Last Update: Fabruary 1, 2025

ESG Policy

1. ESG Policy vision

1.1 Dream Finance OÜ is an enterprise established and authorised under the laws of the Republic of Estonia (hereinafter Company or we), providing cryptocurrency payment processing services for individuals and businesses based on in-house developed software.

1.2 Our vision is to provide a world-class product and service to businesses worldwide.

1.3 Our mission is to solve the world’s payment needs using blockchain technology.

1.4 We value strategic vision and alignment. Our business can and should do things to promote a positive influence in matters that improve the world. We are willing to hold ourselves accountable for our impacts on the environment and people. Putting environmental, social and governance (ESG) principles at the very heart of our operation, we take steps towards a model that will deliver sustainable business advantage and measurable value.

1.5 Our ESG policy contains a set of Company performance standards to ensure we act responsibly and attain environmental and social sustainability goals.

1.6 We aim to assess, identify and mitigate environmental, social and governance risks that could negatively affect the countries where we operate, the Company’s performance and/or our reputation.

1.7 We wish to improve the Company’s environmental, financial, and social performance, make it more attractive for talents and be clear and transparent for the regulatory authorities.

2. Environmental aspects

2.1 Environmental goals. Our company is committed to reducing our carbon footprint and improving company standards to make it more environmentally friendly, practical and cost-effective. Thus, contributing to the Paris Agreement goals is crucial for us. We are committed to climate change mitigation and climate change adaptation.

2.2 Environmental risks and their mitigation. We will periodically assess environmental risks tied to our indirect climate change impact that could negatively affect our value and take steps to mitigate such risks. Environmental risks are considered by the Company’s Management Board once a year.

  • Reducing our carbon footprint.
    We aim to set net-zero targets by the beginning of 2035 and publish them on our website.
    To reduce our carbon footprint, we will measure it by February 2025. Upon receiving the data from the measurements, we will map out the sources and areas of our biggest impact and compile a specific action plan for carbon footprint reduction.
  • Reducing waste generation, including digital and electronic waste
    The steps towards our goals are made daily by reducing waste generation through prevention, recycling and reuse.
    As facilitating cryptocurrency transactions is a resource-heavy activity, the Company will consider the high demand for computing technology and servers. We properly dispose of electronic waste generated by our business by sending back defective devices to the vendor or reseller and pay for its recycling.
  • Reducing our energy consumption and using more renewable energy
    We will strive to reduce our energy consumption by transaction by at least 5% and, if possible, use renewable energy sources for our activity.
    We do not mine any cryptocurrency, which is a highly energy-intensive process.
    Our physical offices are located in an energy-efficient building LEED Gold certificate 2019. As a remote-first enterprise, we save a considerable amount of energy.
    We will assess the options to make our premises more sustainable on the listed topics and beyond and apply for Green Office Certification in 2025.

3. Social aspects

3.1 People are the heart of our success – we prioritise our employees’ and stakeholders’ well-being and growth.

3.2 Internal social aspects. The Company responsibly complies with the legal acts of the Republic of Estonia regulating and protecting the rights of the employees. Moreover, we care for our employees according to the best market standards. The Company conducts yearly anonymous satisfaction surveys to monitor their needs and opinions. The first results will be the starting point against which the results of the next years are to be compared to identify and report the change.

  • Protection of human rights. We are committed to ensuring fair labour practices. We act courteously and respectfully towards each other and everyone we work with. Providing fair working conditions and societal engagement to employees is our responsibility. We strive to act with due diligence to avoid infringing on the rights of others in our business.
  • Safe and healthy workplace. Our colleagues must be comfortable coming to work and feel that the workplace is safe and healthy. We provide fair working conditions, decent wages and an atmosphere that is free of any type of discrimination. Colleagues who are aware that these conditions are violated must report about that. We offer vacations according to the applicable law with a minimum of 20 working days’ worth of vacation and additional days off for healthcare or personal reasons. None of our employees or other personnel (i.e. trainees) are allowed to work without remuneration.
  • Diversity, equity and inclusion (DEI). Nurturing a culture that embraces diversity and inclusion catalyses success and innovation in the workplace. We value individuals with unique personalities, goals, backgrounds and views. We are open to all clients and employees regardless of economic situation, age, gender, ethnicity, religion, sexual identity, or disability. We have a diverse workforce of over 22 citizenships, a wide range of age groups and a nearly 50/50 gender balance companywide.
  • Employee competency model
    It is important to offer professional and personal enrichment opportunities at all levels. Thus, we maintain continuous learning and development by providing high-quality training for our staff.
    7 73% per cent of the roles in the Company are covered by skill matrixes, which include knowledge (skills and tools, soft skills) and job functions (core functionality and managerial leadership). The Company is planning to increase this percentage to 89% by 2026.
    We offer our employees an internal training program, CoinsPaid Academy, and internal courses tailored for different occasions. In addition, employees can attend external training with their manager’s approval.
  • Remuneration system
    The company’s salary system, determination, and review methods are created and constantly improved to ensure that employees are treated justly.
    Performance reviews are held once a year, taking into account the employees’ performance and contributions. As a part of these reviews, we also discuss the employee’s development and opportunities within the Company.
    These reviews influence remuneration and promotions. We ensure that our remuneration system is transparent, making all benefits, competence models, promotions, and other relevant information publicly available in the Company’s internal portal.
  • External social aspect
    We believe companies should take responsibility for their business and employees and the whole society in which they operate. Therefore, we take part in charitable activities, offering humanitarian support, sponsoring the pupils and supporting schools. (Aris FC Academy, Happy Child, Business competition for Ukrainian women refugees in Estonia).
    To support local communities, we offer educational programs on digital finance and provide our office rooms for meetups of the ecosystem. We are committed to contributing to local causes through various endeavours.

4. Governance aspects

4.1 Level of governance. The Company’s Management Board and ESG officer pay special attention to sustainability and consider sustainability issues and risks at least once a year.

4.2 ESG-related internal documentation system. The following Company’s governing documents govern specific ESG-related commitments and procedures:

  • Code of Conduct*,
  • AML/CFT Policy, KYC Policy,
  • Internal Governance Policy*,
  • Conflicts of Interest Policy*,
  • Data Protection Policy* and
  • Privacy Policy.

4.3 Employees receive regular training to uphold compliance standards. The policies above are reviewed and updated annually.

4.4 We received the ISO 27001 certification from Bureau Veritas Eesti OÜ, which will influence the governing of the Company in the future.

4.5 Transparency and reporting

Our company creates maximum transparency, as our clients and partners should be confident in both clearer reporting and greater trust for the long term.

If an employee reports someone’s behaviour that breaches the law or does not comply with our corporate ethics, we will promptly investigate, address, and respond to any questions or concerns of the employee and take appropriate corrective action in response to a violation.

We are in the process of implementing a whistleblowing system and channel by February 2025.

Furthermore, we are committed to being transparent with our sustainability targets and performance, including continuous and annual reporting on our progress on financial performance and the other aspects in compliance with MiCA regulation in external and internal channels, including our annual report.

4.6 Supply chain management

To contribute to sustainable development, we actively manage our supply chains. This includes centralised management of the flow of goods and services and the approval process.

We aim not to be involved in activities that contribute to infringing on human rights or employees’ rights, unethical behaviour, corruption or environmental damage. As a part of this, we prefer suppliers that share these values and have an ESG policy reflecting that.We are progressively implementing an ESG questionnaire to our Due Diligence suppliers process.

4.7 Anti-corruption and anti-bribery. The Company applies a zero-tolerance policy on corruption and bribery. This applies to the Company’s employees and the entire Company’s activities.

4.8 Tax

An important part of the Company’s commitment to social responsibility is compliance with all its tax obligations.

The Company will always strictly comply with applicable tax legislation, perform its tax obligations promptly, and demand the same from its partners and suppliers.

4.9 AML

We have a full package of AML policy and internal procedures, including a comprehensive set of documents including AML Policy, internal rules & procedures, sanctions policy, transaction monitoring policy and procedures designed to prevent financial crime from happening on our platform.

We use a wide selection of vendors for KYC screening, sanctions screening, adverse media screening, Chainalysis, SumSub, Crystal Blockchain, and WC Refinitve.

We have a dedicated transaction monitoring team, an anti-fraud specialist, and a team of investigators.

We process alerts from Chainalysis daily at the risk level. Regular training is conducted through ACAMS, courses and industry events. We aim to keep this standard and continue conducting regular training.

The Company adheres to a four-eyes-check and conducts enhanced due diligence during onboarding, video interviews and periodic internal audits.

4.10 CTF

We do sanctions screening via SumSub on individuals and WC Refinitve for sanction screening.

We have established an in-depth Sanctions Policy and an asset-freezing procedure. International Sanctions Reports are filed as per requirements by local regulators.

Any sanctioned wallets are investigated and reported. Measures are taken to various degrees by merchants involved in sanctioned transactions.

We have an analysis of the UBO structure, exposing mixed ownership and indirect ownership. People with significant control under sanctions are not allowed to use our platform.

4.11 Data protection

The Company is committed to upholding the highest data protection and privacy standards in line with applicable legislation.

The Data Protection Officer serves as the main point of contact within the Company for staff members, regulators, and relevant public authorities on issues related to data protection. They ensure that Company policies and practices comply with the applicable laws, such as GDPR, and provide appropriate advice to staff.

Approved by the Company’s Executive Board Member on 16th January 2025 and valid until January 2028. Subject to review every year.

 

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