1.1   This Code shall apply to the members of the Governing Council and the members of the Supervisory Board when exercising their functions as members of a high-level ECB body, as well as to the members of the Executive Board. It also covers members of the Governing Council and members of the Supervisory Board when acting as members of the Steering Committee and the Mediation Panel where applicable, as well as representatives of national central banks, where the national competent authority (NCA) is not the national central bank (NCB), participating in meetings of the Supervisory Board (hereinafter the ‘members’).

1.2   It shall also apply to persons replacing the members in meetings of the Governing Council or the Supervisory Board (hereinafter the ‘alternates’) in the performance of their duties and responsibilities relating to these high-level bodies where explicitly provided for in this Code. For the purposes of this Code, ‘high-level ECB bodies’ shall mean the Governing Council of the ECB, the Executive Board of the ECB and the Supervisory Board of the ECB.

1.3   This Code shall not apply to accompanying persons attending meetings of the Governing Council or the Supervisory Board. However, accompanying persons shall sign a declaration of ethical conduct covering the general principle of avoidance of conflicts of interest, the prohibition from using confidential information, and the rules on professional secrecy, prior to their first participation in any meetings (hereinafter ‘Declaration of Ethical Conduct’) (14).

1.4   The members of the General Council shall be invited to sign the Declaration of Ethical Conduct. Moreover, the members of the Audit Committee, the Ethics Committee, the Administrative Board of Review (ABoR), and their alternates, where applicable, shall be required to sign the Declaration of Ethical Conduct.

1.5   ECB staff members attending meetings of high-level ECB bodies are adequately covered by the Ethics Framework and therefore shall not be required to sign the Declaration of Ethical Conduct.

1.6   In the event of any doubt relating to the provisions laid down in this Code or their practical application, the opinion of the Ethics Committee established by Decision (EU) 2015/433 (ECB/2014/59) (15) shall be sought.

2.1   Members and alternates shall inform the Ethics Committee without undue delay of any impediment to comply with this Code, including any impediment arising from conflicting provisions of national law.

2.2   This Code shall be without prejudice to stricter ethical rules applicable to members and alternates by virtue of national law.

3.1   Members and alternates shall carry out their duties and responsibilities in strict compliance with the Treaty on European Union and the Treaty on the Functioning of the European Union, the Statute of the European System of Central Banks and of the European Central Bank (hereinafter ‘the Statute of the ESCB’), Council Regulation (EU) No 1024/2013, the Rules of Procedure of the European Central Bank (16) and the Rules of Procedure of the Supervisory Board of the European Central Bank (17), as applicable.

3.2   In carrying out their duties and responsibilities, members and alternates shall observe the highest standards of ethical conduct and integrity. They are expected to act honestly, independently, impartially, with discretion and without regard to self-interest. They shall be mindful of the importance of their duties and responsibilities, shall take into account the public character of their functions and shall conduct themselves in a way that inspires ethical conduct within the Eurosystem, the European System of Central Banks (ESCB) and the SSM, and maintains and promotes public trust in the ECB.

4.1   Bearing in mind the professional secrecy requirements deriving from Article 37 of the Statute of the ESCB and Article 27(1) of Council Regulation (EU) No 1024/2013, members and alternates shall not disclose any information covered by the obligation of professional secrecy obtained in the exercise of their duties and responsibilities that has not been made public and is not accessible to the public (hereinafter ‘confidential information’) except deliberately as part of the agreed communication strategy of the ECB. In particular, they shall not disclose confidential information in public speeches or statements, or to the media, and shall treat such information in accordance with agreed internal rules on the treatment of sensitive ESCB and SSM information. Members and alternates shall continue to be subject to these professional secrecy requirements in accordance with Union law even after their duties and responsibilities carried out for the ECB have ceased.

4.2   Members and alternates shall take all necessary measures to ensure that the staff members of their respective NCB and/or NCA are given access to confidential information only for the performance of the duties of the staff members and in accordance with applicable confidentiality policies, and are made aware of and strictly observe the professional secrecy requirements set out in Article 4.1.

5.1   Members and alternates shall respect the separation of the ECB’s specific tasks concerning policies relating to prudential supervision from its tasks relating to monetary policy, as well as other tasks. Where applicable, they shall comply with Decision ECB/2014/39 of the European Central Bank (18) and any rules adopted by the ECB pursuant to Article 25(3) of Council Regulation (EU) No 1024/2013.

5.2   In carrying out their duties and responsibilities, members of the Supervisory Board and their alternates shall take into account the objectives of Council Regulation (EU) No 1024/2013 and shall not interfere with non-supervisory tasks of the ECB, while duly respecting the specific duties and responsibilities of the Vice-Chair of the Supervisory Board.

7.1   Members and alternates shall ensure that any private activities, whether remunerated or not, do not have a negative impact on their obligations and will not damage the reputation of the ECB. For the purposes of this Code, ‘private activities’ shall mean any other activity undertaken by a member or alternate not in an official capacity.

7.2   Members and alternates may undertake private activities in public, international or non-profit organisations as well as teaching and scholarly activities, provided that these are not activities that raise conflict of interest concerns, for example, activities related to supervised entities or counterparts to the Eurosystem in monetary policy or foreign exchange operations. In the event of private activities as specified in Article 11.1 of the Statute of the ESCB, the members of the Executive Board require the explicit approval of the Governing Council.

7.3   Members and alternates may accept remuneration and the reimbursement of expenses for private activities, provided that such remuneration and expenses are commensurate with the work performed and remain within customary limits.

7.4   Members and alternates shall abstain from official mandates which may hinder their independence and shall resign from any such official mandate that they hold. For the purposes of this Code, ‘official mandates’ mean any external activities performed by a member or alternate in an official capacity, i.e. as part of their duties and responsibilities.

7.5   Members and alternates shall notify the Ethics Committee in writing of any private activities which they intend to perform. They shall also provide it with an annual update of their ongoing private activities and official mandates.

9.1   Members and alternates shall carry out their duties and responsibilities as, and consider themselves in public appearances to be, representatives of a high-level ECB body.

9.2   When making public statements on matters relating to the Eurosystem, the ESCB or the SSM, members and alternates shall have due regard to their role as representatives of a high-level ECB body.

9.3   In scientific or academic contributions, members and alternates shall make clear that such contributions are made in a personal capacity and do not represent the views of the ECB.

10.1   Each member shall on an annual basis submit to the Ethics Committee, for assessment and onward submission to the President, a signed Declaration of Interests which shall include information about the member’s previous occupational activity, private activities, official mandates and financial interests, as well as about any gainful occupational activity of their spouse or partner that may raise conflict of interest concerns (hereinafter the ‘Declaration of Interests’). Each member shall also submit a list of private financial transactions carried out during the year immediately preceding the Declaration of Interests in an annex to the Declaration of Interests (hereinafter ‘Annex I to the Declaration of Interests’). Additionally, each member shall submit, to the best of their knowledge, information about any private financial transaction carried out during the year immediately preceding the Declaration of Interests, by their spouse, partner or minor children, that exceeds EUR 10 000 per transaction, which shall be submitted in a separate annex on a confidential basis to the Ethics Committee (Annex II to the Declaration of Interests). The Declaration of Interests (20) and Annex I to the Declaration of Interests submitted by each member shall be published on the ECB’s website and shall be without prejudice to any requirement to submit a wealth declaration under applicable national rules or contractual obligations.

10.2   The ECB shall process and retain any personal data collected in the Declarations of Interests in accordance with data protection legislation applicable to the ECB.

11.1   Members and alternates shall avoid any situation which may raise conflict of interest concerns. A conflict of interest concern arises where a member or alternate has personal interests that may influence, or may be perceived as influencing, the impartial and objective carrying out of their duties and responsibilities and also extends to, but is not limited to, their direct family members (any parent, child, brother or sister), spouses or partners of the member or the alternate. In particular, members and alternates may not use their involvement in a decision-making process, or the professional information they possess, to gain personal advantage of any kind. A conflict of interest does not exist where a member or alternate is only concerned as part of the general public or a broad class of persons.

11.2   Members and alternates shall disclose in writing, without undue delay, to the President or Chair of the relevant high-level ECB body and to the Ethics Committee any situation that may raise conflict of interest concerns. In particular, they shall recuse themselves from taking part in any discussions, deliberations or votes in relation to any such situation and shall not be provided with any related documentation.

13.1   Members and alternates shall not solicit, and shall exercise caution when offered, any advantages which are connected in any way with the duties and responsibilities conferred on them. For the purpose of this provision, ‘advantages’ shall mean any gift, hospitality, or other benefit, whether financial or in kind, which is not the agreed compensation for services delivered and to which the recipient is not otherwise entitled.

13.2   An advantage, offered or given to a member or an alternate or to any direct family member, spouse or partner, which is connected in any way with the carrying out of the duties and responsibilities of that member or alternate, may be accepted by them in the following circumstances:

13.3   The acceptance of an advantage shall not, in any event, impair or influence the objectivity and freedom of action of a member or alternate and shall not create an inappropriate obligation or expectation on the part of the recipient or the provider.

13.4   The members of the Executive Board, the Chair of the Supervisory Board and the ECB’s representatives on the Supervisory Board shall without undue delay register with the Secretary of the Ethics Committee any gift or offer of a gift received, whatever its value. Other members and alternates shall be subject to the applicable national procedural rules on the registration of gifts.

14.1   Members and alternates shall be confident that any award, honour or decoration is compatible with their public status and does not compromise their independence or raise conflict of interest concerns.

14.2   Members and alternates shall hand over to the respective institution of which they are a representative, or donate to charity, any sum of money or valuables that a prize is endowed with, which they receive in connection with their duties and responsibilities as a member or alternate of a high-level ECB body.

15.1   Members and alternates, bearing in mind their obligations to respect the principle of independence and to avoid conflicts of interest, may accept invitations to widely attended events such as conferences, receptions or cultural events, if their participation is not adverse to the ECB’s interest, and shall observe particular prudence with regard to individual invitations. Members and alternates shall not accept any invitations or payments that are not in compliance with these rules and shall inform their counterparts accordingly.

15.2   Members and alternates may not accept payment of travel and/or accommodation costs by the organisers of any event referred to in Article 15.1. Any fees which may be accepted by members and alternates for lectures and speeches undertaken in their official capacity shall be used by the ECB or the relevant NCB or NCA for charitable purposes.

15.3   If consistent with internationally accepted custom, Articles 15.1 and 15.2 shall apply equally to the accompanying spouses or partners of members and alternates in relation to invitations extended to them.

16.1   Members and alternates shall not use confidential information for their own benefit or for the benefit of a third party, including when carrying out private financial transactions and irrespective of whether such transactions are carried out directly or via a third party, at their own risk and on their own account, or at the risk and on the account of a third party. When conducting private financial transactions, members and alternates shall employ caution, exercise restraint and have a medium to long-term investment horizon.

16.2   It is recommended that members and alternates place their investments under the control of one or more recognised portfolio managers who have full discretion to manage assets which go beyond those required for ordinary, personal and family use. If they have been authorised by the Ethics Committee, such discretionary asset management arrangements shall be exempted from the restrictions set out in this Article 16 (other than the restriction on use of confidential information).

16.3   Members and alternates shall not undertake any private financial transactions other than:

16.4   Members and alternates shall not sell any investment referred to in Article 16.3 until one year after the date of purchase. The one-year minimum holding period shall not apply if the corresponding sale transaction is related to unforeseen personal expenditures or is to cover current or future expenses relating to non-investment purposes or is part of a systematic and periodic investment plan, which has been agreed with a bank or financial adviser.

16.5   Members and alternates shall not carry out any private financial transactions under Article 16.3 in the seven days before a monetary policy meeting of the Governing Council (hereinafter the ‘embargo period’).

16.6   Members and alternates shall give 30 days’ non-retractable advance notice to the Ethics Committee before executing any transaction exceeding EUR 50 000 in the instruments listed in Article 16.3. The advance notice shall not be given during an embargo period. The advance notice shall not be required for a sale transaction related to unforeseen personal expenditures or to cover current or future expenses relating to non-investment purposes.

16.7   Financial assets or instruments other than those listed in Article 16.3, which were acquired by a member or alternate prior to 1 January 2023 or prior to the start of their term in office, or which came into their possession at a later point in time due to circumstances over which they had no influence, may be kept, but the sale of, or the exercise of any rights attached to, such financial assets or instruments requires the prior authorisation of the Ethics Committee. However, a member or alternate shall sell instruments issued by regulated entities prior to the start of that member’s or alternate’s term of office.

16.8   The members of the Executive Board, the Chair of the Supervisory Board and the ECB’s Representatives on the Supervisory Board shall be subject to the compliance monitoring procedures in relation to their private financial transactions as laid down in the Ethics Framework of the ECB.

16.9   Members to whom Article 16.8 does not apply, and alternates, shall be subject to compliance monitoring in relation to their private financial transactions as laid down in the applicable national procedural rules and shall submit to the Ethics Committee on an annual basis signed confirmation that they have complied with the applicable rules on private financial transactions and that the compliance monitoring in relation to their private financial transactions has been conducted in line with the applicable national procedural rules (22).

16.10   Members and alternates shall be subject to the restrictions set out in Articles 16.3, 16.4 and 16.6 for a period of six months after the end of their term of office.

16.11   The restrictions set out in this Article 16 shall not apply to the following transactions for private purposes:

17.1   Members shall inform the President or Chair of the respective high-level ECB body and the Ethics Committee in writing of their intention to engage in any gainful occupational activity in the two-year period from the end of their term of office or from the date of cessation of their function as a member of a high-level ECB body.

Moreover, they may only engage in a gainful occupational activity with:

Moreover, members of the Executive Board and of the Governing Council may only engage in a gainful occupational activity with:

17.2   Alternates shall inform the President or Chair of the respective high-level ECB body and the Ethics Committee in writing of their intention to engage in any gainful occupational activity in the one-year period from the date of their ceasing to act in that capacity.

Moreover, they may only engage in a gainful occupational activity with:

Moreover, alternates to meetings of the Governing Council may only engage in a gainful occupational activity with:

17.3   Members and alternates shall request the Ethics Committee to issue an opinion on the cooling-off periods applicable to them under this Article prior to taking up a specific prospective gainful occupational activity. The Ethics Committee may recommend in its opinion:

17.4   Without prejudice to applicable national rules, for the duration of their cooling-off period members and alternates should be paid appropriate compensation by their respective employer institutions from the end of their term with their institution until the end of the applicable cooling-off period. This compensation should be paid irrespective of the receipt of an offer to engage in a gainful occupational activity. Accordingly, members and alternates may request an opinion from the Ethics Committee on the appropriate level of compensation in respect of cooling-off periods.

17.5   Where during a cooling-off period a member or alternate takes up a gainful occupational activity not covered by Articles 17.1 and 17.2 above and the amount of the net monthly remuneration received from the gainful occupational activity together with the compensation provided for the cooling-off period exceeds the net monthly remuneration which the member or alternate received during their last year of office, the excess shall be deducted from the compensation paid. This provision shall not be applicable to remuneration for activities that have been previously carried out and previously declared by a member or alternate.

17.6   Opinions issued by the Ethics Committee under Articles 17.3 and 17.4 above shall be addressed to the Governing Council. The Governing Council shall then make a recommendation to the respective national competent authority or the respective national central bank which shall inform the Governing Council of any impediment to the implementation of this recommendation.

17.7   Members and alternates shall submit to the Ethics Committee a signed Declaration of Honour (23) on an annual basis during the two-year or one-year notification period from the end of their term of office in which they confirm their gainful occupational activities and the respective remuneration, a report on which shall be submitted to the President.