Following the laws and regulations is not necessarily always the same as behaving to the highest standards of ethics. We, the “Fintech Forum, Sri Lanka” strive to become morally as well as professionally the flagman of the business sector. Although we are not obliged to establish our own ethics policy, we see it as our personal commitment to set guidelines for a clear, structured and transparent way to conduct our businesses at the highest standards of ethics.

With the continuous introduction of new and evolving forms of financial technologies, there comes the responsibility to transparency and devotion to professionalism, so we can ensure that all the stakeholders – our members, partners, customers and regulators – always fully understand the conducted processes in our business activities.

We believe that commitment to high standards is the key for our Members well as for the financial technology industry in general to reach new heights. Providing the best possible services to our customers, acting fair and respectful towards all the stakeholders, and continuously striving to improve ourselves. These values are the foundation for the businesses of our members.

This Code of Ethics of “Fintech Forum, Sri Lanka” (hereinafter: the “Code”) shall specify the relationships between the Association and its member Members (hereinafter: “Members”), between the Members among each other, as well as between the Members all other stakeholders – partners, customers and regulators. The purpose of this Code is not to supersede the existing legislation and regulations, but to supplement them.

This Code shall be a guideline for the Members and their employees on the minimum ethical standards which should always be preserved. The Members shall take appropriate means to communicate this code of ethics and conduct to their employees for them to understand and abide.

A Company can only undisputedly retain its membership in the Fintech Forum, if it meets these ethical standards.

When conducting business, it is essential to have a general standard for ethical behavior. The Companies’ business activities should always be based on commitment to transparency, professionality and integrity. In particular, Members shall comply with the following points.

• Focusing on the interests of customers as much as on the interests of the Members when carrying out business activities.
• Getting to know customers and conducting appropriate and proper customer identification procedures according to the local requirements.
• Basing the relations with customers on mutual loyalty, trust and long-term cooperation.
• Investing and caring about their employees being qualified, polite and attentive, and properly performing their functions.
• Working towards the management being qualified regarding the financial market, the applicable regulatory framework, strategic business planning and risk management.
• Seeking that the IT systems for providing the services, as well as other systems used would function properly and uninterruptedly.
• Establishing and retaining a good reputation. For a good reputation of a Company, all circumstances are taken into account, including all the conduct of the Company and whether it leaves no doubt about the Company’s sound and prudent management.
• Devoting sufficient time and effort to each business activity.
• Establishing sound and proper relations with the government.

Commit to continuous learning and professional development to stay abreast of industry trends, technological advancements, and regulatory changes.

Share knowledge and expertise with fellow members, contributing to the collective growth and advancement of the fintech industry.

Use technology and data responsibly, ensuring compliance with data protection regulations and safeguarding the privacy and security of user information.

Implement robust cybersecurity measures to mitigate the risk of data breaches or unauthorized access.

Take responsibility for one’s actions and their consequences, acknowledging mistakes and taking corrective measures when necessary. 

Resolve disputes and conflicts in a constructive and respectful manner, seeking mediation or arbitration if required. 

The Members shall show commitment to strictly comply with all relevant laws and regulations, nationally and internationally. Furthermore, the following aspects shall be emphasized: 

• When operating internationally, the Members shall respect and pay close attention to the respective laws and regulations of other jurisdictions which might be applicable for that specific business activity. The Members shall comply with the law everywhere they operate. 

• The Members shall thoroughly take care about complaints. They should review complaints by following all regulatory requirements. They should diligently deal with complaints and provide an answer to the customer. The Members shall have a publicly accessible procedure for handling these complaints. 

• For the purpose of financial services, the Members may be trusted with sensible personal and financial information by their customers. Therefore, the Members shall ensure the security of their customers confidentiality and data by developing adequate information safety procedures and measures. These procedures and measures shall always comply with the newest and highest technical standards and regulatory requirements. 

• Crimes like corruption, money laundering, terrorism financing and other illegal activity shall be prevented and reported to the relevant authorities. Other crimes related to the Members as well as bankruptcy, insolvency, or customer protection shall be observed and prevented. 

• The Members ensure compliance with the contracts they conclude with customers. 

• All Members must inform Fintech Forum, if legally possible, as soon as they learn that they are the subject of criminal or possible criminal proceedings, or other proceedings and investigations by regulatory authorities. 

The Members shall establish an internal management structure that allows to ensure these outlined points related to legal compliance. 

The Members shall treat each other fair and respectful. It should be aimed to conduct a fair competition which is just, open and equitable. Also, the competition should be based on factors of price, quality and service, and not based on practices that are condemned by the public or by law. The Members shall not harm each other’s ability to compete. Further, they shall not conduct any actions which result in reputational or any other kind of harm to another Company. The Members may gather information about their competitors, but only in a legal and ethical manner. The Members shall respect the confidential information of their competitors. 

The Members shall strive to establish best practice for their respective business fields. Best practice means using the business methods which are generally accepted as superior to any alternatives. The Members shall use all the knowledge and technology at their disposal to ensure they reach the best possible practice. 

The Members shall furthermore strive to constantly improve their technology, business models and methods, concepts and service. They should be devoted to constantly and diligently raise the overall quality of their businesses, so they will be able to provide always the best possible service to their customers. 

The Members also ensure that the conditions of the contracts they provide to their customers are the result of approved standards and at least good financial business practice. 

Conducting business with suppliers and vendors is a necessary and crucial aspect for most Members. Also here ethical standards should be respected. The Members shall strive to only engage in business relations with suppliers and vendors which comply themselves with ethical standards similar to those outlined in this Code. 

In case a certain business activity with a supplier or vendor would result in an inconsistency with the Code, and this inconsistency could not be avoided, the Member shall disclose this to the board to take appropriate action. 

The Members shall ensure that no employee takes part in a business activity where the employee is subject to a conflict of interest. Conflict of interest means a situation, where private interests of an employee contradict the professional interests of his company or a client. Such a conflict might arise if an employee has financial or other interests which might impair his professional judgement or objectivity when conducting activities for the company. 

In case there are uncertainties whether a conflict of interest might be imminent, the Members should ask the Association for consultation. 

We believe that honest and meaningful cooperation between the Members is crucial to promote progress in the financial technology industry. The Members shall conduct an exchange of information about developments, trends and news in the financial technology sector, as well as an exchange of experience between each other on a regular basis. 

Further, the Members should also strive to establish such a mutual share of information and experience with financial technology Members outside Fintech Forum. . As well, a broader cooperation with stakeholders, associations and international partners in the financial technology industry should be sought-after. 

The Members shall do everything possible to enable an easy and efficient cooperation with the Central Bank of Sri Lanka, the government, and other regulatory and supervisory institutions. 

The Members shall communicate with the public by disclosing business and other information actively and honestly. We strive to promote understanding and trust of society through a constructive dialogue with a wide variety of surrounding stakeholders. 

The Members shall provide the customers with various types of information that are necessary for making rational decisions related to the business with the Members. Furthermore, they shall make sure that the customers would always have access to the necessary and relevant, information about all services provided by the Members. The Members shall comprehensively inform customers about their rights and obligations, benefits and possible risks related with the Members’ suggested products or services. 

All the provided information should be clear, honest and complete. 

The Members shall ensure equal employment conditions for all their employees. Employees shall be treated with respect, dignity and fairness. Decisions regarding employees shall only be made on grounds of professional and objective eligibility and individual merit. No employee shall be treated differently because of ethnicity, gender, religion, sexual orientation or other personal characteristics protected by law. The Members shall take the appropriate steps to prevent unequal or discriminatory treatments of any kind. 

The Members shall aim to create a favorable business environment for all interested groups of people. This includes pursuing to protect the rights of the disabled and establish inclusive measures. 

The Members shall stay politically neutral and not support or make contributions to political parties or candidates. The employees of the Members may get involved into political activities but may only do so only in their private time. The employees shall not use any of the Members’ funds and means for their political involvement.  

The Members shall represent the Fintech Forum, Sri Lanka, with professionalism and integrity in all external engagements and communications and refrain from making statements or commitments on behalf of the forum without authorization from the Board of Directors. 

Every employee, supplier, business partner, client or any other person connected to the Members shall always promptly report possible violations of the Code or of the law. If an employee of a Member becomes aware of a situation which might lead to, or could already constitute, a violation of the code, he has the duty to contact the responsible office. If a situation arises where it’s unclear whether there actually is a violation of the Code, it is always appropriate to inform the responsible office, so the situation can be assessed. 

The report can be made online, via e-mail, phone, or in a personal meeting with the respective responsible person, e.g. the respective line manager. It is not required to provide the name or other identifying information when filing a report, but it is encouraged to provide as much information as possible, which might help to resolve the situation. The provided information will be kept confidential and only used to resolve the situation. Every reported possible violation will be investigated promptly and duly. 

Fintech Forum does not allow any form of retaliation against individuals, who reported possible violations in good faith. 

Violations of this Code will be subject to disciplinary action. These disciplinary actions are including and reach up to the revocation of the membership status of a Member from Fintech Forum. 

By adhering to this code of conduct, members of the Fintech Forum, Sri Lanka, contribute to the establishment of a vibrant, ethical, and sustainable fintech ecosystem in the country.