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Terms and Conditions

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:

 

  • Shareholders: We strive to provide superior, sustainable returns for our shareholders and to protect their interests.

  • 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.

  • Employees: We are committed to offering interesting and challenging positions in an environment of mutual respect.

  • Service providers: We are committed to dealing fairly and in good faith with contractors, suppliers and joint venture partners. 

  • 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.

  • 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:

 

  • 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;

  • A safe and healthy work environment free from discrimination, harassment or retaliation;

  • An “open door” policy that gives every employee access to management;

  • 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:

 

  • Leading by example, particularly in supervisory roles by setting the right tone for compliance with applicable laws, regulations and policies;

  • 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;

  • 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;

  • 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:

  • Having an excellent professional reputation;

  • Acting as an honest ambassador and representative of our companies;

  • 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

  • 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.

  • We only promise what we can deliver.

  • We respond to client complaints in a manner that meets our high standards of integrity, fair dealing and independence.

  • 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.

  • We are committed to communicating

with our stakeholders in an accurate,

transparent and timely manner.

  • 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:

  • Individuals who fail to take reasonable care to identify violations as well as managers who fail to supervise properly;

  • Individuals who withhold material information when asked to disclose the details of a violation;

  • 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:

  • Is it the right thing to do?

  • Are my actions appropriate and in keeping with this Code?

  • Am I personally prepared to stand by this decision and its consequences?

  • Have I taken into account those who could be impacted by this decision?

  • 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.

  • 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.

  • We maintain the highest standards in our cross-border business activities.

  • We are committed to complying with all relevant tax laws.

  • We do not assist clients in activities intended to breach their tax obligations.

  • We use material non-public information only for the business purposes for which we received it.

  • 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:

  • Nurturing a culture based on individual performance, with a competitive reward system;

  • 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;

  • Supporting continuous education and development;

  • 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.

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