Legal Documents
I. Introduction, Purpose, and Scope
Our ESG aspiration is to become the leading fintech company in providing financial services that consistently offer long-term economic, social, and environmental benefits to both our customers and society at large.
As an FCA-regulated electronic money institution, Bilderlings Pay Limited (โBilderlingsโ, โweโ, โusโ, โourโ) is acutely aware of its role and responsibility in fostering sustainable economic growth and enhancing overall prosperity. Our adherence to the FCA’s regulations reflects our dedication to upholding the highest standards of corporate responsibility and integrity.
This Policy outlines the essential aspects necessary to achieve effective corporate sustainability which are defined in line with FCA requirements and core principles. Furthermore, our approach finds resonance with the objectives of the United Nations Sustainable Development Goals (UN SDG), reinforcing our commitment to global standards of sustainability and social responsibility.
- Environmental Transition: Prioritising the responsible use of natural resources and minimising ecological impact. Examples include reducing the carbon footprint and sustainable resource utilisation (UN SDG 12).
- Social Responsibility and Human Rights: We are dedicated to upholding and promoting human rights across all our business practices. This includes ensuring financial inclusion and maintaining ethical business conduct. Additionally, we prioritise health, safety, and environmental concerns in our operations. Our commitment extends to supporting and developing charitable partnerships, reflecting our core values and responsibility towards society (UN SDG 3, 5).
- Inclusion, Diversity, and Transparency: Erasing boundaries and fostering a culture of diversity and inclusion in all our actions. By offering financial services to a diverse customer base, we aim to create a more unified and inclusive ecosystem. This extends to maintaining transparency in all our dealings, reinforcing our dedication to a fair financial environment. (UN SDG 10, 16).
- Innovative Technologies and Sustainable Development: Ensuring long-term financial stability through sustainable investment practices and the development of innovative technologies. Our focus extends to enhancing the company’s profitability while simultaneously working for the societal good. A key aspect of our commitment is making our services easily accessible, ensuring that they contribute positively to both our customers’ needs and broader societal goals. (UN SDG 4, 8).
1.1. Purpose
This Policy aims to provide an overview of our approach to sustainability, outlining its principles, describing Bilderlings’ position on environmental and social matters, and demonstrating its commitment to promoting sustainable development.
1.2. Scope
All Bilderlings employees must comply with this Policy, which is accessible to all staff and available publicly on the company’s website.
II. Environmental Transitionย
2.1. Climate Change
As a financial institution, Bilderlings acknowledges the profound challenge presented by global climate change, a critical issue highlighted by the 2015 Paris Agreement (underscores the urgency to limit global warming to no more than 2 degrees Celsius above pre-industrial levels to mitigate significant environmental risks). We also endorse the FCA’s requirements and are working in accordance with its guidelines to make a positive impact on Climate Change. Bilderlings actively contributes to reducing environmental impact and is committed to achieving Net Zero emissions, thus supporting efforts to safeguard our planet.
2.2. Position
- Bilderlings aims to maintain complete transparency regarding climate-related risks and opportunities, ensuring stakeholders are well-informed about our environmental impact and strategies.
- Bilderlings is dedicated to echoing and enhancing the environmental values and goals of our customers and partners, with a firm commitment to preserving our planet and minimising greenhouse gas emissions.
- When considering climate-related issues Bilderlings takes into account reliable and scientifically accurate climate data.
- Bilderlings supports efforts that focus on reducing our carbon footprint and are also deeply involved in forest restoration projects.
- Bilderlings is devoted to cultivating a workplace environment that encourages deep-rooted care for our planet, promoting a healthier, more sustainable workplace culture.
2.3. Transition Actions
Bilderlings is committed to playing its part in addressing climate change. To make a real impact, we’re focusing on several essential strategies:
- Energy Efficiency: We’re taking steps to cut down on energy use. This means bringing in appliances that use less power.
- Remote Work and Virtual Meetings: We’re rethinking how we travel for business. Instead of hopping on a plane or in a car for every meeting, we’re embracing video conferencing and other remote communication tools. Plus, we’re encouraging our teams to work from home when it’s feasible, reducing the need for daily commutes.
- Waste Reduction and Recycling: We aim to produce less trash and recycle more. This includes using less paper, promoting digital document formats over physical ones, and recycling in our offices.
- Green Office Practices: We endeavour to transform our offices into eco-friendly spaces. This involves aiming to use materials that are kinder to the planet, being mindful about how we use resources like water, and fostering a workplace culture that values and practises sustainability.
2.4. Future Initiatives
As part of our plans we intend to implement regular 3rd party audits and reporting on our company’s carbon footprint. This will be aimed at thoroughly analysing and actively reducing our environmental impact.
III. Social Responsibility and Human Rightsย
3.1. Social Impactย
Bilderlings is steadfast in its dedication to social responsibility and the advocacy of human rights and inclusivity. In line with these values, we have proudly initiated a charity project supporting clown doctors. This distinctive endeavour is aimed at providing joy and laughter, serving as an emotional respite for children within healthcare environments.ย
Bilderlings’ engagement with the clown doctors initiative is a sustained and evolving effort, not merely a singular endeavour. We have established firm plans to not only continue but also enhance our support for this project. This commitment underscores the significance we place on contributing to the community, demonstrating our dedication to making a meaningful and lasting impact in the realms of social responsibility and society support.
3.2. Human Rights
Moreover, at Bilderlings, we uphold a strong stance on human rights. We believe in sustaining an environment that is compliant with international human rights standards and actively promotes these principles. Our approach is centered around inclusivity and diversity, recognizing the unique contributions and perspectives each individual brings to our organisation. We strive to maintain workplace and business practices that are free from discrimination and bias, ensuring equal opportunities for all.
Our commitment to these values is unwavering, and we continuously seek ways to integrate them into every aspect of our operations. Bilderlings is committed to being a positive force in promoting and implementing human rights standards, thereby setting a benchmark for ethical and responsible business practices.
3.3. Healthy Environment and Safety at Work
As part of our ESG Policy, Bilderlings places special emphasis on a healthy and safe working environment. We adhere to strict standards in the area of disciplinary responsibility, eliminating any forms of bullying, harassment, and discrimination. Our goal is to create conditions where every employee feels comfortable and confident, having access to all necessary resources. Maintaining a healthy and safe work environment is a key aspect of our approach to sustainable development. Detailed information for ensuring safety and creating an optimal work environment is developed under our Internal Regulations.
3.4. Business Ethos
From a fintech perspective, our ethos is deeply anchored in a set of fundamental principles that steer our interactions across the financial technology landscape โ with partners, customers, and within our dynamic team. These guiding principles include:
- Open and Constructive Dialogue: We champion transparent discussions, vital in the fast-evolving fintech sector.
- Respect for Human Rights: In a digital age, we remain steadfast in upholding the dignity and rights of every individual, recognizing the impact of technology on human lives.
- Transparency in Fintech Operations: We prioritise clarity and easy access in our financial services and communications, essential in the complex world of fintech.
- Inclusivity: We aim to promote equal opportunities and removing barriers in the financial sector for all.
- Collaboration and Mutual Support: We understand the power of teamwork and collaboration in driving shared success in fintech.
- Legality and Adherence to Fintech Standards: We rigorously comply with legal and ethical standards in line with FCA requirements, recognizing the importance of trust and integrity in the fintech industry. Our commitment to and implementation of FCA principles of business is reflected in our internal policies and procedures (Principles of Business Policy).
IV. Governance
In its business development, Bilderlings is governed by a code of ethics and high professional standards. Bilderlings conducts its business in strict compliance with internal regulations. The policies and procedures developed by Bilderlings have formed a clear and transparent system of corporate governance.
The legal framework of Bilderlings not only provides a clear demarcation of the governance functions and determines functional rights and responsibilities of everyone in the company but also creates a mechanism for managing the conflicts of interests and prevents any transactions or other actions, that might pose the risk of decreased trust in Bilderlings.ย
Bilderlings adheres to the principle of zero tolerance of corruption in all its forms manifestations.
Bilderlings ensures information security and protection of customer data.
Bilderlings maintains the information channel open to all members of staff, who wish to report any malpractices or violations in the compliance sphere.
V. Inclusion, Diversity, and Transparency
At Bilderlings, our commitment to inclusivity and the creation of a welcoming environment for all customers is a cornerstone of our ethics. We steadfastly uphold the principle that financial freedom and access to financial services is a fundamental right for all individuals, irrespective of their background or geographical location, providing it aligns with legal and ethical norms.
In our endeavour to guarantee the utmost accessibility of our services, we conduct regular analyses of peer organisations. This involves a comprehensive comparison of service offerings and fees.
Moreover, in alignment with our dedication to ensuring the openness and transparency of our activities, we regularly provide relevant required information to stakeholders, regulators, and customers. This practice forms an integral part of our Principles of Business Policy and Vulnerable Customers Policy and Procedure reflecting our commitment to ethical business practices and accountability.
5.1. Customer Feedback
At Bilderlings, we recognize the importance of customer feedback as a vital tool in our ongoing efforts to enhance openness and diversity in our services. We are committed to responding promptly to customer criticism and suggestions, and we actively gather feedback periodically, which informs our strategies for improvement and innovation.ย
Looking ahead, we are committed to integrating regular customer surveys into our operational framework. This initiative is aimed at continually evolving and tailoring our services to more precisely align with the needs and preferences of our customers. By leveraging these insights, we intend to refine our offerings, ensuring they are not only accessible but also resonate with the requirements and expectations of those we serve. This approach would contribute to making Bilderlings a more open, responsive, and transparent financial institution for customers.
5.2. Communication with Customers
At Bilderling we aim to provide the best possible Customer service and maintain open and transparent communication with our customers and stakeholders. To uphold these values, we have established a Communication Procedure that sets forth guidelines to ensure communication that is fair, clear, and transparent. We also adhere to the Consumer Duty principle including the communications standards set forth therein.
VI. Sustainable Development
At Bilderlings, we strive for a balance between economic growth, profit generation, and environmental and social impact. In its strategy, Bilderlings focuses on long-term development.ย
6.1. Innovation as the Driving Force of Sustainable Development
Innovation is a key tool for sustainable development, especially in the fintech industry. The application of innovative technologies and approaches not only allows for increasing efficiency and competitiveness of services but also makes a significant contribution to economic and social development.
Innovations and new technological solutions in the finance sector can promote wider access to financial services, which is particularly important for developing countries. The development and implementation of mobile payment systems, for example, enables people to access financial services without physically visiting banking institutions. Thus, fintech companies not only expand their customer base and increase profitability but also contribute to the socio-economic development of society as a whole.
The implementation of environmentally sustainable technologies also plays an important role in the sustainable development strategy of fintech companies. The use of cloud technologies and digitization of business processes helps to reduce the carbon footprint of the company, reducing paper and energy consumption. Such steps not only strengthen the company’s image as a socially responsible business but also contribute to achieving global goals in sustainable development, such as those outlined in the 2015 Paris Agreement, and those of the UN.
6.2. Our Principles in Sustainable Development
- Financial Inclusivity: At Bilderlings, we strive to make financial services more accessible to society.ย ย
- Compliance and Regulatory Adherence: At Bilderlings, we always look after and comply with financial regulations and laws (incl. international standards, regulator requirements, and local regulations according to our Compliance Policy.
- Anti-greenwashing rule: We are committed to avoiding greenwashing in our operation and communications, and to comply with the anti-greenwashing rule and applicable regulations and guidance issued by the FCA. We ensure that any reference we make to the sustainability characteristics of our financial products and services are consistent with the sustainability characteristics of the product or service and are fair, clear, and not misleading.
- Fighting Financial Crimes: At Bilderlings, as a financial institution, strict adherence to procedures is essential to prevent money laundering, fraud, and corruption, and to ensure compliance with all relevant financial regulations and policies.
- Innovation and Adaptability: Bilderlings continuously innovates to stay ahead in the market. Our strategy includes investing in new technologies, automating processes, exploring emerging markets, and adapting to evolving customer behaviours. Our Mobile App and IT solutions enable customers to manage their finances with ease and efficiency. We are committed to breaking down geographical, technological, and financial barriers, making the world of finance accessible to everyone.ย
- Risk Management: Bilderlings implements robust risk management practices to mitigate financial risks, including credit, market, and operational risks.ย
- Customers as a core of our business: At Bilderlings we prioritise customer satisfaction and trust, developing a deep understanding of customer needs and striving to provide excellent customer service.
- Data Security and Privacy:ย As a fintech company we ensure the highest standards of data security and privacy of our customers. This is crucial to maintain trust and comply with data protection laws.
- Transparent and Ethical Practices: We maintain transparency in pricing models, and clear terms of service according to regulator’s requirements and moral-ethical standards.
ย VII. Bilderlingsโ commitment
To adhere to the principles outlined in this Policy, we strive to conduct our operations responsibly and efficiently. We recognise the importance of an integrated approach to sustainability. It is crucial not only to develop each area individually but also to ensure their harmonious interaction and synergy. We are committed to addressing both present and future social issues in the areas where we operate, ensuring a balance between economic growth, environmental stewardship, and social responsibility, while also respecting cultural diversity and human rights.
7.1. Key Commitments of this Policy
- Continue to integrate sustainability principles into business plans, procedures, and processes.
- Ensure continuous compliance with UK health, safety, environmental, and social legislation, as well as FCA requirements.
- Provide comprehensive information to stakeholders and actively engage with them to discuss sustainability performance and gather feedback.
- Continue to develop and implement social investment and sustainability programs aligned with the company’s strategic goals.
- Place a strong emphasis on forming strategic partnerships with external stakeholders to amplify the positive impact of social development programs and contribute to the well-being of communities in our areas of operation.