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.
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