This policy defines our approach to non-solicitation requirements and outlines the permitted and prohibited marketing activities for our employees.
Date: July 1st, 2022
Clarity Global Inc. is fully aware of non-solicitation requirements and respects any regulatory framework. By adhering to this non-solicitation policy, we accord to the requirements of all the regulations, our partner banks' guidelines and uphold the trust of our partners and maintain the reputation as a trusted financial services provider.
This policy applies to all employees of Clarity Global Inc.
For the purpose of this Policy solicitation refers to any attempt to actively target customers on markets outside Canada.
3.1. Clarity Global Inc. is using the following marketing channels to attract new customers:
3.2. Using other marketing channels to attract new customers in all markets except Canada is prohibited, unless it is a commonly used market practice or we have a Legal Opinion issued by a reputable law firm explicitly stating that Clarity Global Inc. is permitted to do so.
The following activities are prohibited for all employees of Clarity Global Inc. according to this Policy:
The following activities would not be considered as solicitation according to this Policy:
6.1. Chief Compliance Officer will provide guidelines to the Sales & Marketing Department considering the permitted and prohibited activities and communication contents according to this Policy.
6.2. Compliance will review the source of each potential client of Clarity Global Inc. to assure adherence to the Policy before establishing contractual relations with the potential client.
6.3. Client's source will be a part of Internal Audit to make sure that the provisions of this Policy are not violated in any way.
Non-compliance with the provisions of this Policy may lead to the following consequences:
8.1. Non-solicitation provision will be included to the employment contracts of Clarity Global Inc. employees and contractors.
8.2. Requirements of the Policy and Consequences of Non-Compliance will be an integral part of the training materials for staff training to promote appropriate activities and adherence to this policy.
8.3. All employees are required to review and acknowledge this policy upon commencement of employment and completing the respective training and on an annual basis thereafter.
8.4. Failure to adhere to this policy may result in disciplinary action, including termination of employment.
9.1. Employees, contractors and representatives are encouraged to report any suspected violations of this policy to their supervisor or the designated compliance officer according to the Whistleblower Policy of Clarity Global Inc.
9.2. Clients' complaints, consultations and so forth, if any, in relation to this Policy should be addressed to our Complaint Handling Officer at: +17788193278 during our office hours 8.00-17.00 CET, Monday-Friday, or by email — dispute@clarityglobalinc.com.
This policy will be reviewed periodically, but not less than annually, to ensure its effectiveness and compliance with relevant laws, regulations and best practices.
