

Code of Conduct
ZMF-Global Group
Sultan Business Center
Out Metha Road
Dubai - 27844 UAE
Content
Our Ethical Values
Our Professional Standards
Adherence to this Code
Our Integrity Hotline
Our Integrity Hotline is available
24 hours a day, seven days a week.
The phone numbers are published
on the intranet by office location:
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Ethical Values and Our Professional Standards
Our vision is to become the world’s most efficient and service-oriented Hospitality Company.
The Code of Conduct provides a clear statement of the ethical values
and professional standards that we expect all members of the Board
of Directors and employees to uphold as they work to achieve our
vision. Only by operating within this framework can we maintain and
strengthen our reputation for integrity, fair dealing and measured
risk-taking. The Code of Conduct applies to all members of the Board
of Directors and employees of ZMF-Global and all of
its subsidiaries, there are no exceptions.
We fully endorse this Code and are personally committed to ensuring
that all our members of the Board of Directors and employees operate
within this framework in our business activities and our relationships
with our stakeholders.
Board of Directors and Executive Board of ZMF-Global
Dubai-UAE, December 2009
Our Ethical Standards
Service and Excellence
We are committed to being a proactive, principled partner to our clients.
Adherence to Laws and Regulations
Members of the Board of Directors
and employees are expected to comply with all applicable laws, regulations and policies.
Compliance
We strive to maintain an exemplary control and compliance culture.
Sustainability
We conduct our business with a long-term view to supporting environmental
and social sustainability.
Respect
We treat our employees with respect
and fairness.
Trust
We are committed to behaving in an
ethical and professional manner.
Transparency
We seek constructive, transparent and
open dialogue with our stakeholders.
Commitment
We value the efforts of our employees
and strive to create a work environment
that is designed to attract, develop
and retain talent.
Integrity
Integrity is essential for our long-term success.
To achieve this, we must respect the interests
of our shareholders, clients, employees, service
providers, government authorities, regulators,
politicians, and society as a whole.
Establishing and maintaining a reputation for
integrity also means that we need to identify
and manage or avoid potential conflicts of
interest. To do so, we have put in place specific
policies and processes such as those relating
to reputational risk, employee personal account
trading and outside interests. Our members
of the Board of Directors and employees may
not personally compete with ZMF-Global.
We protect our corporate property, systems
and information. We do not make inappropriate
personal use of them and ensure that they
are used effectively.
Responsibility
We take responsibility for our actions and
honour our commitments to our stakeholders:
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Shareholders: We strive to provide superior, sustainable returns for our shareholders and to protect their interests.
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Clients: We are committed to being a principled, proactive partner to our clients with the objective of providing solutions of the highest quality. Client confidentiality is paramount and we aim to protect it at all times.
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Employees: We are committed to offering interesting and challenging positions in an environment of mutual respect.
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Service providers: We are committed to dealing fairly and in good faith with contractors, suppliers and joint venture partners.
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Government authorities, regulators and politicians: We are committed to an open dialogue with government authorities, regulators and politicians to help shape operating conditions for our industry and mitigate systemic risks.
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Society: We act as good corporate citizens and support the active involvement of our employees in their local communities.
Respect
We treat our employees with respect and
fairness. We strive to ensure the following:
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Equal opportunities irrespective of ethnicity, nationality, gender, sexual orientation, gender identity, religion, age, marital or family status, pregnancy, disability, or any other status that is protected as a matter of local law;
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A safe and healthy work environment free from discrimination, harassment or retaliation;
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An “open door” policy that gives every employee access to management;
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Candid, regular and timely management feedback on personal performance.
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Compliance
We strive to maintain an exemplary control
and compliance culture. In particular, we are
responsible for:
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Leading by example, particularly in supervisory roles by setting the right tone for compliance with applicable laws, regulations and policies;
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Conducting ourselves in accordance with relevant guidelines, policies, manuals, handbooks and best practices relating to our respective areas of responsibility and diligently implementing the prescribed measures and approaches;
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Questioning new or established practices, objecting if a standard of conduct is not met and escalating the issue to the relevant supervisor or control function or alerting the Integrity Hotline;
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Acting in good faith and with due care at all times.
Confidentiality
We treat confidential information as such
and do not disclose any non-public information
concerning our clients, our company
or any of our employees unless required to
do so by law.
We are committed to maintaining effective
controls and monitoring whenever confidential
and sensitive information is transferred.
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Trust
Trust has been central to the success of
investment over the centuries. We are committed
to behave in an ethical and professional
the manner that will reflect well on ourselves and
the industry as a whole and encouraging
others to do likewise.
We earn trust by:
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Having an excellent professional reputation;
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Acting as an honest ambassador and representative of our companies;
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Demonstrating that we act at all times according to ethical values and professional standards outlined in this Code. We expect every member of the Board of Directors and employees to actively build trust in ZMF-Global and to refrain from any behaviour that might compromise this trust.
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Our Professional Standardstted to being proactive,
principled partner to our clients
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We believe that knowing our client’s needs and offering them added value based on a combination of good judgement, expertise and prompt service is essential for both our clients’ success and our own.
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We only promise what we can deliver.
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We respond to client complaints in a manner that meets our high standards of integrity, fair dealing and independence.
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We are committed to achieving excellence by improving and challenging management practices and processes in an atmosphere of openness, fairness and trust.
We seek constructive, transparent and
open dialogue with our stakeholders
based on fairness and mutual respect.
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We are committed to communicating
with our stakeholders in an accurate,
transparent and timely manner.
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We have a particular focus on disclosing
potential risks in our dealings with
our clients.
We conduct our business with a view
towards long-term environmental and
social sustainability.
We consider potential environmental
and social impacts when making business
decisions and when managing our
resources and infrastructure.
Adherence to this Code
Our most valuable asset is our reputation. It is our policy that our employees report violations of laws, rules, regulations or this Code internally so that such matters can be properly addressed.
We encourage our employees to make reports directly to the relevant supervisors and the members of the Legal and Compliance
department, the ZMF-Global Integrity Hotline or, where appropriate, directly to the corresponding higher level within ZMF-Global in accordance with our policies and procedures. Reports may be made
on a confidential and anonymous basis.
We prohibit retaliation against any employee for such reports made in good faith.
We assess whether any violations of this Code have occurred and, if so, which disciplinary measures are appropriate. This also applies
in the case of:
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Individuals who fail to take reasonable care to identify violations as well as managers who fail to supervise properly;
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Individuals who withhold material information when asked to disclose the details of a violation;
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Line managers who approve or condone violations or who seek to retaliate against employees or other parties who have reported violations or identified the individual responsible for them. In the case of violations by the Chief Executive Officer and senior financial officers (Chief Financial Officer, Head of Accounting and persons performing similar functions within ZMF-Global legal entities), such reports should be made to the General Counsel or to the Audit Committee of the Board of Directors.
Our Integrity Hotline
The hotline is available globally, 24 hours a day, seven days a week. Staffed by trained professionals, the Hotline receives initial reports of potential misconduct from employees. They may file a report anonymously and calls are taken in English, German, French or Italian. Reports made to the Hotline are dealt with promptly and discreetly. The company prohibits retaliation against any employee for reports made in good faith. To access the Integrity Hotline, in most cases, you need to first dial the access code, which varies according to the country you are dialling from.
Hotline Dubai
Sultan Business Center
Out Metha Road
Dubai – 27844 UAE
Phone. +971-4 (0) 507 7028 14
Transparency
Complying with our Code
What does it mean for me?
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In addition to reading this document, you should ask yourself these questions before taking any decisions or actions:
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Is it the right thing to do?
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Are my actions appropriate and in keeping with this Code?
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Am I personally prepared to stand by this decision and its consequences?
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Have I taken into account those who could be impacted by this decision?
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Is this decision in our long-term interest?
What does this mean for me?
Ensure that you always make
decisions and take actions that
are consistent with this Code,
applicable laws and relevant
policies. You should feel comfortable
personally supporting
your decisions, should they
be exposed to public scrutiny.
For example, consider whether
the transaction you are working
on could lead to a negative
a headline in the media. Always
keep potential reputational
impacts in mind.
What does this mean for me?
Behave in a manner that takes
into account the interests of the
Conglomerate’s different stakeholders.
For example, if you are responsible for a transaction that might have an adverse reputational impact, you should bring it to the attention of the relevant regional reputation risk approver.
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What does this mean for me?
Treat your colleagues with
respect.
For example, if you see behaviour
that is at variance with
our value of respect, bring
it to the attention of the appropriate
senior manager.
What does this mean for me?
Trust your instincts. If you have
any doubts at all about a
the course of action, check with the
relevant policy. Escalate your
concerns to your supervisor or
to the appropriate control
function.
For example, certain laws (e.g.,
US Foreign Corrupt Practices
Act) apply well beyond their
own jurisdiction and a breach
in any country in which we
conduct business could have
severe consequences for our
franchise. If you are in any
doubt, escalate your concerns.
What does this mean for me?
The legal safeguards on client
data and data protection in
general are very strict in many
countries and, in particular, in
Switzerland.
For example, protecting company
documents and records from
unauthorized access. Always be
mindful of where you conduct
your conversations and how you
Share information electronically
and in hard copy.
What does this mean for me?
Your actions should be conducted
in a transparent and
open way and communicated
as such to clients and colleagues
alike.
It takes time and effort to establish
trust with our clients
and stakeholders. The only way
to build and maintain trustworthy
partnerships is to conduct
your business in an honest and
reputable manner
Outstanding Swiss Quality
We base our business operations on
disciplined and intelligent risk-taking.
We believe in independent risk management,
compliance and audit processes
and full management accountability.
Adherence to Laws
All members of the Board of Directors and employees are expected to comply with applicable laws, regulations and policies.
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In particular, we take our responsibility to ensure the integrity of the international financial system very seriously. This means that we are committed to ensuring that we do everything possible to prevent money laundering, the financing of terrorist activities and corruption.
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We maintain the highest standards in our cross-border business activities.
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We are committed to complying with all relevant tax laws.
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We do not assist clients in activities intended to breach their tax obligations.
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We use material non-public information only for the business purposes for which we received it.
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We keep accurate records of our business activities.
We value the efforts of our employees and strive to create a work environment that is designed to attract, develop and retain talent by:
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Nurturing a culture based on individual performance, with a competitive reward system;
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Having fair and objective periodic evaluations that take into account personal contributions towards teamwork, the achievement of objectives and also compliance with this Code and internal policies;
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Supporting continuous education and development;
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Encouraging employee mobility and flexible working wherever possible. Every member of the Board of Directors and the employee is expected to contribute her or his very best to implement our vision and the spirit of this Code.