The company is convinced that its success depends on the behavior of each of its collaborators. In addition to rigorous compliance with laws and regulations, the company is committed to respecting its own values, which shape its reputation, culture and organization.
The company is aware of the importance of promoting and ensuring its integrity in all segments of its business. The attention of all collaborators is drawn to the respect of the code of integrity and conduct and its impact on the company's reputation.
Rules of conduct are operational rules that all collaborators of the company must share and apply. Compliance with these rules is essential for the company to be in line with its values and ethical standards.
In addition, the company must adopt a responsible behavior regarding deontology (e.g. by respecting third party codes of conduct such as the Febelfin code of conduct). In order to respect their personal integrity, collaborators must always respect the ethics and rules.
The company's core values, code of conduct and ethics are a point of reference for the behavior to be adopted or the decisions to be made, especially when there are no specific rules or procedures. For specific situations, they are transposed into a policy and procedural framework specific to the company and to the issues in question (e.g. policy on conflicts of interest, policy on personal transactions, policy on complaints from retail customers, etc.).
The company's code of integrity and conduct is the official basis for the company's policy in providing its services. It serves as a guideline for the company's actions and decisions.
Integrity implies fidelity to the generally accepted standards in the financial sector, i.e., ethics, but also to the company's own values. On the one hand, compliance with ethical rules is an essential condition for operating in the financial sector. On the other hand, the company's core values ensure that it remains a unique company.
Consequently, the company's ethical rules and values must be anchored in the behavior of all its collaborators.
The company's values are binding at all levels and regardless of the nature of the functions performed.
The code of conduct clearly sets out what the company expects of everyone. Each function is responsible for implementing the code of conduct and adapting it to its specific activities.
Managers and collaborators have a key responsibility in putting the company's values and rules of conduct into practice. Management not only sets an example, but also actively encourages its collaborators by creating a climate in which core values and ethics are central.
The code of integrity and conduct applies to all officers and collaborators (whether employed or self-employed) of the company, directors, shareholders of the company with a qualifying interest, suppliers or consultants to whom certain activities or assignments are outsourced.
The company's core values are the basis for honest behavior. These values guide the behavior of managers and collaborators and serve as a benchmark for evaluating decisions at the operational, tactical and strategic levels. They are a benchmark against which to measure one's actions. The values embody what the customer can expect from the company's collaborators and what each collaborator can expect from others.
The company's core values are:
Collaborators behave in a respectful manner, with honor, respect, honesty, loyalty, empathy and humility.
Every customer is treated as the most important customer. Every customer is entitled to excellent service. The company acts towards its customers by making sure that its actions are always an added value for its customers.
"Nothing mediocre will satisfy us" (Saint Ignatius). The collaborators are always striving to achieve the highest level of quality in their work. This excellence stems from the passion of the collaborators and their pride in belonging to the company.
“Complexity is a silent killer of growth” (Jimmy Allen). The collaborators do not complicate things and avoid unnecessary formalities and develop simple solutions. They focus on the essentials and do not get lost in unimportant details. They communicate in clear language and adapt it to their target audience.
"Who doesn't move forward moves backward". Collaborators think critically and seize every opportunity to optimize performance, operations, services and customer experience, to simplify and to clarify.
The firm's rules of conduct include generally accepted standards in the investment services and insurance industries, with which the firm must comply. The integrity of the firm and its collaborators are inextricably linked.
The company supports initiatives by financial sector organizations that promote good practices to strengthen integrity and related trust.
The company considers the interests of its clients and itself as a whole. The company ensures that the client's interest is central to the development and offering of products and services and to the advertising of its products and services.
Each collaborator seeks to understand the needs, expectations and interests of clients in order to provide them with products and services that are clearly adapted to their situation.
The fair treatment of clients must be guaranteed. Each client is considered as the most important client. The excellent as the highest degree of quality guides the work of every collaborator.
Protecting the interests of clients is a commitment that involves :
Knowing and comply with applicable laws and regulations;
Offering services and products that serve the interests of the clients;
Ensuring that customers can understand the products;
Applying fair and transparent pricing;
Never acting on behalf of a client without their authorization.
The company is committed to providing clear, accurate and complete information to clients on a regular basis and to maintaining a regular dialogue with them.
The company makes every effort to preserve client confidentiality. This implies for the collaborators to :
Treat all client relationships as strictly confidential;
Only share client data within the company with those collaborators who really need to have access to it to best serve the customer's interests;
Collect only the data necessary to fulfill a specific business purpose;
Strictly respect the company's information protection system.
All commercial communications to clients about products and services must be transparent and clear. The company strives to respond to client questions as quickly and effectively as possible.
The company deals fairly with client complaints. It rectifies things as quickly as possible if errors are identified.
If conflicts of interest cannot be avoided, the client's interest always takes precedence. In the professional sphere, the company's interest must take precedence over the personal interest of a collaborator or a third party. This personal interest may include the interest of a shareholder, a director or a collaborator.
In order to avoid conflicts of interest, the company has a strict policy on financial and non-financial gifts from clients and suppliers.
Each collaborator supports the company in its fight against economic crime, including fraud, money laundering and terrorist financing, corruption and influence peddling.
Each collaborator is constantly vigilant and contributes to the fight against economic crime.
Each collaborator ensures that the procedures and controls for identifying the client and her characteristics ( KYC : Know Your Customer ) are well implemented.
The company is committed to respecting sanctions and embargoes. The company will make every effort to be aware of applicable embargoes and economic sanctions.
The IT organization keeps abreast of the evolution of risks, is responsible for raising awareness, informing and training collaborators and maintaining the various plans
The company and its collaborators never engage in any form of corruption or bribery.
Personal data are always processed in accordance with the client's expectations.
The company never sets up constructions, mechanisms or any other type of services that organize tax evasion.
If tax fraud is suspected or observed, the company will refrain from doing so and, if necessary, will inform the competent authorities in the context of the fight against money laundering and the financing of terrorism.
In the context of the global fight against tax fraud and transparency mechanisms, the company ensures that the competent authorities receive the necessary reports. It does not resort to any artifice that could undermine this tax transparency.
The company will not allow market abuse through the misuse of inside information or market manipulation.
The company complies with all rules against market abuse, including rules against insider trading and market manipulation.
The firm acts promptly and fairly with respect to the markets and professional counterparties. It follows the directives of the markets for the execution of orders.
The company does not propagate false or biased information.
The company never acts with the intention of moving a price in the market to a level that does not reflect market supply and demand. It never engages in transactions whose objective is to fictitiously alter the market value of assets or liabilities in order to generate revenues or profits, or to avoid losses. In general, the company never interferes with the proper functioning of the markets through any behavior. It always trades in good faith and seeks to maintain stability, liquidity and transparency in the markets.
If market abuse is suspected or found, the company shall inform the competent authorities.
In cooperation with other financial institutions, the company does everything possible to prevent the financial system from being misused for money laundering or terrorist financing. For this reason, the company always knows all its clients in order to assess the risk of the relationship with them and analyzes each atypical transaction.
The company never sets up constructions, mechanisms or any other type of services that organize money laundering or the financing of terrorism or that were known or should have been known to contribute to it.
If an act of money laundering or terrorist financing is suspected or observed, the company will inform the competent authorities in the context of the fight against money laundering and terrorist financing.
The company applies the local and international restrictive measures in force (sanctions and embargoes) to the services it offers to its clients and in its relations with other parties.
The company refrains from any act of direct or indirect discrimination. The company wants everyone to feel free to be themselves. Everyone is therefore entitled to her own convictions, but these may not conflict with a professional attitude.
The company's collaborators always apply the internal framework and respect the legal rules. They apply them in their own activities as well as in individual situations and decisions.
If they feel that there may be a conflict between the internal framework and the legal rules, they always apply the higher rule. The legal rules take precedence over the internal framework and the standards of the code of integrity and conduct take precedence over the rest of the internal framework. In case of doubt or impasse, collaborators should contact their superior or a member of the compliance function.
Collaborators do not engage in market securities or financial transactions for their personal account based on confidential information obtained in the course of their professional activities. Collaborators do not disclose confidential information to family members or relatives. Collaborators shall follow policies and procedures regarding trading and dealing on her own behalf.
Each collaborator respects her commitments in dealing with partners and suppliers, is fair to them and makes choices based on objective criteria.
Any act of corruption is prohibited. Any collaborator who is subject to services or solicitations from third parties shall inform her superiors.
Gifts offered to our clients or their representatives must remain limited. The same applies to people with public authority, civil servants or similar.
Each collaborator shall take care to preserve the tangible and intangible assets of the company, whether financial or material, and shall use them in a reasonable manner. No one shall misuse the goods or services made available to them.
Everyone seeks to use resources sparingly and takes into account the environmental dimension of their decisions.
Each collaborator behaves in a rigorous and responsible manner with other collaborators. This involves :
Being familiar with and strictly adhere to policies and procedures and other instructions given by actual management in relation to work activities;
Respecting the rules of professional secrecy;
Treating colleagues with respect in all circumstances;
Working in a way that puts colleagues in the best position;
Ensuring that relationships between colleagues are always professional;
Listening to and considering the opinions and contributions of other collaborators even if they have differing opinions.
The company rejects all forms of discrimination.
The company is committed to providing a work environment in which all collaborators are treated with respect and dignity.
Company collaborators are required to:
Promote fair treatment of applicants in the recruitment process, systematically base their judgment on objectively assessed competencies, ensure equal opportunities and define compensation conditions in a fair and equitable manner;
Reject any form of discrimination, intimidation or harassment of other collaborators, clients or any person having a relationship with the company, based on race, color, creed, religion, nationality, ethnic origin, age, gender, sexual orientation, marital status, disability or political opinion;
Not engage in sexual harassment or conduct that could be considered sexual harassment.
The company ensures the safety and security of the workplace in the course of daily activities. It seeks to improve the working conditions of each of its teams.
The company reports any activity that may involve a threat to the physical safety of a collaborators or an outside person on the company's premises.
Although the company's rules of conduct and values should guide collaborators in making decisions, there is no one rule for every specific situation. Collaborators must therefore use their own personal judgment. When in doubt about what to do, employees should ask themselves whether an action is appropriate and, if so, seek the advice of their colleagues.
Ethics is a fundamental requirement for everyone working for or with the company. Every collaborator is obliged to respect it.
The rules on incompatibilities apply to directors and members of the company's management committee.
Among these persons, a distinction must be made between (i) non-executive directors of the company and (ii) persons who take part in the effective management of the company. In principle, the members of the executive committee of the company are automatically considered to be persons involved in the effective management of the company.
Where a legal entity is appointed as a director or member of the management committee, the permanent representative appointed by the legal entity in accordance with the applicable law shall be treated as a director of the company.
The company shall ensure that it complies with the applicable law and regulations regarding incompatibilities (e.g., upon adoption of this code, Articles 34 et seq. of the Law of October 25, 2016 on the activity of providing investment services and on the status and supervision of portfolio management and investment advisory companies).
In accordance with the law, the company states that directors and members of the executive committee are authorized in principle to hold administrative or management positions in other industrial, commercial or financial companies. This freedom is, however, subject to the conditions and limits set out below, where applicable, in addition to the conditions and limits provided for by law.
The exercise of any mandate or function involving participation in the day-to-day management of another external company (hereinafter, "external executive mandates") is subject to authorization by the Board of Directors.
The exercise of any mandate or function that does not involve participation in the day-to-day management of another outside company, not expressly prohibited by law, is not subject to authorization by the Board of Directors. The person concerned is obliged to inform the Board of Directors prior to the commencement of the exercise of such mandate.
The members of the company's executive committee and, where applicable, the persons participating in its effective management, may only hold an external executive function in the cases listed exhaustively by law.
The company appreciates in concreto the impact of the external executive position on the individual's availability to fully perform her duties within the institution.
This obligation does not apply to outside functions for which the person concerned is appointed on the company's behalf. These functions are presumed to be an extension of the person's duties within the company and not to affect the person's availability.
Where an executive of the company holds an external executive position in another company with which the company does not have close links:
The company can only provide a service to this other company under normal market conditions;
The effective managers refrain from any intervention, both within the company and within the other company in which the external executive mandate is exercised, concerning the provision of the service.
The company discloses the external mandates (executive and non-executive) held by the members of its Board of Directors and by its executive officers, with the exception of mandates held in undertakings for collective investment and in asset management companies.
The executive committee is responsible for publishing these external mandates on the company's website and ensuring that it is updated annually.
Advertising includes the following:
The names and functions of the members of the board of directors and effective officers of the company holding an external mandate;
The name of the other company, the location of its registered office, the field of its activities and, if applicable, the fact that any financial instruments it has issued are listed on a regulated market;
The position held by the individual at the other company;
The existence, if any, of an equity link held by the firm outside of its trading book and the significance of that link.
The executive committee is competent to issue the authorization to exercise an external principal.
The person wishing to exercise an external mandate subject to the authorization of the Board of Directors shall send a file to the latter by e-mail. This file contains:
The information and documents that allow the executive committee to make an opinion on the legality of the mandate, the availability and the absence of conflicts of interest and the measures suggested in this regard;
The nature and importance of the external mandate (in particular but not only in terms of the number of days per year), the foreseeable frequency of the meetings that it entails, the overall estimate of the impact of all the external functions performed by the executive concerned on her availability, as well as any other element that it would consider or that the executive committee might consider relevant.
The executive committee shall determine whether to authorize the exercise of an outside appointment by considering:
First, if the outside agency is not prohibited by applicable law;
Second, whether the person will be available to perform her duties in the company.
If any of these conditions are not met, the executive committee shall refuse to authorize the external mandate.
Secondly, the executive committee ensures that the mandate does not generate a conflict of interest. To this end, if the company provides a service to the other company, it designates one or more persons who will be responsible for the interventions relating to this other company. He also inquires about the person who will be responsible for the interventions within this other company.
If the executive committee authorizes the external executive mandate, it shall immediately publish it on its website.
The executive committee shall communicate its decision to the person by e-mail within 15 days of receiving the file.
The person exercising an external mandate has the obligation to inform the executive committee of any significant change relating to any of the elements of the file submitted in its application for authorization. In such cases, the executive committee will review the case.
Through its chairman, the Board of Directors notifies its supervisory authority (currently the FSMA) of external executive and non-executive mandates without delay by ordinary mail and by e-mail.
This notification must contain the following:
The precise identification of the concerned manager and her function within the company;
The precise identification of other companies in which the executive concerned holds external mandates;
The characteristics of the external mandates that it exercises with these other companies;
The procedure for authorization by the company's bodies, where applicable;
The method of advertising used, where such advertising is required.
The rules relating to incompatibilities are established and determined by the company's Board of Directors. The Board of Directors has sole authority to approve any change in these rules.
Each year at its ordinary general meeting, the Board of Directors ensures that the rules it has established are still appropriate to the company's situation.
Each collaborator respects the Code of Conduct and contributes to building, maintaining and improving the company's reputation.
Collaborators shall collectively and individually ensure that the Code of Conduct is applied.
When evaluating collaborators, managers emphasize the importance of embodying the company's values and emphasizing appropriate behaviors as described in the Code of Conduct.
Collaborators have a duty to:
Know and respect all the rules of the Code of Conduct;
Take the necessary training to understand their responsibilities;
Be vigilant and challenge their colleagues if they are not operating in the spirit of the Code of Conduct;
Use the whistleblower procedure if necessary.
Appropriate measures are taken, in compliance with applicable regulations and the company's human resources policy, against collaborators who do not behave in accordance with the Code of Conduct.
The company promotes a culture of dialogue and exchange in which collaborators feel free and safe to express themselves not only directly to their colleagues, but also to report practices that may be contrary to integrity. The company encourages and values the sharing of good examples and best practices.
To strengthen this dialogue and exchange, collaborators actively give and receive feedback.
Any breach of ethics must be reported. It is important that the violation is reported, regardless of whether it was committed by the collaborator, a client, another collaborator or an external partner. This ensures that the damage is kept to a minimum and that similar incidents do not occur in the future.
The right to report is a right given to each individual to express her opinion when he or she considers that he or she has good reason to believe that an instruction received, an operation or, more generally, a particular situation of which he or she has personal knowledge does not appear to comply with the rules governing the conduct of the company's activities. This right must be exercised in a responsible, disinterested, good faith, non-defamatory and non-abusive manner.
The company protects whistleblowers from retaliation or punishment and guarantees strict confidentiality of their identity.
Internally, the right to report can be done:
The alert, its author and any third party involved in the alert are treated confidentially. Where possible, an acknowledgement of receipt of the report will be sent to the reporter within 7 days of receipt of the report. The Compliance Officer will provide feedback to the whistleblower within 3 months of the acknowledgement of receipt of the report, or if no acknowledgement of receipt is sent to the whistleblower, within 3 months of the expiry of the 7 day period following the report.
Failure to report a violation when you knew about it is considered negligence.
Specific procedures may provide for a different way of reporting offences, for example in relation to money laundering.
The Board of Directors determines and monitors the company's code of integrity and conduct. The Management Committee takes the necessary steps to translate the Code of Integrity and Conduct into practices and procedures.
Every collaborator of the company must put the Code of Integrity and Conduct into practice and apply these principles in his or her own actions and decisions. Managers and collaborators have a responsibility to They set an example and encourage their colleagues by creating a climate in which core values and other principles are central.
In case of doubt, question or uncertainty regarding this Code of Integrity and Conduct, the company's values and rules of conduct, collaborators, members of the Executive Committee and members of the Board of Directors and shareholders should ask the company's Compliance Officer. The Compliance Officer responds within a reasonable period of time.
The actual management and the responsible collaborators have a specific role to play in disseminating and raising awareness of the code of integrity and conduct among collaborators and external partners. In addition, they ensure that the Code of Integrity and Conduct is given a prominent place in the selection and management of external partners and collaborators.
The Compliance function also monitors compliance with core values and other requirements.
The code of integrity and conduct is also part of the internal audit's area of investigation