1. Code of Conduct and Ethics

SwipeVault expects all employees, contractors, and representatives to adhere to the highest ethical standards in their daily operations. This includes, but is not limited to, the following:

• Integrity: Conduct all business with honesty and transparency.
• Confidentiality: Safeguard the privacy of all parties involved in escrow transactions. Confidential information should not be disclosed unless required by law or authorized by the client.
• Professionalism: Treat clients, partners, and colleagues with respect and professionalism at all times.
• Conflict of Interest: Employees must avoid situations where personal interests conflict, or appear to conflict, with the interests of the company or clients.

2. Escrow Transactions

The company follows a strict set of procedures for managing escrow transactions. These rules must be followed by all employees handling such transactions:

• Verification of Parties: All parties involved in an escrow transaction must be verified before processing. This includes identity verification for individuals and corporate verification for businesses.
• Authorized Signatories: Only authorized signatories may initiate or approve escrow transactions. Employees must confirm the identity of individuals requesting the release of escrow funds.
• Document Review: Before placing any funds in escrow, the associated agreements and documents must be thoroughly reviewed for completeness, accuracy, and legal compliance.
• Funds Handling: Escrow funds must be kept separate from operating funds in a secure, interest-bearing account until the transaction conditions are met. Any release of funds must be documented and executed according to the terms outlined in the escrow agreement.
• Disbursement: Disbursements from the escrow account will only be made once the terms of the agreement have been fulfilled by all parties. Documentation supporting the release must be maintained for record-keeping and auditing purposes.

3. Client Communication and Expectations

• Client Confidentiality: Information related to escrow accounts, transactions, and personal client data must be kept confidential, except where disclosure is required by law.
• Timely Communication: Clients should be notified promptly at each stage of the escrow process. Regular updates on the status of their transaction should be provided, including any potential delays.
• Dispute Resolution: In the event of a dispute between parties, SwipeVault will act as a neutral third party. The company will facilitate communication and, where necessary, seek to mediate a resolution in accordance with the escrow agreement. However, SwipeVault is not responsible for resolving disputes beyond the terms of the escrow agreement.
• Disclosures: Clients must be informed of any fees, terms, or conditions that apply to their escrow account before the transaction is initiated. Fees will be disclosed upfront and agreed upon by all parties involved.

4. Security and Compliance

• Cybersecurity: Employees must follow all security protocols to protect client data, funds, and the company’s internal systems. Access to systems and sensitive data must be restricted to authorized personnel only.
• Regulatory Compliance: SwipeVault complies with all applicable federal, state, and local laws regarding escrow services. This includes compliance with Anti-Money Laundering (AML) laws, Know Your Customer (KYC) requirements, and the Bank Secrecy Act (BSA).
• Audit Procedures: Regular audits will be conducted to ensure the integrity of transactions and the accuracy of financial records. Employees must fully cooperate with audit processes and provide necessary documentation upon request.
• Record Keeping: All transaction records, including correspondence, agreements, and payment details, must be kept in accordance with the company’s document retention policy for a minimum of [Insert Duration] years.
• Incident Reporting: Any suspected security breaches, fraud, or errors in transaction processing must be reported immediately to management. Employees are required to follow the company’s internal procedure for reporting suspicious activity.

5. Employee and Contractor Policies

• Workplace Conduct: Employees and contractors must adhere to professional conduct standards, including punctuality, respect for co-workers, and adherence to company policies.
• Training: All employees handling escrow services must undergo thorough training on the procedures, legal requirements, and ethics associated with escrow transactions. Refresher training will occur regularly.
• No Outside Business Interests: Employees may not engage in any external business or activities that conflict with the interests of SwipeVault. Prior approval from management is required for any outside employment or business ventures.
• Use of Company Property: SwipeVault’s assets, including computers, phones, software, and intellectual property, should only be used for business purposes. Unauthorized use or misuse of company property will not be tolerated.
• Non-Disclosure Agreement (NDA): All employees and contractors must sign a non-disclosure agreement (NDA) to protect the confidentiality of client information and internal business operations.

6. Compliance with Anti-Money Laundering (AML) & Know Your Customer (KYC) Regulations

SwipeVault is committed to preventing money laundering and terrorist financing activities. As part of this commitment:

• KYC Procedures: All clients must complete a KYC process before entering into an escrow agreement. This includes providing valid identification and relevant documents to verify their identity.
• Suspicious Activity Reporting (SAR): Employees are required to report any suspicious transactions or activities to the designated compliance officer. These reports may include unusual deposits, withdrawals, or transactions that seem inconsistent with a client's known business operations.
• AML Training: Employees will receive periodic training on recognizing and preventing money laundering activities. This training is mandatory and must be completed annually.

7. Fees and Payment Policies

• Escrow Fees: SwipeVault charges a standard fee for escrow services, which is based on the size and complexity of the transaction. All fees will be clearly outlined in the escrow agreement and communicated to clients upfront.
• Payment Methods: Payments to fund escrow accounts must be made through secure, traceable methods such as wire transfer, ACH, or certified check. SwipeVault does not accept payments via third-party platforms or cryptocurrency.
• Refund Policy: If an escrow transaction is canceled before any disbursements are made, a partial refund of the escrow fee may be issued, depending on the terms outlined in the escrow agreement.
• Late Payments: If payment is delayed or there is insufficient funding in the escrow account, SwipeVault will notify all parties involved. Continued delays may result in termination of the escrow agreement, subject to the terms and conditions agreed upon.

8. Dispute Resolution and Termination of Agreement

• Dispute Resolution: In the event of a disagreement between parties in an escrow transaction, SwipeVault will mediate the situation. If the dispute cannot be resolved, the matter will be referred to binding arbitration in accordance with the applicable laws of [Insert State or Country].
• Termination of Agreement: SwipeVault may terminate an escrow agreement if there is a breach of the agreement’s terms by any party. Additionally, if there are compliance violations or fraudulent activities, SwipeVault reserves the right to immediately suspend or cancel the agreement.

9. Amendment of Company Rules

SwipeVault reserves the right to amend or modify these rules at any time. Any changes will be communicated to all employees and contractors, and clients will be notified of any significant changes that may affect their escrow agreements.