Code of conduct
Last updated: May 19, 2026. Version 1.3.
Ethical principles, conflicts of interest, anti-corruption, honest yield communication, whistleblowing. Applies to staff, managers, board, and partners.
BlueLock operates on five non-negotiable principles: (a) radical honesty — we never deceive client, partner, regulator, or staff; (b) transparency — fees, policies, decisions are public when possible; (c) respect — every human interaction starts from the principle of dignity; (d) accountability — we own mistakes before they're discovered; (e) excellence — quality is non-negotiable.
Staff must declare: (a) ownership stake in competitors; (b) close relationships (spouse, ascendant, descendant) with client, partner, or regulator; (c) side activity that may conflict. Declarations are reviewed by the Ethics Committee. Conflicts may imply removal from the related function, without loss of employment.
BlueLock follows the Anti-Corruption Law (Law 12.846/2013) and Swiss equivalents. We don't offer, receive, or broker: (a) bribes; (b) gifts above R$ 200 / CHF 50; (c) disproportionate hospitality; (d) political contributions on behalf of the company. Facilitation payments ("grease") are prohibited, even where legally tolerated in other jurisdictions.
(a) We never ask for full password, SMS code, or card photo via channels outside the Web App; (b) We never charge "release", "unlock", or "processing" fees not announced on /taxas/; (c) We never pressure for urgent operation without regulatory justification; (d) We acknowledge our errors publicly and fix them quickly; (e) Honest yield communication — the 18.5% APY rate on free CHF balance and the 2.1% to 3.2% rates on CDBs are current nominal rates, not perpetual guarantees. We never promise "guaranteed yield forever", "risk-free", or "bulletproof" yield. Rate changes are communicated with the prior notice defined in the Terms of Use (clauses 4, 5, and 6); (f) We never suggest the client fragment deposits or withdrawals to bypass regulatory limits or the progressive withdrawal schedule.
(a) Salaries are public by level and internal function; (b) Reviews are bidirectional — staff evaluates manager and vice versa; (c) Performance-based dismissals happen with a 30-90 day improvement plan first; (d) Harassment (moral, sexual, racial) has zero tolerance — investigation and dismissal within 7 days of a substantiated report.
Staff who access client data sign a confidentiality agreement. Access is logged and audited. Data sharing among colleagues only with clear operational need. Leaving the company does not end the duty of confidentiality — confidentiality is lifelong for client data, including balance, yield history, and CDB history.
Anonymous whistleblowing channel available to staff, clients, partners, and third parties: etica@bluelock.app or internal form. We guarantee: (a) real anonymity; (b) non-retaliation; (c) investigation by an Ethics Committee independent of the reported hierarchy; (d) reply within 30 business days.
We respect competitors. We don't run misleading communications about Wise, Remessa Online, Itaú, or others — our /cambio/ page compares public data, always traceable. We don't try to hire competitors' staff via pressure or predatory poaching.
BlueLock operation is 100% digital — no physical branches, no paper, no heavy native apps (responsive Web App only). Infrastructure runs in data centers that report emissions. We seek banking partners with public net-zero commitment. We don't finance activities linked to fossil fuels, deforestation, or weapons.
This code applies to all staff, managers, board members, and partners operating on behalf of BlueLock. Annual review by the Ethics Committee. Current version: 1.3. Last revision: May 19, 2026.