Code of Ethics
The values and principles that guide the activities of THE REAL MONEY and of anyone acting on its behalf · V0.2
Preamble
THE REAL MONEY is the trading name of TOGO INFINITY LIMITED, a company registered in Ireland. We operate as a multi-service platform offering our customers financial instruments, payment services, investments in physical gold, digital assets and personalized advice.
This Code of Ethics sets out the values, principles of conduct and responsibilities that guide the activities of THE REAL MONEY, its employees, collaborators, Gold advisors, suppliers and anyone acting in the name of or on behalf of the company (hereinafter collectively the "Recipients").
The Code of Ethics is not a formality in itself. It reflects the way THE REAL MONEY intends to conduct its business: with transparency, respect and responsibility towards customers, partners, the communities in which it operates and the environment.
This Code of Ethics is binding on all Recipients. Breach of its principles may give rise to disciplinary, contractual or legal consequences, depending on the nature of the relationship with THE REAL MONEY.
Our core values
Everything we do at THE REAL MONEY is built on five core values:
We always act honestly, consistently and in compliance with the rules.
We communicate clearly, fully and understandably.
We treat every person with dignity, fairness and consideration.
We accept the consequences of our actions and decisions.
We develop new solutions that respect both the rules and people.
Principles of conduct
The following principles apply to all Recipients, in any operating context and in any interaction with customers, colleagues, institutional partners and supervisory authorities.
2.1 Legality and regulatory compliance
Recipients operate in full compliance with the laws, regulations and provisions of the Supervisory Authorities applicable in every country where THE REAL MONEY operates, with particular reference to MiFID II, MiCAR, AMLD6, the GDPR, the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 and the Irish legislation in force. No commercial or economic consideration can justify a failure to comply with these regulations.
2.2 Honesty and fairness
Recipients must act honestly in all their professional relationships. No form of deception, manipulation, falsification of data or misleading communication with customers, colleagues, partners or authorities is tolerated. The information provided to customers must be accurate, complete, up to date and understandable.
2.3 Customer protection
The customer is at the center of every decision. Recipients always act in the customer's best interest, providing transparent information on products, risks and costs, and never placing the commercial interests of THE REAL MONEY or of the authorized intermediaries ahead of customer protection. When providing advisory services, Recipients strictly apply the suitability principles of the MiFID II Directive.
2.4 Conflicts of interest
Recipients must identify, manage and, where necessary, disclose to customers any potential conflict of interest that may arise in the course of their activity. Placing personal interests ahead of those of customers or of the business is prohibited. Recipients do not accept compensation, gifts or benefits from third parties that could influence their professional judgment, save where expressly authorized by company policy.
2.5 Confidentiality and data protection
Recipients treat information relating to customers, partners and the internal operations of THE REAL MONEY with the utmost confidentiality. Personal data is processed in accordance with the GDPR, the Data Protection Act 2018 (Ireland) and internal privacy policies. Confidential information may not be disclosed to unauthorized third parties or used for purposes other than those for which it was collected.
2.6 Prevention of money laundering and terrorist financing
Recipients actively cooperate in implementing THE REAL MONEY's AML/KYC/KYB procedures, immediately informing the Compliance Officer of any transaction or behavior that could constitute money laundering or terrorist financing. No Recipient may ignore, obstruct or delay the application of customer due diligence measures.
2.7 Fairness in marketing communications
THE REAL MONEY's commercial and marketing communications must be truthful, clear and not misleading. It is not permitted to overstate the potential return of a product while omitting the associated risks, or to use communication techniques that exploit the inexperience or vulnerability of the recipients. Communications relating to the Advisory Services and to digital assets must comply with the provisions of MiFID II and MiCAR on communications with customers.
2.8 Responsible use of technology
Recipients use the company's IT systems, technology platforms and data exclusively for legitimate business purposes. Unauthorized access to systems or data, the manipulation of records or logs, and the use of technology to circumvent compliance or security controls are prohibited. Recipients actively cooperate in implementing THE REAL MONEY's ICT risk management framework, immediately informing the Compliance Officer of any IT incident, vulnerability or anomaly detected in the course of their activities.
2.9 Digital Operational Resilience (DORA)
THE REAL MONEY operates in compliance with Regulation (EU) 2022/2554 (DORA) on digital operational resilience, applicable from 17 January 2025. Recipients must comply with the internal procedures adopted by THE REAL MONEY in implementing DORA, paying particular attention to:
- Immediately reporting to the Compliance Officer any ICT incident or vulnerability detected.
- Not sharing or exchanging system access credentials without authorization.
- Complying with the company's IT security policies.
- Cooperating in periodic operational resilience testing.
Breach of the internal ICT procedures is considered a breach of this Code of Ethics.
Relations with customers
Customers are the reason THE REAL MONEY exists. Our relations with them are built on trust, transparency and mutual respect.
3.1 Clarity and accessibility of information
THE REAL MONEY undertakes to give its customers clear, complete and accessible information on all the services available, including costs, fees, risks and contractual terms. Contractual and informational documents are drafted in plain, understandable language, avoiding unnecessary jargon.
3.2 Non-discrimination
THE REAL MONEY guarantees equal treatment to all customers, regardless of nationality, gender, age, religion, sexual orientation, disability or any other personal characteristic. Decisions concerning access to the Services are based exclusively on objective and legally sound criteria.
3.3 Protection of vulnerable customers
Recipients must be particularly careful when dealing with customers who may be vulnerable because of their age, financial situation, limited financial experience or personal difficulties. In such cases, the approach must be based on the utmost caution, clarity and the customer's best interest.
3.4 Complaint handling
Every complaint received is an opportunity to improve. THE REAL MONEY handles complaints promptly, impartially and transparently, in accordance with the procedure described in the "Complaint Handling Procedure" document, available on the Platform. Recipients may not obstruct or discourage customers from exercising their right to submit a complaint.
Relations with authorized intermediaries and partners
THE REAL MONEY works with a network of authorized intermediaries and partners, selected on the basis of soundness, reliability and regulatory compliance. Relations with these entities are based on the principles of fairness, loyalty and mutual respect for contractual obligations.
- THE REAL MONEY verifies that the authorized intermediaries hold the licenses and authorizations required by the applicable regulations in their country of establishment.
- THE REAL MONEY does not maintain relations with persons operating in breach of the applicable legislation, involved in money laundering, corruption or terrorist financing practices, or engaging in conduct contrary to the principles of this Code of Ethics.
- Recipients do not accept gifts, compensation or benefits from authorized intermediaries or other partners that could influence the operational or commercial decisions of THE REAL MONEY, beyond the limits set by company policy.
Working environment
5.1 Respect and dignity
THE REAL MONEY guarantees an inclusive and respectful working environment, free from any form of discrimination, harassment, intimidation or abuse. All Recipients have the right to work in an environment that respects their personal and professional dignity.
5.2 Equal opportunities
Decisions on hiring, promotion, training and remuneration are based exclusively on merit, skills and performance, without discrimination of any kind.
5.3 Health and safety
THE REAL MONEY undertakes to ensure safe working conditions that comply with the Safety, Health and Welfare at Work Act 2005 (Ireland) and the applicable health and safety regulations. Recipients actively cooperate in maintaining these conditions and immediately report any situation of risk.
5.4 Professional development
THE REAL MONEY invests in the continuous training of its employees, with particular attention to regulatory updates relating to MiFID II, MiCAR, anti-money laundering and data protection. Training is regarded as a fundamental tool for ensuring service quality and compliance with the regulations in force.
Anti-corruption and integrity in institutional relations
THE REAL MONEY adopts a policy of zero tolerance towards any form of corruption, bribery, fraud or unlawful conduct, in accordance with the Criminal Justice (Corruption Offences) Act 2018 (Ireland), European legislation and the international anti-corruption standards (OECD, FATF).
6.1 Absolute prohibitions
- Offering, promising, giving or accepting, directly or indirectly, money, gifts or any other advantage to public officials, supervisory authorities, employees of partners or third parties, in order to obtain preferential treatment or influence a decision.
- Making or receiving facilitation payments, even of small amounts.
- Using intermediaries, agents or consultants to indirectly circumvent the prohibitions in this Code.
- Falsifying or altering any document, accounting record or official communication.
- Taking part, even passively, in money laundering or terrorist financing practices.
6.2 Relations with the supervisory authorities
Relations with the competent Supervisory Authorities are based on the utmost cooperation, transparency and respect. Recipients provide the Authorities with accurate and complete information, within the time limits and in the formats required, without omissions or reservations.
Environmental, social and governance (ESG) responsibility
THE REAL MONEY recognizes the importance of sustainability as a fundamental aspect of its operations. Its commitment to ESG criteria is not a statement of principle: it translates into concrete operational decisions.
7.1 Environmental dimension
THE REAL MONEY undertakes to progressively reduce the environmental impact of its activities, favoring digital solutions that reduce paper consumption and the associated emissions, and assessing the environmental footprint of the blockchain technologies used in its digital asset services. As part of its Advisory Services, THE REAL MONEY integrates sustainability (ESG) preferences into the MiFID Profile, in compliance with European legislation (EU Regulation 2022/1288).
7.2 Social dimension
THE REAL MONEY undertakes to contribute to financial inclusion by making investment and savings tools in gold and digital assets accessible to a wider public through an intuitive, transparent and multilingual platform. THE REAL MONEY maintains an active policy of non-discrimination towards its customers and employees.
7.3 Governance dimension
THE REAL MONEY adopts clear governance structures, with a separation of responsibilities between the operational, compliance and supervisory functions. The Board of Directors oversees the effectiveness of this Code of Ethics and approves any amendments. The Compliance Officer monitors compliance with the Code and reports to the Board of Directors at least every six months.
Reporting breaches (Whistleblowing)
THE REAL MONEY actively encourages the reporting of conduct contrary to this Code of Ethics, to the applicable regulations or to company policies. Reports may concern the conduct of employees, contractors, Gold advisors, suppliers or any other person acting on behalf of THE REAL MONEY.
8.1 Reporting channels
| Channel | Reference | Notes |
|---|---|---|
| Dedicated platform | Whistleblowing section of The Real Money website | Reports may be made anonymously. |
| Confidential email | whistleblowing@therealmoney.com | Managed exclusively by the Compliance Officer. |
| Ordinary mail | THE REAL MONEY — Compliance Officer · Togo Infinity Limited · Block 4 Harcourt Centre, Harcourt Road · Dublin 2, Ireland, D02 HW77 | Sealed envelope marked "Confidential - Whistleblowing report". |
8.2 Protection of the reporting person
THE REAL MONEY guarantees the confidentiality of the identity of the reporting person in accordance with the Protected Disclosures (Amendment) Act 2022 (Ireland) and Directive 2019/1937/EU on whistleblowing. Any form of retaliation, discrimination or penalization against those who report in good faith is strictly prohibited.
Enforcement of the Code, controls and consequences of breaches
9.1 Responsibility for implementation
The Compliance Officer of THE REAL MONEY is responsible for overseeing the application of this Code of Ethics, handling reports of breaches and recommending the appropriate corrective measures to the Board of Directors. Each Recipient is responsible for complying with the Code in their own activities.
9.2 Training
THE REAL MONEY's employees and collaborators receive periodic training on the content of the Code of Ethics and the relevant regulations. This training is mandatory for all new Recipients and is updated whenever significant regulatory changes or revisions of the Code occur.
9.3 Consequences of breaches
Breach of this Code of Ethics may result, depending on the seriousness and nature of the conduct, in:
- For employees and collaborators: disciplinary measures, up to and including termination of the employment or collaboration relationship.
- For Gold advisors and agents: termination of the agency contract or of the services agreement.
- For suppliers and partners: termination of the commercial contract.
- In every case: a report to the competent authorities where the conduct constitutes a criminal or administrative offence.
Updating and revision of the Code
This Code of Ethics is subject to periodic review, at least annually, by the Compliance Officer, with the approval of the Board of Directors. These reviews take into account regulatory developments, the reports received through the whistleblowing channel and any critical issues arising in the handling of complaints.
The updated version of the Code of Ethics is always available in the "Code of Ethics" section of the THE REAL MONEY platform and is communicated to all Recipients within 30 days of its approval.
