Code of Conduct and Ethics

Chapter I
General provisions

​Article 1
In the exercise of its duties, particularly in liaising with the other employees and with the CMVM, the CMVM employees comply with the provisions of the CMVM Code of Conduct and Ethics for CMVM Employees, hereinafter referred to as CCE.
Article 2
Subjective scope
The CEE is applicable to all CMVM employees, irrespective of the nature of the tie.

Article 3
Material scope
The CCE contains the principles of professional ethics governing the exercise of functions, in particular, the relations between employees and between these and the CMVM, without prejudice to the legal norms to which they, in the exercise of their activity, are subject in particular to:
a) The duties resulting from the CMVM Statutes;
b) The duties that result from their quality as employees, foreseen, essentially, in the Employment Code and complementary legislation;
c) The duties that result from their status as employees of a public legal entity, namely those provided for in the Code of Administrative Procedure and other legislation related to the exercise of administrative activity.

Article 4
General principles
CMVM employees are exclusively assigned to serving the public interest that the CMVM is responsible for pursuing, and shall observe the fundamental values ​​and principles of administrative activity, namely legality, fairness and impartiality, competence, responsibility, proportionality, decision-making, transparency and good faith in order to ensure integrity, independence, credibility and efficiency in the exercise of the powers vested thereon.

Article 5
Legality and independence
1. The employees of the CMVM shall act solely and exclusively in accordance with the law and with the legitimate instructions and guidelines received from that Committee.
2. In case of doubt regarding the legal framework applicable to their performance, CMVM employees shall raise the need to resolve it with their hierarchical superior.

Article 6
Professional diligence
1. The CMVM employees’ performance shall be based on loyalty to the CMVM, honesty, independence, exemption and not fall prone to personal interests. 
2. The CMVM employees shall have high standards of professional ethics.
3. The CMVM employees shall identify and provide to their superiors and colleagues, in a timely and complete and accurate manner, all information that may be relevant to the smooth running of the works.
4. The CMVM employees shall carry out their duties with care, efficiency and accountability, ensuring compliance with instructions, respect for appropriate hierarchical channels and transparency in dealing with all stakeholders, and behaving in a way that maintains and enhances trust of the public in the CMVM and contribute to the effective functioning and good repute and respectable image of the CMVM.
5. The CMVM employees shall contribute to keeping a safe working environment, while respecting the political, religious, sexual or other orientations within their intimate sphere, refraining from practicing any type of harassment, namely of disturbing or restricting other employees, affect their dignity, or create an intimidating, hostile, degrading, humiliating or destabilising working environment.
Article 7
Confidentiality duty
In addition to observing the duty of professional secrecy, under the terms established by law and the Code of Good Administrative Behaviour (CGAB), CMVM employees:
a) They shall not disclose the content of, in particular, letters, packages, closed letters or telecommunications addressed to them, with internal or external origin, by virtue of the exercise of their functions at the CMVM, in addition to what is necessary for the same exercise;
b) They shall maintain confidential all information that is classified as such including the liaison with other work colleagues.

Article 8
Use of resources
1. The CMVM employees shall:
a) Ensure the conservation and the adequate and efficient functional use of the resources that are made available to them by the CMVM;
b) Respect, protect and not make improper use of the CMVM's assets, and
c) Take all the appropriate and justified measures to limit the costs and expenses of the CMVM in order to efficiently manage the available resources;
2. The use of equipment and materials, namely computer and telephone, for personal purposes shall also comply with the principles of good faith and proportionality and shall be prudent and parsimonious and not interfere with the normal functioning of the CMVM nor with the diligent performance of the employee.

Article 9
Requests for authorisation and communications 
to the Management Board

1. The request for the authorisation made to the Management Board for higher education teaching or temporary collaboration with public entity, follows Internal Regulation provisions approved by the Management Board.
2. The request for the authorisation made to the Management Board, for carrying out either directly or indirectly as to any transactions on securities or other financial instruments for own account or otherwise, including the entering into, modification or extinction of any financial intermediation contract, unless it its exclusive purpose is that of public funds or retirement saving funds, complies with the Internal Regulation provisions approved by the Management Board.
3. The CMVM employees shall notify the Management Board of the list of securities and other financial instruments they hold either directly or indirectly, and of the financial intermediation contracts to which they are parties to, unless the security, instrument or contract  relates to public funds, retirement saving funds or education-retirement savings or treasury or money market funds, as per Internal Regulation provisions, approved  by the Management Board

Article 10
Disclosure duty concerning conflicts of interest
1. All CMVM employees are required to inform their respective hierarchical superior when situation of conflict of interests arises. 
2. The information in the previous number is provided on a confidential basis and shall only be used for managing potential or current conflict of interests or for the purpose of any disciplinary proceeding.

Article 11
Appropriate presentation 
CMVM employees shall present themselves in a proper fashion akin to the performance of their duties, with particular care for the professional practices and customs in the financial sector, so that their good presentation, coupled with their diligent performance, contributes to a sound working environment and a good image and reputation of the CMVM.

Article 12
Whenever the situation is deemed materially relevant by the respective hierarchical superior or by the Management Board, the CMVM employee in a situation of potential conflict of interests is prevented from dealing with any issues that may relate to the entity potentially involved.

Article 13
1. The proper application of this CCE relies on the professionalism, integrity and insight of the employees.
2. The hierarchical superiors shall have an exemplary role when acting out the established principles and criteria, as well as ensuring compliance thereto.

Article 14
Disclosure ​
The CCE is an integral part of the CMVM Internal Regulation and a copy of same is handed to the employee.

Amendment approved at a Management Board meeting of 21 September 2017.