Guard Against Conflicts Of Interest
Every member of staff declares conflicts of interest at the point they become aware of them. A declared conflict is managed by the relevant manager and by the Compliance Officer, including by recusal, by reassignment of the work, or by additional approval. Undeclared conflicts of interest are a breach of this Code.
9. We Do Not Insider-Trade Or Front-Run
Members of our team and members of their immediate household do not trade on material non-public information that they obtain through their work at MavenPay. Members of our team do not front-run customer transactions, do not piggyback on customer transactions, and do not use information about a customer's position for personal benefit.
10. We Commit To Accessibility
Accessibility is a standard, not an option. Our Accessibility Statement sets out the conformance target, how we test against it, and how to reach us when something does not work.
11. We Commit To Transparency On Corrections
When we make a mistake, we correct it, we tell the people who relied on the wrong information, and we publish the correction in line with our Corrections Policy and, for factual statements that may have misled the public, our Factual Correction Policy.
12. We Commit To The Law
Members of our team comply with the law that applies to them and to their work. Where the law of one jurisdiction conflicts with the law of another, members of our team escalate to the Compliance Officer for a documented resolution. Doubt is not a defence; ask before acting.
13. Reporting A Concern
If you are a member of our staff, a contractor, an adviser, a customer, a counterparty, or a member of the public, and you believe a member of our team or an entity acting on our behalf has breached this Code, you can report it confidentially to compliance@mavenpay.com.
We do not retaliate against a reporter who acts in good faith. We do not require a reporter to identify themselves. Where the law allows, we keep the reporter's identity confidential.
Where the breach concerns the Compliance Officer or the senior leadership of the company, the report is escalated to a member of the board who is independent of the matter, and the response is reviewed by an external counsel where appropriate.
14. Enforcement
A confirmed breach of this Code by a member of staff or a contractor may result in formal warning, additional training, removal from a role, financial recovery, dismissal, or referral to law enforcement, depending on the nature of the breach.
A confirmed breach by an entity acting on our behalf may result in remediation steps, suspension, or termination of the relationship.
We file the reports the law requires us to file. We publish anonymised summaries of enforcement outcomes annually where the law permits.
15. Governance Of This Code
The Code is owned by the Compliance Officer of Maven Pay Inc. It is reviewed at least once every twelve months. It is reviewed sooner when the business, the regulatory environment, or the risk profile materially changes. Material changes are approved by the senior leadership of the company and are communicated to every member of staff before they take effect.
16. Contact
For any question about this Code, write to compliance@mavenpay.com.
17. Changes To This Code
We may update this Code from time to time. When we make a material change, we will tell you in the MavenPay product or by email at least thirty days before the change takes effect. The current version of this Code and its effective date are shown at the top of this page.
