Confidentiality & Insider Information

Purpose

This policy underscores VeriFee’s commitment to protecting sensitive information belonging to clients, employees, vendors, and the company itself. It sets forth the standards for confidentiality, privacy, and handling of material nonpublic information, ensuring compliance with ethical practices and applicable laws.

Scope

This policy applies to all employees, contractors, vendors, and third-party partners engaged with VeriFee.

1. Non-Disclosure Commitment

VeriFee treats all information shared by clients as confidential under a non-disclosure framework. This approach aligns with our principle of operating as though under a mutual NDA with every client.

• Confidential Information Definition: Includes but is not limited to client details, processing statements, negotiated terms, operational strategies, financial data, and proprietary methodologies.
• Obligations:
  • Information must not be shared, disclosed, or utilized for purposes outside the agreed service scope.
  • Data must be safeguarded against unauthorized access, and any breaches must be reported immediately to VeriFee’s Data Protection Officer.

2. Privacy Policy Alignment

Our handling of personal and client data adheres strictly to our Website Privacy Policy:

• Information collected from clients and vendors is used solely to deliver services or as described in our Privacy Policy.
• Prohibited Activities:
  • Selling or sharing personal or client data to third parties for marketing or other purposes.
  • Using data beyond the scope of agreed services.
• Data Security: VeriFee implements robust technical and organizational measures, including encryption and regular audits, to ensure data protection.

3. Insider Trading and Material Nonpublic Information

Employees and affiliates are treated as covered persons for all material nonpublic information (MNPI), including financial performance data and potential transactions.

• Definition of MNPI: Revenue figures, savings benchmarks, client acquisition details, and pending service innovations.
• Prohibited Actions:
  • Using MNPI to trade securities.
  • Sharing MNPI with any individual or entity not bound by this policy.
• Acknowledgment:
  • Employees are required to sign an acknowledgment of adherence to insider trading laws and VeriFee’s policies.

4. Alignment with Service Agreements

This policy supports and complements VeriFee’s Service Agreement provisions. In cases where client information, such as names or logos, is used for marketing purposes, VeriFee ensures this is done:

• In compliance with explicit permissions granted under the Service Agreement.
• Without compromising sensitive or nonpublic aspects of the client’s operations, financial details, or proprietary data.
• Transparently, with clients being informed of how their names or logos will be presented and for what purposes.

If any conflicts arise between this policy and the Service Agreement, the terms of the Service Agreement will take precedence. However, VeriFee commits to notifying clients promptly and working collaboratively to address any concerns related to the usage of their names or logos.

5. Policy Enforcement

• Audits and Monitoring: VeriFee conducts regular checks to ensure compliance with this policy.
• Violations:
  • Breaches may result in disciplinary action, including termination of engagement or legal action.
  • Vendors found in violation risk immediate contract termination and potential legal repercussions.

6. Reporting and Contact

Employees and partners must report suspected violations to the Compliance Team at legal @verifee.com