Ethical Conduct
In the exercise of its public powers and tasks as set out by the Bank of Slovenia Act, the Treaty on the Functioning of the European Union, and the Statute of the ESCB and of the ECB, Banka Slovenije endeavours to uphold the highest standards of ethical conduct on the part of its employees in accordance with the common guidelines and values established within the framework of the ESCB and the ECB.
Banka Slovenije sets out rules of ethical conduct that demand a high level of independence, objectivity, honesty and transparency from our employees and our partners in executing tasks for Banka Slovenije. We strive to ensure that these rules are upheld, as the integrity of our employees and of Banka Slovenije itself is a vital prerequisite for building and maintaining the public’s confidence that we are successfully realising our mandate and our objectives in the public interest.
Banka Slovenije’s success in achieving its goals and performing its tasks depends on the trust build with its employees and among the public through decisions and actions.
We recognise that our commitment to integrity is fundamental to maintaining this trust, and preserving Banka Slovenije as a reputable and credible institution.
Banka Slovenije has adopted the Code of Ethics of Banka Slovenije, which sets out the rules of ethical conduct for the employees, and has also established a compliance department, which ensures that employee conduct complies with the applicable regulations, the integrity standards and the ethical rules of the profession.
The Code of Ethics reflects our commitment to the highest standards of ethics and integrity, and applies to all individuals working for Banka Slovenije or on its behalf, including members of the Governing Board, employees, and external service providers. By adhering to the Code of Ethics, we clearly affirm that independence, transparency, fairness, professionalism, impartiality and accountability are the fundamental principles that underpin our work. These values form part of our common responsibility to work in the public interest, to uphold Banka Slovenije’s reputation, and together to build the trust of the public.
The public, supervised entities, business partners and other stakeholders who work with Banka Slovenije can understand the values of Banka Slovenije based on the Code of Ethics, and are able to apply them in their actions in relation to Banka Slovenije. The Code of Ethics thus helps external stakeholders avoid actions that could lead to allegations of improper conduct or influence.
Acceptance of gifts
Employees may not solicit or accept, for themselves or on behalf of others, gifts or other advantages (hereinafter: gifts) from third parties that are in any way connected to the performance of professional duties at Banka Slovenije. The prohibitions and restrictions on accepting gifts also apply if the gift is given to a member of the employee’s immediate family in connection with the performance of their duties.
Employees may accept gifts on behalf of Banka Slovenije offered by representatives of other central banks, public authorities, international organisations and other public institutions during official events (meetings, visits and similar events) as a representative of Banka Slovenije (protocol gifts). Employees may also accept gifts of minor value (up to EUR 100) given by representatives of public or private entities, usually on the occasion of cultural, ceremonial, educational or similar events (occasional gifts).
Employees may not accept gifts that are in any way linked to the performance of tasks:
relating to supervision, or during the performance of Eurosystem tasks if the gift giver has any link with the regulated entity,
in public procurement procedures, and in other procedures for contracting for goods or services, when the gift giver is in any way linked to a supplier with whom Banka Slovenije is, or intends to be, involved in business cooperation,
if the nature, form or value of the gift deviates significantly from the normal circumstances in which the gift would be given,
if the acceptance of the gift is prohibited by regulations (gifts in connection with lobbying, criminal offences, etc.).
Employees are also not allowed to accept gifts in the form of money, securities, gift vouchers or precious metals, unless the prevailing intention of a gift of money, securities or a product made of a precious metal is commemorative or historical or has similar symbolic value (e.g. commemorative and collector coins, medals).
Restrictions on private financial transactions
When entering into private transactions (for their own account or for the account of third parties), employees are required to act with caution, restraint and due care, and must avoid any actions that affect or could affect the supply of a particular financial instrument on the market, or that give or could give erroneous or misleading signals to the public in connection with a particular financial instrument or issuer, thereby affecting the supply of, demand for or price of a particular financial instrument.
Employees who in the course of their work at Banka Slovenije learn of market-sensitive information in connection with particular financial instruments or issuers of financial instruments may not use this information to enter into private transactions in those instruments, or to give investment advice with a view to obtaining a direct or indirect financial benefit for themselves or others.
A general prohibition on transactions in particular financial instruments applies to certain categories of employee. Members of the Governing Board of Banka Slovenije may not enter into financial transactions in instruments (irrespective of the issuer’s home country) unless such transactions are explicitly permitted (Article 21 of the Code of Ethics). Employees involved in the performance of supervisory tasks may not enter into private financial transactions in financial instruments issued by a supervised entity (including entities in the same group as a supervised entity). Employees involved in the performance of Eurosystem tasks may not enter into private financial transactions in financial instruments issued by a financial market entity. Employees who in the performance of their work at Banka Slovenije are involved in public procurement procedures may not enter into private financial transactions in financial instruments issued by a business partner of Banka Slovenije or by a person participating in the procedure as a tenderer.
Cooling-off periods and avoidance of revolving doors
At Banka Slovenije we avoid a revolving doors situation for employees leaving employment at Banka Slovenije by stipulating restrictions in connection with new employment for certain categories of employee involved in key processes and activities. To avoid conflicts of interest and to ensure independence and impartiality in decision-making and actions, our expectation is that employees leaving employment at Banka Slovenije may not take up new employment or new work with an employer or client during the cooling-off period if this employment would entail a conflict of interest for Banka Slovenije (e.g. employment at a supervised entity, a counterparty or a business partner). Former employees upholding restrictions in connection with new employment are entitled to compensation for the cooling-off period on the basis of the cooling-off agreement.
Communications with external stakeholders
In its communications with external stakeholders, Banka Slovenije focuses on its tasks and objectives, and ensures that all interested stakeholders and public audiences are informed to the same degree with regard to relevant content and views pertinent to the functioning of Banka Slovenije.
In their communications with external stakeholders, employees are required to consistently uphold their obligation to safeguard the confidentiality of Banka Slovenije’s documents, information and data that are classified as confidential in accordance with regulations or contractual commitments. In their communications with external stakeholders, members of the Governing Board and employees involved in the performance of Eurosystem tasks must observe a seven-day period of silence prior to each monetary policy meeting of the Governing Council of the ECB, and refrain from making speeches or other statements during this period that could influence expectations about future monetary policy decisions.
The four eyes principle is upheld in all private meetings with external stakeholders, with the proper audit trails in place. Banka Slovenije publishes information on its website about public events and non-public official meetings and gatherings (including teleconferences) with external stakeholders. These are to be attended by members of the Governing Board in connection with the performance of their functions at Banka Slovenije, including functions in the official and working bodies of the ECB, the EBA, and the Single Resolution Board, and other official mandates at the EU and in international institutions.
FX Global Code
The FX Global Code is a set of global principles of good practice in the foreign exchange market, developed by a partnership of central banks and market participants from the largest centres of global foreign exchange trading, under the aegis of the BIS.
Its purpose is to promote a robust, fair, liquid, open, and appropriately transparent foreign exchange market. It is aimed at all stakeholders, whether buyers or sellers, including non-bank participants and trading platforms. It puts in place a framework of principled rules and best practices that all stakeholders in the global foreign exchange markets should model themselves on. The central banks of the ESCB are wholeheartedly committed to supporting and encouraging adherence to the FX Global Code. Banka Slovenije has confirmed its own commitment to upholding the principles of the FX Global Code, and encourages its partners (counterparties in foreign exchange trading) to make a public commitment to upholding the code by signing the statement of commitment.