Compliance Policy

This Compliance Policy is effective dated: June 01, 2024

Control Document: GEF-PP-014, Ver. 1.0

Purpose

The purpose of this Compliance Policy is to establish a framework for ensuring that galaxefi (“Company”) complies with all applicable laws, regulations, standards, and internal policies. This policy aims to promote ethical conduct, prevent legal and regulatory violations, and maintain the Company’s reputation and integrity.

Scope

This policy applies to all employees, contractors, vendors, and other stakeholders who interact with the Company or on behalf of the Company. It covers all areas of operation, including but not limited to:

  • Business practices
  • Financial transactions
  • Data privacy and security
  • Employment and labor practices
  • Environmental regulations

Definitions

  • Compliance: Adherence to laws, regulations, standards, and internal policies.
  • Regulatory Authorities: Government agencies and other bodies that enforce laws and regulations applicable to the Company.
  • Internal Policies: Rules and guidelines established by the Company to govern its operations and conduct.

Compliance Objectives

The Company aims to achieve the following compliance objectives:

  • Ensure adherence to all applicable laws, regulations, and standards.
  • Promote ethical conduct and prevent misconduct.
  • Identify, assess, and mitigate compliance risks.
  • Foster a culture of compliance and integrity.
  • Maintain transparency and accountability in all business activities.

Compliance Objectives

Compliance Officer

  • Appoint a Compliance Officer responsible for overseeing the implementation and enforcement of the Compliance Policy.
  • The Compliance Officer will act as the primary point of contact for all compliance-related matters and inquiries.

Policies and Procedures

  • Develop, implement, and maintain comprehensive policies and procedures to ensure compliance with applicable laws and regulations.
  • Regularly review and update policies and procedures to reflect changes in legal requirements and business operations.

Training and Awareness

  • Provide regular compliance training to all employees and stakeholders to ensure they understand their responsibilities and the importance of compliance.
  • Conduct awareness programs to promote ethical conduct and compliance with Company policies.

Risk Assessment

  • Conduct regular risk assessments to identify and evaluate potential compliance risks.
  • Implement appropriate controls and mitigation strategies to address identified risks.

Monitoring and Reporting

  • Establish mechanisms for monitoring compliance with laws, regulations, and internal policies.
  • Encourage employees and stakeholders to report any suspected violations or concerns through designated reporting channels.
  • Ensure that reports of non-compliance are investigated promptly and thoroughly.

Audits and Reviews

  • Conduct regular internal audits and reviews to assess the effectiveness of the compliance program and identify areas for improvement.
  • Engage external auditors as necessary to provide independent assessments of compliance practices.

Reporting and Investigation

  • Employees and stakeholders are encouraged to report any suspected violations of laws, regulations, or Company policies.
  • Reports can be made confidentially and without fear of retaliation through the following channels:
  • The Compliance Officer will ensure that all reports are investigated promptly and that appropriate corrective actions are taken.

Consequences of Non-Compliance

  • Non-compliance with laws, regulations, or Company policies may result in disciplinary action, up to and including termination of employment or contract.
  • The Company will cooperate with regulatory authorities in investigations and may report non-compliance as required by law.

Roles and Responsibilities

  • Compliance Officer: Responsible for overseeing the compliance program, providing guidance, and ensuring adherence to this policy.
  • Management: Responsible for promoting a culture of compliance and ensuring that their teams understand and follow applicable laws and policies.
  • Employees and Stakeholders: Responsible for understanding and adhering to this policy and reporting any suspected non-compliance.

Policy Review and Updates

  • This policy will be reviewed annually and updated as necessary to ensure its effectiveness and alignment with legal and regulatory requirements.
  • Changes to this policy will be communicated to all employees and stakeholders.

Quick Contact

By adhering to this Compliance Policy, galaxefi commits to conducting its business with integrity, transparency, and accountability, ensuring compliance with all applicable laws and regulations. For questions or concerns about this Policy, please use the following form: