Ethics – working with integrity
The ECB is committed to promoting integrity, good corporate governance and the highest ethical standards.
A strong business culture has to be complemented by a strong ethical culture
Our high-level officials and staff members perform their duties impartially and with integrity and behave in a manner befitting the character of the ECB as an institution of the European Union.
What do ethics mean at the ECB?
Here at the ECB our conduct is governed by ethical principles and rules, which are set out in the Ethics Framework for all staff and the Code of Conduct for high-level ECB officials.
Conflicts of interest
Managing conflicts of interest properly is arguably the most important principle of ethical conduct. It relates directly to our value of integrity and underpins many other elements of our ethical rules. These rules outline principles and standards of conduct for avoiding situations that give or may be perceived to give rise to conflicts of interest. All ECB high-level officials and staff members must perform their professional duties impartially and objectively.
Gifts and hospitality
In order to avoid even the appearance of conflicts of interest, staff members are generally not permitted to accept any advantage connected with their employment at the ECB. This rule is particularly relevant when staff members are interacting with the private sector, supervised banks or current or potential suppliers. It is a restriction that applies to all benefits regardless of nature, including gifts and hospitality.
High-level officials are also required to respect the principles of independence and impartiality, and to avoid conflicts of interest related to accepting advantages. Owing to their prominent role and function, however, they may accept certain hospitality and gifts of minor value.
Staff members are required to request authorisation before engaging in any external activity that is of an occupational nature, or that goes beyond what can reasonably be considered a leisure activity. This is to ensure that the activity in question does not create a conflict of interest.
Every year, high-level officials report on any activities that they performed in an official or personal capacity as part of their declarations of interests.
After leaving the ECB
High-level officials and staff members leaving the ECB may be subject to a cooling-off period. They may be required to wait for a certain period of time before taking up new employment, depending on their function at the ECB, to avoid the situation of “revolving doors”. Such restrictions apply in particular to management and staff working in banking supervision, who may be subject to cooling-off periods of up to two years.
In addition to this measure, high-level officials and staff members continue to be bound by their professional secrecy obligations even after they have stopped working for the ECB. They may not disclose any non-public information that they could have come into contact with while carrying out their duties. High-level officials and staff members remain subject to compliance monitoring exercises associated with their private financial transactions for a defined period of time after leaving the ECB.
Staff members have to conduct procurement procedures in accordance with specific rules and provisions, and maintain objectivity, neutrality, transparency and fairness. They are also expected to avoid and report conflicts of interest. To this end, staff members involved in procurement procedures are required to complete a certification form to confirm that they have understood the rules surrounding conflicts of interest and have no such conflicts with potential bidders.
Our recruitment procedures include an assessment of conflicts of interest related to the candidate’s previous jobs and their personal relationships with current ECB staff members.
Interacting with third parties
Staff members and high-level officials are required to be cautious and transparent about whom they meet, when they meet and what they say. High-level officials and staff are expected to follow guiding principles and specific house rules with respect to speaking engagements and attending meetings.
The meeting diaries of the members of the ECB’s Governing Council, Executive Board and Supervisory Board are published regularly, in the interests of transparency and accountability.
The diaries of the remaining Governing Council and Supervisory Board members can be found on the respective national central banks’ or national supervisors’ websites.
Private financial activities
Staff members and high-level officials are expressly prohibited from taking advantage of inside information to carry out any private financial transaction or to recommend or advise against such transactions. The ECB has in place strict and detailed rules concerning private financial transactions. The rules include guidelines for declaring account details and for reporting on and authorising financial transactions. Compliance with these rules is monitored rigorously.
Integrating ethics at all levels
It is the individual responsibility of each ECB high-level official and staff member to comply with the ethical rules. These rules need to be supported by well-functioning monitoring and reporting mechanisms and procedures in order to be implemented adequately and consistently.
As part of this, high-level officials are required to complete declarations of compliance with the Code of Conduct and declarations of interests, which include information on previous occupational activities, private activities and financial interests.
To further strengthen the ethical rules, an enhanced whistleblowing framework has been introduced that allows staff to report breaches anonymously.
The following two bodies play a key role in ensuring the ethical rules are adhered to:
A dedicated Ethics Committee provides advice and guidance to the ECB’s high-level officials and ensures that the ethical rules are implemented adequately and coherently.
The Committee is composed of three external members: individuals of high repute whose independence is beyond doubt and who have a sound understanding of the objectives, tasks and governance of the ECB, the European System of Central Banks (ESCB), the Eurosystem and European banking supervision. The Committee is chaired by Patrick Honohan and includes two further members: Virginia Canter and Erkki Liikanen.
Compliance and Governance Office
The Compliance and Governance Office provides guidance and advice to members of staff, raises awareness of ethical issues and monitors compliance with the Ethics Framework.
In order to maintain the ECB’s ethical culture and to enhance employees’ understanding of the reasons behind the ethical rules, the Office conducts regular training courses for ECB staff. This helps staff to understand and assimilate their ethical responsibilities and to think, respond and make decisions ethically.
What do ethics mean for the Eurosystem and European banking supervision?
Over recent years, the public has become more aware of ethics rules and issues related to corporate governance, particularly following the establishment of European banking supervision. In order to adequately mitigate related reputational risks, the Governing Council decided that this increased level of public awareness and scrutiny should be mirrored by an adequate and common corporate ethical culture designed to safeguard the integrity of the ECB, the ESCB, the Eurosystem and European banking supervision.
The Governing Council has therefore established certain ethical standards for all central banks of the Eurosystem and for European banking supervision. These rules concern, in particular, the prevention of misuse of inside information, the management of conflicts of interest, and the acceptance of gifts and hospitality.
- Guideline (EU) 2015/855 of the ECB of 12 March 2015 laying down the principles of a Eurosystem Ethics Framework (ECB/2015/11)
- Guideline (EU) 2015/856 of the ECB of 12 March 2015 laying down the principles of an Ethics Framework for the Single Supervisory Mechanism (ECB/2015/12)
- Ethics Framework for the SSM – Implementation practices
An Ethics and Compliance Officers Task Force, which is made up of chief compliance or ethics officers from the Eurosystem and European banking supervision, helps – based on practical experience gained – to further enhance and harmonise ethics and compliance standards.