1. Purpose of the Code

This Code of Conduct (“the Code”) lays down the internal rules applicable in matters of professional conduct and ethics. It should be read especially in connection with the company’s laws, regulations, policies, the Internal Policy Guide and the Staff Regulations.

This Code provides support and guidance for appropriate behaviour and applies to any person employed by EUROFIMA through an employment contract, irrespective of position, type and duration of employment. All staff members are expected to comply with principles, values and rules set in this Code. On an annual basis, staff members will be required to confirm their awareness of the Code.

Due to EUROFIMA’s special status as a supranational organisation all staff members have a particular responsibility for their activities and conduct both on and off duty. To a significant extent the staff and its behaviour influences the image and reputation of EUROFIMA.

2. Core Values

Staff members are expected to commit themselves to EUROFIMA’s objectives, to act impartially and with honesty. They are expected to carry out their professional tasks in good faith, with due care, competence and diligence.

EUROFIMA aims to provide a positive work environment, encouraging staff to work together in a culture of mutual support and cooperation contributing to effective business ethics and a compliance culture which guides the company’s behaviours and actions. In this regard, EUROFIMA strives to ensure the following:

  • Promoting a balanced distribution of nationalities, gender and age in its selection process putting emphasis on personal and professional qualifications and experience
  • Equal opportunities irrespective of gender, nationality, religion, age or ethnicity respecting and appreciating differences amongst individuals in the company
  • Adherence to high standards of professional ethics and endeavour to act in a way in which a sound spirit is maintained by being honest and fair
  • An open-door policy allowing all staff access to the management
  • Safe and healthy working conditions preventing work-related illness and accidents, maintaining good working and functional ability, free from harassment, discrimination and retaliation
  • EUROFIMA encourages further training and professional development of its staff members

 2.1. Non-discrimination

EUROFIMA promotes a balanced diversity and equal treatment among employees and seeks to ensure that everyone is treated with respect, has equal opportunities and feels valued. It puts emphasis on preventing discrimination and intervenes if an employee is harassed in any way.

No employee shall be unjustifiably discriminated on the basis of inter alia sex, age, nationality, ethnic origin family status, religion, health, political activities or for any other comparable circumstances.

2.2. Dignity at work

All forms of harassment, including psychological or sexual harassment, sexual blackmail, mobbing and bullying are unacceptable and strictly forbidden.

If such behaviour is witnessed and staff members have prevented or contributed to preventing victims from coming forward or have discredited them, staff members are in breach of their professional duties.

If such behaviour constituting any form of harassment is witnessed, EUROFIMA is obliged to show those in question concern and offers its support.

3. Rules

 Staff members are required to:

  • Comply with applicable laws, external and internal rules and regulations, procedures, policies and guidelines.
  • Observe professional secrecy and refrain from unauthorised disclosure of  information received in the context of the professional activity.
  • Keep the organisation’s assets entrusted or made available to them safe and secure and make sure that these assets are handled properly and used in line with relevant laws and regulations.
  • Refrain from overstepping the powers conferred upon them and respect the rules on authorised signatures.
  • Remain accountable for duties delegated by them to others and exercise adequate monitoring and supervision.
  • Provide stakeholders with information which is accurate, complete, objective and understandable.
  • Protect the reputation of EUROFIMA in everything that is done and said in and outside of work, conducting the job in a professional manner with the required standards of honesty, ethics and integrity.
  • Act with caution and care when engaging in social media, using sound judgement  and common sense and behave in accordance with the core values of the company. Avoid speaking on behalf of the company on personal social media accounts.

4. Confidentiality

As “confidential information” are to be considered all unpublished information (whether written   or   oral   regardless   of   manner   of   storage   and   presentation)   concerning

EUROFIMA’s transactions, shareholders, borrowers, other contracting parties and contracts which staff members have access to during the course of their work.

The basic principle of EUROFIMA’s policy on disclosure of confidential information is that confidential information must not be communicated to outside parties without authorisation. This prohibition includes all communication whether in electronic form,  hard copies or else. This implies that every staff member is responsible that confidential information be adequately stored to protect secrecy while in their possession.

Staff members are bound by the obligation of confidentiality in respect of confidential information received in the course of their activities. They shall continue to be bound by this obligation after termination of their employment contract with EUROFIMA.

EUROFIMA communications, documents and archives are confidential.

Special measures shall be taken to ensure the respect of the confidentiality of personal data, of past and present staff members.

5. External activities

Except with the prior written permission of EUROFIMA staff members should not engage in any professional activities outside of the organisation. EUROFIMA will refuse to grant such permission to staff members if it considers that the activities in question could be prejudicial to the fulfilment of the duties of the staff concerned. Outside activities that could be reasonably conceived as a conflict of interest should be avoided.

In pursuing any duty authorised external activity, staff may not misuse EUROFIMA’s resources or make improper use of its name, reputation or financial support.

Staff members may engage on a private capacity in voluntary or community-based work during their free time for charitable, religious or educational purposes, association or for any other non-profit organisation.

6. Private investments

Staff members are generally free to conduct their personal financial affairs as they see fit, with the exception mentioned hereafter:

  • Staff members shall not take personal financial interest in any kind of transactions related to EUROFIMA, whether in the form of compensation, commission, advantageous terms of purchase or sale or the like.
  • Staff members shall not avail themselves of EUROFIMA’s official channels of communication or professional bank contacts in order to manage their personal affairs. This prohibition is intended to avoid any risk of confusion between private and professional transactions.

7. General principles to be adhered when working with colleagues

The organisation strives to promote working relations based on loyalty and mutual trust. Relations between colleagues, irrespective of hierarchical levels, should be  characterised by mutual respect and courtesy, equal treatment and non-discrimination. The institutional channel to solve conflicts is that staff members first express concerns with situations which are or have a potential to be conflictive with their respective Unit Head and/or direct line manager. Unit Heads and/or direct line managers have the responsibility to make themselves available to their staff members to deal with conflict situations in an impartial and sensitive manner. Should the conflict not be resolved, concern should then be raised in confidence with the Head of Human Resources.

8. Duty to report (Whistleblowing)

If a staff member becomes aware of illegal activities, grave misconduct and/or a potential violation of this Code, policies and guidelines or the set rules and regulations of the company he/she has the duty to report it to his/her direct line manager and/or the Head of Human Resources without delay. The employee is, alternatively or in parallel, also entitled to consult the Internal Auditor.

At present the Internal Auditor of EUROFIMA is Mr. Christian Weber, Senior Manager at Deloitte AG, phone +41 58 279 6609, email

Staff members who raise a breach of professional duty concern shall be supported, i.e. respond effectively and quickly to any concerns that colleagues raise, and prompt action shall be taken when any breach of professional duties is uncovered.

9. Non-Retaliation

EUROFIMA ensures confidential treatment for and refrains from discriminatory or disciplinary action against staff members who report on alleged illegal activities, misconduct or violation. Such staff members enjoy assistance and protection and any form of retaliation is prohibited.

10. Disciplinary measures and possible legal proceedings

All staff members who knowingly or through negligence violate or breach the obligations contained in this Code may be subject, depending upon the seriousness of the infringement, to disciplinary measures - from reprimands and warnings to dismissal.  Such measures will not preclude EUROFIMA from initiating any legal proceedings that it deems appropriate.

Any legally relevant misconduct, in particular violence, sexual harassment, theft and fraud, will be brought to the attention of the relevant authorities by the recipient of the report without any hesitation.

11. Entry to Force

This Code enters into force with immediate effect and should be published on EUROFIMA’s intranet and be subject to regular review.