Code of Ethics

Every individual carries the following obligations:

1. Compliance with laws, rules and regulations. All employees observe the laws and regulations that govern their roles and activities.
2. Acting in the organisation’s best interest. No senior financial officer lets personal interests shape decisions to the detriment of the organisation, nor takes for personal gain a business opportunity that belongs to it.
3. Avoiding conflicts of interest. Employees avoid situations that create, or could create, a conflict between personal and professional relationships. Actual and apparent conflicts are dealt with ethically and openly.
4. No bribery or corruption. Employees neither demand nor accept payments or other advantages from third parties for themselves or for others, and grant no unlawful advantage to third parties in connection with their work.
5. Accurate financial reporting and disclosure. Employees meet the legal requirements and internal policies for financial statements, public disclosures and communications, so that investors and regulators receive complete, fair, accurate, timely and understandable information on the organisation’s financial condition and results.
6. Responsible banking. Our corporate responsibility rests on responsible banking: acting reasonably, ethically and with integrity in everything we do. As we grow internationally, we accept the responsibility that growth brings.
7. Governance, controls and compliance. Best-practice governance, controls and compliance are essential to us. We hold ourselves to the highest standards of integrity and honesty, so that clients can entrust us with their business. Bribery and corruption damage communities, and we enforce best practice against both.
8. Signatory authority. Each executive director may bind the bank with a sole signature for amounts up to EUR 25,000 or the equivalent in another currency. Amounts up to EUR 250,000 or the equivalent require the signatures of two executive directors. Amounts above EUR 250,000 require the signature of the president.

This code guides conduct and decisions throughout the organisation and sustains a culture of trust, integrity and responsibility.