Implementation & Control Mechanisms

All team members of Firm are required to comply with this Code – its individual provisions as well as its spirit. We acknowledge that certain unethical conduct may be remedied without Firm having to interfere, especially when no third parties are concerned. A simple apology is often sufficient. However, we require that any material noncompliance or even suspicion thereof be reported to the EC Officer (or ABC Officer), especially if: it cannot be ruled out that a criminal or an administrative offense has been committed; a civil or other liability of Firm might arise as a consequence of such an act; the reputation of Firm might be significantly harmed; any other laws, rules of professional conduct or other legally binding regulations have been breached and the breach was not fully and completely remedied; or the intensity of the breach suggests that a simple apology may not be sufficient. Firm will treat any received complaints or information as strictly confidential. They will not be disclosed to anyone unless we would be required to do so under the law. We guarantee that no one will be harmed, sanctioned or put at a disadvantage at work for reporting noncompliance with this Code.

The Firm Global Legal Counsel is required to schedule and carry out regular audits of compliance with this Code in the Firm. All BODs are required to carry out regular audits on a local level.

Feel free to ask the EC Officer or ABC Officer any questions in regards to this Code, including the interpretation of the rules included herein or information about their application in other jurisdictions.

The BODs of individual offices are required to closely follow the applicable laws, regulations and binding rules relevant to this Code as well as general ethical standards in their jurisdictions and to inform the EC Officer or ABC Officer about any significant changes. BODs are also required to suggest modifications or amendments to this Code whenever it would get it into conflict with the local laws, regulations, binding rules or general ethical standards applicable in their jurisdiction.