Integrity in every decision.
Responsibility in every relationship.
Our standards for ethical behaviour, professional responsibility and trusted business relationships across the ECB group.
Standards that guide our actions
This Code sets out the conduct expected of directors, management, employees and representatives acting on behalf of the relevant ECB group entity. It guides how we serve clients, work with business partners and protect the integrity of our activities.
Integrity & lawful conduct
Act honestly, exercise sound judgement and follow applicable laws and the policies of the relevant ECB entity. Do not misrepresent authority, regulatory status, services or transaction outcomes.
Fair treatment & respect
Treat clients, colleagues and counterparties fairly and professionally. Do not tolerate discrimination, harassment, intimidation, exploitation or misleading sales practices.
Conflicts of interest
Disclose actual, potential or perceived conflicts promptly. Personal interests, outside roles and related-party relationships must not improperly influence decisions. Obtain the appropriate review before proceeding.
Bribery, gifts & hospitality
Do not offer, request or accept bribes, kickbacks or improper advantages. Gifts, hospitality and expenses must have a legitimate purpose, be proportionate and meet applicable approval and recording requirements.
Confidentiality & information security
Access and share client, employee and business information only for authorised purposes. Use approved systems, protect credentials and report suspected data loss or unauthorised access. Confidentiality duties continue after a relationship ends.
Financial crime prevention
Follow applicable AML / CFT, KYC, beneficial ownership, sanctions and transaction-review procedures. Escalate unusual activity through the appropriate compliance channel. Do not bypass checks, conceal information or disclose protected reporting activity.
Accurate records & communications
Maintain complete and accurate records of decisions, transactions, fees and approvals. Do not falsify documents or make unsupported claims. Communicate commercial terms, risks and conditions clearly and use authorised public communications.
Responsible authority & resources
Act within delegated authority and obtain required approvals. Protect funds, systems and company assets from misuse. Use confidential or non-public information only for authorised business purposes, never for improper personal advantage.
Raise concerns. Act responsibly.
Raise suspected misconduct, conflicts, financial crime or control failures promptly through an appropriate manager or compliance contact. Do not retaliate against anyone who raises an honest concern or participates in a review.
Cooperate with authorised reviews and preserve relevant records. Where a breach is established, corrective or disciplinary action may follow under applicable law and the relevant entity’s procedures.
Reporting guidance
For guidance on the appropriate reporting contact, email [email protected]. In an initial email, describe the concern briefly without including passwords, full account details or sensitive documents. If the concern involves your usual contact, request an alternative compliance or leadership contact through an established ECB business channel.
Request reporting guidance