Compliance, Legal and Regulatory*

This website services various legal entities that market services under the “Corpay” brand in various jurisdictions. Your services may be provided by one or several of the legal entities listed below. Corpay is a worldwide payments provider for businesses and includes:

For Corpay and Comdata Mastercard related products:

The Corpay and Comdata Mastercard is issued by Regions Bank, pursuant to a license by Mastercard International Incorporated. MasterCard, Cirrus and Maestro are registered trademarks of MasterCard International Incorporated.

1. Comdata Inc., d/b/a Corpay (“Corpay”), offers to cardholders and account administrators (each a “User”), through a third-party service provider, a messaging service whereby such Users may receive certain account and transaction related messages (“Account Messages”), Marketing Messages (as defined below), and send certain request messages via email and/or SMS text messaging (the “Messaging Services”). These Terms and Conditions apply to User’s use of the Messaging Services.
2. By subscribing to the Messaging Services, User agrees to these Terms and Conditions as such Terms and Conditions may be amended or modified from time to time by Corpay in its sole discretion. Continued use of the Messaging Services after User has been notified of a change in the Terms and Conditions shall be deemed an acceptance of such new Terms and Conditions by User.
3. In accordance with the foregoing, User acknowledges, consents and agrees, that User wishes to receive the Messaging Services for the telephone number provided by User through an enrollment method made available by or on behalf of Corpay. User acknowledges and agrees that, as part of the receipt of the Messaging Services, that Users consents to receive marketing information, product feature information, services solicitations, and to receive offers for products, services, or promotions from Corpay (collectively, “Marketing Messages”).
4. I authorize Corpay, and its affiliates and service providers, to contact me via text message (SMS) at the phone number that I have provided using automated dialer technology and other methodologies, and authorize the delivery of Account Messages and Marketing Messages to such phone number.
5. Corpay may, in its sole discretion, terminate or suspend access to the Messaging Services or any portion thereof at any time and with respect to any User.
6. User is not required to provide consent or enroll in this Messaging Service as a condition of purchasing goods or services from Corpay. User may terminate the services at any time by texting “STOP” to 84234 or by contacting customer service via the phone number on the back of your card. User will receive a message confirming the termination of the Messaging Services and will receive no further messages.
7. User may text “HELP” to 84234 for help in using the Messaging Services.
8. If you are a cardholder with cardholder terms and conditions applicable to the use of your card issued by or on behalf of Corpay, these Terms and Conditions control your use of the Messaging Services to the extent there is a conflict with your cardholder terms. For corporate or fleet account administrators or other employees, these Terms and Conditions control your use of the Messaging Services to the extent there is a conflict with the card agreement your company has entered into with Corpay.
9. Eligibility. User must be a Corpay cardholder or an authorized account administrator for a Corpay card account to access the Messaging Services.
10. Costs and Expenses. Carrier Msg and Data Rates may apply and there may be third party costs and expenses associated with using the Messaging Services. For example, User may incur charges from its internet service provider with respect to email messages sent or received through the Messaging Services, or from its mobile service provider with respect to SMS text messages sent or received through the Messaging Services. Corpay shall not be responsible for any charges incurred by User related to the use of the Messaging Services.
11. Restrictions on Use. User shall not use the Messaging Services in or for any illegal, fraudulent, unauthorized or improper manner or purpose and will only use the Messaging Services in compliance with all applicable laws, rules and regulations, including all applicable state, federal, and international Internet, data, telecommunications, telemarketing, “spam,” and import/export laws and regulations, including the U.S. Export Administration Regulations.
12. Warranty Disclaimer. CORPAY AND ITS THIRD PARTY PROVIDER PROVIDE THE MESSAGING SERVICES “AS IS” WITH NO WARRANTIES OF ANY KIND. CORPAY AND ITS THIRD PARTY SERVICE PROVIDER EXPRESSLY DISCLAIMS ANY WARRANTY, EXPRESS OR IMPLIED, REGARDING THE MESSAGING SERVICES, INCLUDING ANY IMPLIED WARRANTY OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, NON- INFRINGEMENT, OR THAT THE MESSAGING SERVICES WILL BE SECURE, UNINTERRUPTED OR FREE OF ERRORS, VIRUSES OR OTHER HARMFUL COMPONENTS.
13. Limitation of Liability. UNDER NO CIRCUMSTANCES WILL CORPAY OR ITS AFFILIATES AND ITS THIRD PARTY SERVICE PROVIDER, OR THEIR RESPECTIVE EMPLOYEES, OFFICERS AND DIRECTORS BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL OR CONSEQUENTIAL DAMAGES THAT RESULT FROM THE USE OR INABILITY TO USE THE MESSAGING SERVICES, INCLUDING BUT NOT LIMITED TO RELIEANCE ON ANY INFORMATION OBTAINED THROUGH THE MESSAGING SERVICE, OR THAT RESULT FROM MISTAKES, OMISSIONS, INTERRUPTIONS, DELETION OF FILES OR EMAIL, LOSS OF OR DAMAGE TO DATA, ERRORS, DEFECTS, VIRUSES, DELAYS IN OPERATION OR TRANSMISSION, OR ANY FAILURE OF PERFORMANCE, WHETHER OR NOT CORPAY HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
14. If User is dissatisfied with the Messaging Services or with these Terms and Conditions, User’s sole and exclusive remedy is to discontinue using the Messaging Services. User acknowledges by its use of the Messaging Services and acceptance of these Terms and Conditions that use of the Messaging Services is at User’s sole risk.
15. Indemnity. User, and with respect to authorized corporate account administrators, Corpay’s client, agrees to indemnify, defend and hold harmless Corpay, its affiliates and its third party service provider, and their respective employees, officers and directors, from and against any and all claims, liabilities, penalties, settlements, judgments, fees (including reasonable attorneys’ fees) arising from (i) any content that User or anyone using User’s account may submit or transmit using the Messaging Services, (ii) User’s use of the Messaging Services, (iii) User’s violation of these Terms and Conditions, and (iv) any violation of failure by User to comply with all laws and regulations in connection with the Messaging Services.
16. SMS Text Messaging. For SMS Text Messaging, Corpay, through its third party provider, supports the following carriers: AT&T, Sprint, T-Mobile, Verizon Wireless, Boost, Cricket, MetroPCS, U.S. Cellular, Virgin Mobile, ACS Wireless, Appalachian Wireless, Bluegrass Cellular, Carolina West Wireless, Cellcom, C-Spire Wireless (formerly Cellsouth), Cellular One of East Central Illinois, Cincinnati Bell Wireless, Cross (dba Sprocket), Duet IP, Element Mobile, EpicTouch, GCI Communications, Golden State, Hawkeye (Chat Mobility), Hawkeye (NW Missouri Cellular), Illinois Valley Cellular, Immix (Keystone Wireless / PC Management), Inland Cellular, iWireless, Mobi PCS (Coral Wireless LLC), Mosaic, MTPCS / Cellular One (Cellone Nation), Nex-Tech Wireless, nTelos, Panhandle Telecommunications, Peoples Wireless, Pioneer, Plateau, Revol Wireless, Rina - Custer, Rina - All West, Rina - Cambridge Telecom Coop, Rina - Eagle Valley Comm, Rina - Farmers Mutual Telephone Co, Rina - Nucla Nutria Telephone Co, Rina - Silver Star, Rina - South Central Comm, Rina - Syringa, Rina - UBET, Rina - Manti, South Canaan / CellularOne of NEPA, Thumb Cellular, Union Wireless, United, Viaero Wireless, West Central Wireless, Leaco, Nemont/Sagebrush. T-Mobile is not liable for delayed or undelivered messages.

17. Waiver of Jury Trial; Binding Arbitration. User or Corpay may, without the other’s consent, elect mandatory, binding arbitration for any claim, dispute, or controversy between or among such parties arising from or in any way relating to these Terms and Conditions, the Account Messages, the Marketing Messages, the Messaging Service, or the relationship of such parties, including without limitation claims regarding the application, enforceability, or interpretation of these Terms and Conditions and this arbitration provision, and no matter what legal theory such claims are based on or what remedy (damages, or injunctive or declaratory relief) such claims seek (a “Claim”). The party filing for arbitration must choose one of the following arbitration firms and follow its rules and procedures for initiating (including paying the filing fee) and pursuing arbitration before a single neutral arbitrator: American Arbitration Association, National Arbitration Forum, or JAMS. All other fees will be allocated as provided by the rules of the arbitration firm and applicable law.

    Can User assert or participate in a class action? To accommodate the right to arbitrate, User agrees that User will neither assert, nor participate in, a class action or other representative action or proceeding related to these Terms and Conditions, the Account Messages, the Marketing Messages, the Messaging Service or any other aspect of User’s relationship with Corpay. Claims must be brought in the name of an individual person or entity and must proceed on an individual (non-class, non-representative) basis.

    Who can be a party? The arbitrator will not award relief for or against anyone who is not a party. If User or Corpay requires arbitration of a Claim, neither User, Corpay, nor any other person may pursue the Claim in arbitration as a class action, private attorney general action or other representative action, nor may such Claim be pursued on your or our behalf in any litigation in any court. Claims, including assigned Claims, of two or more persons may not be joined or consolidated in the same arbitration. However, applicants, co-applicants, authorized users on a single account and/or related accounts, or corporate affiliates are here considered as one person.

    What Claims are subject to arbitration? All Claims relating to these Terms and Conditions, the Account Messages, the Marketing Messages, the Messaging Service, or our relationship are subject to arbitration, including Claims regarding the application, enforceability, or interpretation of this Agreement and this arbitration provision. All Claims are subject to arbitration, no matter what legal theory they are based on or what remedy (damages, or injunctive or declaratory relief) they seek. This includes Claims based on contract, tort (including intentional tort), fraud, agency, User or Corpay’s negligence, statutory or regulatory provisions, or any other sources of law; Claims made as counterclaims, cross-claims, third-party claims, interpleaders or otherwise; and Claims made independently or with other claims. A party who initiates a proceeding in court may elect arbitration with respect to any Claim advanced in that proceeding by any other party. Claims and remedies sought as part of a class action, private attorney general or other representative action are subject to arbitration on an individual (non-class, non- representative) basis, and the arbitrator may award relief only on an individual (non-class, non-representative) basis.

    Whose Claims are subject to arbitration? Not only Corpay’s and User’s, but also Claims made by or against anyone connected with Corpay or User or claiming through Corpay or User, such as any user of User’s telephone or card account, including without limitation, an employee, agent, representative, affiliated company, predecessor or successor, heir, assignee, or trustee in bankruptcy.

    What time frame applies to Claims subject to arbitration? Claims arising in the past, present, or future, including Claims arising before the opening of your account, are subject to arbitration.

    Broadest interpretation. Any questions about whether Claims are subject to arbitration shall be resolved by interpreting this arbitration provision in the broadest way the law will allow it to be enforced. This arbitration provision is governed by the Federal Arbitration Act (the “FAA”).

    What about Claims filed in Small Claims Court? Claims filed in a small claims court are not subject to arbitration, so long as the matter remains in such court and advances only an individual (non-class, non-representative) Claim.

    How does a party initiate arbitration? The party filing an arbitration must choose one of the following three arbitration firms and follow its rules and procedures for initiating and pursuing an arbitration: American Arbitration Association, JAMS, and National Arbitration Forum. Any arbitration hearing that User attends will be held at a place chosen by the arbitration firm in the same city as the U.S. District Court closest to User’s then current billing address, or at some other place to which User and Corpay agree in writing. User may obtain copies of the current rules of each of the three arbitration firms and forms and instructions for initiating arbitration by contacting them as follows: American Arbitration Association, 335 Madison Avenue, Floor 10, New York, NY 10017-4605 Web site: www.adr.orgl JAMS, 1920 Main Street, Suite 300, Irvine, CA 92610 Web site: www.jamsadr.com; National Arbitration Forum, P.O. Box 50191, Minneapolis, MN 55405 Web site: www.arbitration-forum.com. At any time User or Corpay may ask an appropriate court to compel arbitration of Claims, or to stay the litigation of Claims pending arbitration, even if such Claims are part of a lawsuit, unless a trial has begun or a final judgment has been entered. Even if a party fails to exercise these rights at any particular time, or in connection with any particular Claims, that party can still require arbitration at a later time or in connection with any other Claims.

    What procedures and law are applicable in arbitration? A single, neutral arbitrator will resolve Claims. The arbitrator will be either a lawyer with at least ten years of experience or a retired or former judge, selected in accordance with the rules of the arbitration firm. The arbitration will follow procedures and rules of the arbitration firm in effect on the date the arbitration is filed unless those procedures and rules are inconsistent with these Terms and Conditions, in which case these Terms and Conditions will prevail. Those procedures and rules may limit the discovery available to User or Corpay. The arbitrator will take reasonable steps to protect confidential information if requested to do so by User or Corpay. The arbitrator will apply applicable substantive law consistent with the FAA and applicable statutes of limitations, will honor claims of privilege recognized at law, and will have the power to award to a party any damages or other relief provided for under applicable law. User or Corpay may choose to have a hearing and be represented by counsel. The arbitrator will make any award in writing and, if requested by User or Corpay, will provide a brief statement of the reasons for the award. An award in arbitration shall determine the rights and obligations between the named parties only, and only in respect of the Claims in arbitration, and shall not have any bearing on the rights and obligations of any other person, or on the resolution of any other dispute.

    Who pays? Whoever files the arbitration pays the initial filing fee. If Corpay files, Corpay pays; if User files, User pays, unless User gets a fee waiver under the applicable rules of the arbitration firm. If User has paid the initial filing fee and User prevails, Corpay will reimburse User for that fee. All fees will be allocated as provided by the rules of the arbitration firm and applicable law. However, Corpay will advance or reimburse User’s fees if the arbitration firm or arbitrator determines there is good reason for requiring Corpay to do so, or if User asks us and Corpay determines there is good reason for doing so. Each party will bear the expense of that party’s attorneys, experts, and witnesses, and other expenses, regardless of which party prevails, but a party may recover any or all expenses from another party if the arbitrator, applying applicable law, so determines.

    When is an arbitration award final? The arbitrator’s award is final and binding on the parties unless a party appeals it in writing to the arbitration firm within fifteen days of notice of the award. The appeal must request a new arbitration before a panel of three neutral arbitrators designated by the same arbitration firm. The panel will consider all factual and legal issues anew, follow the same rules that apply to a proceeding using a single arbitrator, and make decisions based on the vote of the majority. Costs will be allocated in the same way they are allocated for arbitration before a single arbitrator. An award by a panel is final and binding on the parties after fifteen days has passed. A final and binding award is subject to judicial review and enforcement as provided by the FAA or other applicable law.

    Survival and Severability of Terms. This arbitration provision shall survive: (i) termination or changes in these Terms and Conditions, any account or account Agreement that User may have with Corpay, or the relationship between User and Corpay concerning the Messaging Service or any account; and (ii) the bankruptcy of any party. If any portion of this arbitration provision is deemed invalid or unenforceable, the remaining portions shall nevertheless remain in force. Any different agreement regarding arbitration must be agreed to in writing.

Corpay maintains appropriate licensing and regulatory standards for a Money Services Business (and equivalent) in the regions in which we operate and where required. Please use the link below to download this information.

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AFEX Markets Europe Ltd Client Asset Key Information Document 

This document provides you with key information about the Client Asset Regulations. 
 
AFEX Markets Europe Ltd Client Asset Key Information Document click here and Client Assurance Document click here.
 

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The information contained in these documents are proprietary and confidential to Corpay and are only applicable to clients of AFEX Markets Europe Limited. This material may not be duplicated, published, or disclosed, in whole or in part, without the prior written permission of Corpay.

Associated Foreign Exchange Ireland Limited Client Assurance Document click here.

Corpay’s Commitment to Accessibility

Corpay (“Corpay”) is committed to providing a barrier-free environment for our clients, employees and other stakeholders: whether they enter our premises, receive services from us or access our information.

Corpay strives to meet the needs of its employees and customers with disabilities and is working hard to remove and prevent barriers to accessibility.

Our business is committed to fulfilling our requirements under the Ontario statute: Accessibility for Ontarians with Disabilities Act (“AODA”).

As an organization, we are committed to treating all people in a way that allows them to maintain their dignity and independence. Corpay believes in integration and equal opportunity, is committed to meeting the needs of people with disabilities in a timely manner, and is committed to meeting the accessibility requirements under the AODA.

To read our Accessible Customer Service Policy, download it here.

Please click here to view our Self-Certified Report from 2013, and click here to view the 2023 report.

Multi-Year Accessibility Plan: Please click here to read our Multi-Year Accessibility Plan.

Contacts: If you would like to request information regarding our accessibility or are having trouble accessing our services, please reach us on the below.

Human Resources
Phone: (416) 646-6401 or cambridgefx.humanresources@fleetcor.com

Corpay¹’s Annual Modern Slavery and Human Trafficking Statement

Regarding the Fiscal Year That Ended December 31, 2021

Message from the Senior Management of Corpay Cross-Border

The year 2021 marks more than 150 years since Abraham Lincoln’s Emancipation Proclamation, and more than 180 years since the British Empire abolished slavery. Yet, so many years later the practice of slavery still lives on: The Global Slavery Index’s most recent estimate is that some 40.3 million people are enslaved by modern slavery². The senior managers of Corpay cross border require all Corpay cross-border employees, clients, other stakeholders and the public at large to review this Corpay statement regarding modern slavery which apply formally to our UK entities and informally to all Corpay cross-border businesses. Corpay cross-border is committed to working together will all stakeholders to ensure that Corpay lives up to it commitment of zero tolerance for direct or indirect enablement of slavery and human trafficking.

Introduction

Corpay is a multinational group of financial service companies providing financial solutions and the cross-border group specializes in foreign currency and global payments solutions. This Slavery and Human Trafficking Statement is the Corpay cross-border policy applicable to the identified Corpay cross-border corporations. This statement complies with the requirements of subsection 54(1) of Britain’s Modern Slavery Act 2015 (“BMSA”).

What is the BMSA? It is an Act of the Parliament of the United Kingdom. It is designed to reduce and eliminate slavery in the UK and consolidates previous offences relating to trafficking and slavery. The act extends to England and Wales. The bill was introduced to the House of Commons in draft form in October 2013. It received Royal Assent and became law on 26 March 2015.

BMSA is intended to combat slavery, servitude and forced, compulsory labour and about human trafficking, including by way of provision for the protection of victims. BMSA likewise provides for an Independent Anti-slavery Commissioner, among other measures to facilitate this goal.

Corpay complies with the spirt of BMSA in all its offices. We therefore ensure worldwide that no modern slavery, servitude, forced or compulsory labour and human trafficking (“modern slavery”) is taking place anywhere in our business or supply chain. Details of how we ensure this are set out in the seven sections that follow.

1. Corpay’s structure, business and supply chains
   Corpay corporations are subsidiaries of Fleetcor (NYSE: FLT). Corpay cross-border ’s global headquarters are in Toronto, Canada, with additional offices in Australia, Ireland, Italy, Jersey, Singapore, Spain, UK and, the USA. Corpay is licensed to service customers based in all those countries. Corpay cross-border is a financial services business: Specifically, we provide solutions catering to our customers’ foreign currency exchange and global payments needs. Corpay cross-borders ’s business is therefore based on intangibles rather than physical inventory, and our risk of being supplied directly or indirectly by slave labour is low. Our key suppliers are our banking partners, as well as our technology partners that provide us software to help us offer enhanced trading capabilities, as well as comply with anti-money laundering and related laws. Corpay performs appropriate due diligence on both suppliers and customers. Additionally, with the exception of restricted private client business, our business is primarily B2B servicing corporate rather than consumer clientele. Between our B2B focus, and the countries that our business focuses on, we face a low overall risk of in any way facilitating modern slavery.

2. Corpay’s policy in relation to slavery and human trafficking
   We do not tolerate or condone the practice of modern slavery in any form and Corpay cross- border group is committed to ensuring that there is no modern slavery in our business or supply chain. Our policies to implement this commitment include:

   • A policy requiring employees who suspect, or become aware of, any instances of modern slavery in our business or supply chain, to report such incidents to management and /or make use of our whistle-blowing channels (as appropriate). All good faith whistleblowing is protected against retaliation.

3. At Corpay Cross-Border, we follow due diligence processes in relation to slavery and human trafficking in our business and supply chains
   The due diligence processes we follow include the following measures:

   • Due diligence relating to modern slavery carried out on suppliers identified as being at higher risk of modern slavery.
   • A periodic risk assessment of our business and supply chain to identify suppliers and business engagement where the risk of modern slavery is highest.
   • Scrutinizing clients both during initial on-boarding and on a transactional basis for compliance and reputational risks.

4. Risk assessment and management: The parts of Corpay’s business and supply chains where there is a risk of slavery and human trafficking taking place, and the steps we have taken to assess and manage that risk
   Corpay engages with numerous related suppliers and services across the globe. In order to manage and mitigate any risk we periodically assess our business and supply chain in order to identify those areas in which we consider the risk of modern slavery to be the highest. At present we would consider that the risk of modern slavery occurring is somewhat higher in jurisdictions where they have less legislation against or controls of such activity. For business involving such jurisdictions we are on heightened alert for suspicious signals of possible modern slavery. Many jurisdictions with a relatively high percent of their population enslaved are for separate reasons deemed high risk countries by Corpay and therefore payments to such countries are always intensely scrutinized.

   Corpay cross-border is committed to acting professionally and fairly in all of our business dealings and relationships we operate, including enforcing appropriate systems and controls. Corpay cross-border also confirms that all counterparties we do significant business with conduct all their business with integrity and that they, like us, have a zero tolerance approach to modern slavery.

5. Measured against appropriate performance indicators, Copay Cross-Border is effective in ensuring that slavery and human trafficking is not taking place in our business or supply chains
   Corpay cross-border investigates all its counterparties who play a more than minimal role in the Corpay business to ensure the counterparties are not in breach of anti-slavery laws. Corpay cross-border likewise obtains contractual promises from all such counterparties that they comply with their legal obligations, which include laws against slavery.

   Corpay cross-border stays alert to tips provided by any of the contact options described at the end of this statement. Corpay provides an initial response within five business days of receipt, and a complete response within thirty calendar days of receipt. This way we ensure raised concerns get the appropriate priority, and we maximize our ability to collaborate with others in carrying out our anti-slavery compliance.

6. The training and capacity building about slavery and human trafficking available to Corpay Cross-Border staff
   Corpay cross border in the fiscal year ending December 31, 2017, commenced training on our policies and procedures in relation to modern slavery to Corpay cross-border staff, as part of annual refresher training in anti-money laundering compliance beginning for some entities in spring 2018. These measures ensure we are awareness of Corpay’s zero tolerance for being party in any way to slavery or human trafficking, and that this zero tolerance stance overrides any potentially competing priorities.

7. Corpay Cross-Border Contact Information
   In case of any questions or concerns relating to this statement, please feel free to contact us by any of the following methods: 1) Email to legal@cambridgefx.com; or 2) Mail to Cambridge Mercantile Corp. (UK) Limited, 4th Floor, 8-10 Moorgate, EC2R 6DA, London, England, Attention: Legal.

   Corpay’s website is www.corpay.com .

   Standard and accessible formats of this document are free on request to Human Resources at email address: Cambridgefx.humanresources@fleetcor.com .

   This document was last updated on December 9, 2021.

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¹ “Corpay” (also “we” “us” “our”) in this document refers individually and collectively to the brand used by the following UK based legal entities in the Corpay cross-border group as identified in our legal pages https://payments.corpay.com/compliance#1 .

² https://www.globalslaveryindex.org/2019/findings/executive-summary/

Some of the Corpay account Terms and Conditions are available by reference:

For Corpay Cross-Border Terms and conditions, click here .

Please click the following link to download this information: Download PDF

Please click here to read and download our Data Privacy and Security information document.

Please click here to read and download our fraud awareness and social engineering recommendations and best practices

ESG Policy and SFDR Disclosure

Purpose

AFEX Markets Europe Ltd (T/A Corpay) (AFEX) recognises the operational impact which the business has on the communities we serve and, on our environment, at large. Corpay believes in behaving as a responsible business and is committed to exerting a positive impact on both society and the environment.

Corpay believes that companies have a responsibility to contribute to the effort to fight climate change and to care for nature and the environment. It is also Corpay’s belief that companies should provide good employment conditions and be committed to diversity by creating an inclusive workplace and offering a productive, safe, healthy and harassment-free environment. Corpay also recognises that good corporate governance is essential to long-term success and to ensuring that companies deliver value for all stakeholders, including shareholders.

Scope

This Policy applies to all directors, officers and employees of Corpay and must comply with the spirit and intent of the Policy. This policy is subject to all applicable local laws and regulations.

ESG Principles

Corpay’s core ESG Principles are set out below. Corpay seeks to:

Environmental:

• Comply with all legal and regulatory requirements
• Continually improve and review environmental performance
• Continually improve and reduce environmental impacts
• Incorporate environmental factors into business decisions
• Increase employee awareness and training

Social:

• Comply with all legal and regulatory requirements
• Offer work-life balance and good employment conditions to its workforce in a productive, safe and harassment-free environment
• Promote equal opportunities and diversity among its workforce
• Pay its staff the real living wage as a minimum
• Give, and encourage its staff to give, to charity
• Encourage staff to be active and look after their health
• Assess suppliers with regards to ESG
• Measure customer satisfaction

Governance:

• Comply with all relevant laws and regulations and provide a whistleblowing platform for raising any concerns
• Have in place a sound corporate governance structure
• Have a zero-tolerance approach to health and safety matters
• Adhere to high ethical standards and operate free from corruption and conflicts of interest
• Have all the necessary measures in place to fight money laundering
• Have all the necessary cyber security measures in place to protect itself against fraud and other types of cyber crime
• Protect the personal data of all data subjects
• Have in place, and regularly test, a Business Continuity Plan

Integration of Sustainability Risk

When we say ‘sustainability risk’ here we mean an environmental, social or governance (ESG) event or condition that could cause an actual or a potential negative impact on the value of a product we recommend to you.

We give advice on over-the-counter foreign exchange derivative products. Our products are used for the purposes of currency risk management and not to invest on the market with the intention to make a profit. Clients use our products if they have an exposure to foreign exchange risk and desire to hedge against this underlying commercial foreign exchange exposure.

When we give you advice, we use a range of information to help you make an informed decision, this includes:

• how long you want to invest/hedge your money for;
• the level of your exposure to foreign exchange risk;
• your attitude to investment risk – i.e. the potential for losses and gains and the volatility of investments; and,
• explaining to you how the products we may recommend are used and their features.

Corpay does not currently take specific account of sustainability risks in its advice process because the products which we offer are designed, and used, predominantly for hedging purposes.

How we include sustainability factors in our advice process may develop over time, but this will be largely driven by the products we offer and how these products factor in sustainability risks.

In accordance with the European Sustainable Finance Disclosure Regulation (SFDR) (EU) 2019/2088, please click here to access the SFDR Disclosure.

Please click the following link to download this information: Download PDF