Compliance with the Code of Conduct is mandatory by virtue of membership of STSA and the Association expects all of its Members to conduct their business activities in accordance with the best practices laid out in this Code of Conduct.
The Association’s Code of Conduct was adopted on 16 November 2015.
STSA works to promote a positive contribution to the commodities industry in Switzerland, as well as to generate understanding about how the participants are fulfilling their roles as responsible corporate citizens. STSA has always been committed to supporting its Members through identifying and developing best practices in a multitude of areas as well as enabling the sharing of information and experience among its Members.
As the industry continues to develop, STSA expects all of its Members to conduct their business activities with integrity and in compliance with best practices laid out in this Code of Conduct (“The Code”).
The Code comprises two sections: firstly the commitments made by STSA to its Members, and secondly the commitments of STSA Members. Under each Commitment, The Code gives examples of best practices supported by STSA.
STSA allows its Members to display The Code in their communication materials and is dedicated to working with its membership to assist with its implementation.
Members agree to comply with The Code by virtue of membership of STSA, and STSA is committed to ensure that Members who are found to be acting contrary to The Code will be dealt with in accordance with appropriate procedures.
The STSA reserves the right to withdraw the membership of any STSA member who is found to have breached The Code, according to the articles of association.
2. STSA Commitments
STSA commits to:
I. Working with its Members to assist with the implementation of The Code;
STSA can support its Members to implement the principles laid out in The Code into their own corporate framework. This could include sharing information, offering guidance, training and introducing Members to other Members or relevant contacts
IV. Promote the Code whenever possible;
3. Members’ Commitments
Members commit to:
I. Respecting the confidentiality of STSA and its members. Members will refrain from disclosing the content or the nature of any discussion, documentation, correspondence or information provided or produced by STSA or any Member of STSA in connection with the activities of STSA (other than for purposes of consultation within their own firms or where such information is already in the public domain);
II. Treating fellow members with respect at all times and always acting with the interests of the STSA, fellow members and the industry in mind;
III. Ensuring compliance with, and being mindful of, their responsibilities under applicable competition/anti-trust laws, rules and regulations;
V. In relation to the activities of STSA, liaising with Swiss regulators in a co-operative manner to discuss issues relevant to the industry;
Members will, where possible and relevant, contribute to the work of STSA with the authorities by way of helping to develop strategy, provide analysis, develop opinions, consultation responses and presentations
Members, where possible and relevant, will assist STSA with its communications with the authorities
VI. Conducting business in compliance with relevant laws and regulations as applicable to the respective Member;
Members will endeavour to understand the laws and regulations applicable to them
VII. Implementing appropriate compliance and due diligence policies and procedures in line with recognised industry best practice in relation to their businesses activities;
Examples of processes and procedures that can be implemented include KYC procedures, risk-based supply chain due diligence, payment processes and monitoring of certain activities
VIII. Taking reasonable steps to undertake their business activities with integrity and in an ethical manner.
Examples include implementation of training programmes, implementation of corporate policies and procedures and appropriate and applicable risk analysis.