1. Application

This Code of Conduct (hereafter “the Code”) sets out the rules applicable in matter of professional conduct and ethics. It is to be read especially in connection with the Internal Policy Guide and the Personnel Regulations.

This Code applies to each 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.

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 of EUROFIMA.

2. Key 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. In this regard, EUROFIMA strives to ensure the following:

  • Equal opportunities irrespective of gender, nationality, religion, age or ethnicity.
  • An open door policy allowing all staff access to the management.
  • A safe working environment place free from harassment, discrimination and retaliation.
  • Continuous professional development.

Staff members are expected to behave courteously and respectfully towards their superiors and colleagues. Persons in management position are particularly expected to behave in an exemplary manner with regards to the principle rules and values set in this Code.

3. Rules

Staff members are required to:

  • Comply with applicable laws, external and internal regulations.
  • Observe professional secrecy and respect the confidentiality of information acquired in the course of their work.
  • Make a responsible use and control of the organisation’s assets entrusted to them.
  • Refrain from overstepping the powers conferred to them and respect the rules on authorised signatures.
  • Remain accountable for tasks delegated by them to others and exercise adequate control and supervision.
  • Provide stakeholders with information which is accurate, complete, objective and understandable.

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As “confidential information” are to be considered all unpublished information (whether written or oral regardless of manner of storage and presentation) concerning EUROFIMA’s transactions, shareholders, borrowers, other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.

Staff members may engage 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 comply with in working with colleagues

The organisation strives to promote working relation based on loyalty and mutual trust. Relations between colleagues, irrespective of hierarchy levels, should be characterised by mutual respect and courtesy. 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 department head. Heads of departments 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

If a staff member becomes aware of a potential violation of this Code she/he has a duty to promptly report it to her/his Unit Head or the Head of Human Resources or the responsible member of the Management. If no constructive feedback is obtained for reported matters, Internal Audit can be contacted as a last resort.

9. Disciplinary measures

Knowingly violation of the obligations provided in this Code may result in disciplinary measures including termination of employment.

10. Entry into force

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