CasaNext FinCorp
Compliance Policy

Last Updated: September 13, 2025

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1. Purpose and Scope

This Compliance Policy establishes the principles, standards, and procedures by which CasaNext FinCorp (“CasaNext,” “we,” or “our”) ensures adherence to all applicable laws, regulations, and ethical obligations. It applies to all directors, employees, contractors, and business partners.

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2. Regulatory Framework

CasaNext commits to compliance with:

• Moroccan Regulations:

  • AMMC (Autorité Marocaine du Marché des Capitaux) rules and directives.

  • Bank Al-Maghrib circulars on financial institutions.

  • Law 09-08 on the protection of personal data.

  • Law 43-05 on Anti-Money Laundering & Counter-Terrorist Financing (AML/CFT).

  • Law 37-10 on Anti-Corruption and influence peddling.

• International Standards:

  • GDPR (EU data protection).

  • FATF recommendations on AML/CFT.

  • OECD and UN Global Compact principles.

  • CFA Institute Code of Ethics & Standards of Professional Conduct.

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3. Key Compliance Principles

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3.1 Integrity & Transparency

• All actions must be conducted honestly, fairly, and in accordance with applicable laws.

• No employee may engage in activities that could compromise the trust of clients or regulators.

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3.2 Anti-Money Laundering & Counter-Terrorist Financing (AML/CFT)

• Risk-based due diligence (KYC – Know Your Customer).

• Transaction monitoring and suspicious activity reporting to relevant authorities.

• Screening against sanctions lists (UN, EU, OFAC, Moroccan authorities).

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3.3 Insider Trading & Market Abuse

• Strict prohibition of insider trading, unlawful disclosure of material non-public information, and market manipulation.

• Employees must immediately report any potential conflict or suspicion of misuse of information.

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3.4 Anti-Corruption & Bribery

• Zero tolerance for corruption, bribery, facilitation payments, or influence peddling.

• Gifts and hospitality must be modest, transparent, and not intended to influence decisions.

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3.5 Data Protection & Confidentiality

• Compliance with GDPR and Law 09-08.

• Safeguarding all client, employee, and market data.

• Restricted access to sensitive data on a “need-to-know” basis.

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3.6 Conflicts of Interest

• Full disclosure of actual or potential conflicts.

• Compliance team review and mitigation measures before engaging in business activities.

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4. Compliance Governance

• Chief Compliance Officer (CCO): Oversees compliance framework, reports directly to senior management and the Board.

• Compliance Committee: Ensures independent review, monitoring, and escalation of compliance matters.

• Training & Awareness: Regular training on AML/CFT, anti-corruption, data protection, and ethical conduct.

• Monitoring & Audits: Periodic compliance audits and continuous monitoring of processes.

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5. Reporting & Whistleblowing

• Employees and stakeholders are encouraged to report suspected violations via confidential reporting channels.

• CasaNext guarantees protection against retaliation for good-faith reporting.

• Investigations are handled independently and objectively.

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6. Disciplinary Measures

Non-compliance with this Policy may result in:

• Internal disciplinary action, up to termination of employment or contract.

• Reporting to regulators or law enforcement authorities.

• Civil or criminal liability under Moroccan or international law.

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7. Continuous Improvement

CasaNext is committed to:

• Updating this Policy regularly in line with evolving regulations and best practices.

• Engaging external experts when needed to benchmark compliance standards.

• Maintaining a culture of integrity and accountability at every level.

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8. Contact for Compliance

For questions, reporting, or compliance concerns:

Compliance Department – CasaNext FinCorp
Email: saad@casanext.finance
Website: www.casanext.finance