1. Commitment to Compliance
Cryptobarrel UAB (“Cryptobarrel” or the “Company”) is committed to conducting its business in full compliance with applicable laws, regulations, and recognized industry standards. The Company maintains internal policies and procedures designed to support responsible business conduct, operational integrity, and effective risk management.
Cryptobarrel operates as a software development company and does not provide financial services, crypto-asset services, or services to end users. Nevertheless, the Company recognizes the importance of maintaining robust compliance and governance standards in all aspects of its operations.
2. Ethical Business Conduct
Cryptobarrel conducts its business in accordance with the highest standards of honesty, transparency, fairness, and accountability. The Company is committed to maintaining a culture of integrity across all areas of its operations and decision-making processes. Cryptobarrel expects its employees, contractors, and business partners to act in a responsible and ethical manner, to comply with applicable laws and regulations, and to adhere to the Company’s internal policies and professional standards.
The Company maintains a zero-tolerance approach to fraud, corruption, bribery, conflicts of interest, and any other form of unlawful, unethical, or improper conduct. Cryptobarrel does not permit any activity that could compromise its integrity, reputation, or compliance with applicable legal and regulatory requirements.
To support these principles, Cryptobarrel has implemented internal controls, policies, and procedures designed to prevent, detect, and respond to misconduct or inappropriate behavior. These measures include defined roles and responsibilities, internal oversight mechanisms, and processes for identifying and addressing potential risks. The Company takes appropriate action where violations are identified and seeks to continuously strengthen its compliance and governance framework.
Cryptobarrel also expects its business partners and service providers to uphold comparable standards of integrity and ethical conduct when working with or on behalf of the Company.
3. Anti-Financial Crime Commitment
Although Cryptobarrel does not provide services to end users, does not operate customer accounts, and does not hold or manage customer funds, the Company is committed to supporting the prevention of financial crime, fraud, corruption, money laundering, terrorist financing, and the misuse of technology for unlawful purposes.
Cryptobarrel recognizes the importance of maintaining appropriate safeguards to ensure that its business operations, systems, and infrastructure are not knowingly used in connection with illegal or prohibited activities. The Company applies internal policies, risk awareness measures, and governance controls designed to support compliance with applicable anti-money laundering and counter-terrorist financing (“AML/CTF”) principles, to the extent relevant to its business activities as a software development company.
Cryptobarrel maintains internal procedures aimed at promoting ethical conduct, preventing misuse of corporate resources, and identifying potential risks associated with its business relationships and operational environment.
The Company remains committed to maintaining a compliance-focused culture and continuously strengthening its internal controls to align with evolving legal, regulatory, and industry expectations.
4. Corporate Governance and Internal Controls
Cryptobarrel UAB maintains internal governance, compliance, and control structures appropriate to the nature, scale, and complexity of its business activities. The Company is committed to operating in a well-controlled and transparent manner, supported by clearly defined roles, responsibilities, and oversight mechanisms.
Cryptobarrel has established internal policies and procedures designed to promote ethical conduct, ensure accountability, and support the effective management of operational and compliance risks. These policies address areas including professional conduct and ethical standards, access to systems and information, risk awareness and mitigation, and employee responsibilities.
The Company implements internal access controls to help ensure that access to systems, data, and corporate resources is granted based on business need and appropriate authorization. Cryptobarrel also applies governance measures designed to protect the integrity, confidentiality, and availability of its systems and information.
Employees and contractors are expected to comply with the Company’s internal policies and applicable legal and regulatory requirements. Cryptobarrel promotes accountability by defining responsibilities and expectations for personnel and by maintaining appropriate internal oversight.
Cryptobarrel periodically reviews and updates its governance framework and internal controls to ensure their continued effectiveness and alignment with evolving business, regulatory, and industry requirements.
5. Employee Integrity and Awareness
Cryptobarrel UAB recognizes that its personnel play a critical role in maintaining the Company’s integrity, security, and compliance standards. The Company expects its employees and contractors to conduct themselves in a professional, responsible, and ethical manner at all times and to act in accordance with applicable laws, regulations, and internal policies.
All personnel are required to understand and comply with the Company’s internal rules, including those relating to ethical conduct, information security, confidentiality, and the appropriate use of corporate systems and resources. Cryptobarrel expects its personnel to exercise sound judgment and to avoid any conduct that could expose the Company to legal, regulatory, security, or reputational risks.
The Company promotes awareness of compliance, security, and ethical responsibilities within its organization through internal communication, guidance, and organizational practices. Cryptobarrel seeks to foster a culture of integrity, accountability, and respect for legal and regulatory requirements.
Cryptobarrel also expects its personnel to promptly report any suspected violations of applicable laws, regulations, or internal policies in accordance with the Company’s internal procedures.
6. Information Security and Compliance Framework
Cryptobarrel UAB operates under an Information Security Management System (“ISMS”) aligned with the international standard ISO/IEC 27001. This framework supports the Company’s commitment to maintaining the confidentiality, integrity, and availability of its information, systems, and operational processes.
The Company’s information security framework includes policies, procedures, and technical and organizational measures designed to protect information assets against unauthorized access, loss, misuse, alteration, or disruption. These measures support the secure development, operation, and maintenance of the Company’s systems and infrastructure.
Cryptobarrel applies security and access control principles appropriate to its business activities, including defined responsibilities, controlled access to systems and information, and safeguards intended to reduce operational and security risks.
The Company regularly reviews and improves its information security and compliance framework to ensure continued alignment with applicable legal requirements, industry standards, and evolving business needs.
Cryptobarrel’s Information Security Management System forms an integral part of its overall governance, risk management, and compliance approach.
7. Whistleblowing and Reporting Concerns
Cryptobarrel UAB encourages its employees, contractors, and business partners to report, in good faith, any suspected violations of applicable laws, regulations, internal policies, or ethical standards. The Company recognizes the importance of maintaining an open and accountable environment where concerns can be raised responsibly.
Reports may relate to, for example, suspected misconduct, unethical behavior, fraud, security incidents, misuse of company resources, or other activities that may pose legal, regulatory, or reputational risks to the Company.
Reports may be submitted to the Company via email at: ofni@oi.lerrabotpyrc
Cryptobarrel treats all reports appropriately, confidentially, and in accordance with applicable laws and internal procedures. The Company does not tolerate retaliation against individuals who report concerns in good faith.
Where appropriate, Cryptobarrel will review reported concerns and take reasonable steps to address any identified issues.
8. Continuous Improvement
Cryptobarrel UAB is committed to continuously improving its compliance, ethics, governance, and risk management practices to ensure their effectiveness and alignment with evolving legal, regulatory, and industry requirements.
The Company recognizes that maintaining strong governance and compliance standards requires ongoing attention, evaluation, and enhancement. Cryptobarrel therefore periodically reviews its internal policies, procedures, and control measures to ensure they remain appropriate for the nature and scale of its business activities.
Cryptobarrel also considers developments in applicable laws, industry standards, and best practices when assessing and improving its internal framework. Where appropriate, the Company implements updates and improvements to strengthen its compliance, security, and operational resilience.
This commitment to continuous improvement supports Cryptobarrel’s objective of maintaining a responsible, secure, and well-governed business environment.