Code of Ethical Conduct of the Polish Corporate Treasurers Association
adopted by the General Meeting of Members on March 16, 2013

1. Introduction and mission

The Code of Ethical Conduct (Code) is a comprehensive set of rules common to all members of the Association of Polish Corporate Treasurers (Association). The Code was adopted in response to requests for adoption of framework principles to ensure safe environment for the members of Association.

The Code aligned to the Code of Ethics document adopted by the European Association of Corporate Treasurers (EACT) and the International Group of Treasurer Associations (IGTA) in 2012, which sets out the rules of conduct for members of regional and national associations (NTA). Note that NTA are also members of EACT and / or IGTA.

Thanks to Code, the international community of treasurers has the opportunity to present a unified position, promote accepted values in contacts with internal and external partners, as well as promote high ethical standards.

 2. Principles and values
The Code provides guidelines for identifying and preventing conflicts of interest and unacceptable behavior. The principles contained therein are also intended to help members in the self-evaluation process.
Each member of the Association should represent values ​​that should not conflict with ethical standards, corporate governance principles or the law or accepted practice. The values ​​referred to above are:

2.1 Honesty, nobility, trust and integrity
Members of the Association recognize the overriding need to tell the truth in all circumstances, without omitting or misrepresenting information. In addition, they should be loyal to the employer, colleagues and the Association and should oppose decisions and actions that could be contrary to their interests.
The goal of the Association is to create an atmosphere of trust and partner cooperation, so that members respect and appreciate other points of view and look for, accept and offer constructive criticism of their actions.

2.2 Transparency
Members of the Association try to communicate clearly, avoiding any ambiguity. Transparency is particularly important in matters relating to specialized problems related to the Treasury's operations, which may be misunderstood or lead to an erroneous assessment of the situation.

2.3 Independent and professional opinion
A member of the Association strives to make decisions in an independent, balanced and professional manner, while avoiding conflicts with private interests. In the process of providing professional advice, the Association promotes the habit of professional consultation, whenever possible on any matter.

2.4 Competence
A member of the Association operates in accordance with good practice, professional standards and its own scope of responsibility. In addition, he should take care of his own professional development by systematically raising the level of qualifications and setting an example to his colleagues. A member of the Association does not refer to competences which he does not possess, and does not take actions when he has insufficient knowledge.

2.5 Confidentiality
A member of the Association is obliged to treat all information obtained with confidentiality appropriate to their type, with special care when dealing with sensitive information.
He should also comply with any corporate disclosure recommendations unless they conflict with applicable law.
He should refrain from disclosing or using for his own or other inappropriate purposes, confidential information obtained in the course of employment, in the performance of official duties or membership in the Association or other organizations, as well as other information of which he is aware of confidential nature.

2.6 Compliance with regulations
A member of the Association should act in accordance with the laws, regulations and conventions of the countries and markets in which he conducts business, such as commercial law, tax law, regulations of stock exchange supervision and provisions protecting the interests of financial market participants and other similar ones.
The member is also obliged to act in accordance with the anti-discrimination law in force in his country and respect the right to equal treatment of people irrespective of gender, race, ethnicity, nationality, sexual orientation, religion or political views.
In addition, a member of the Association is required to thoroughly familiarize themselves with applicable law.

2.7 Model of conduct
Members of the Association with greater professional experience should help less experienced colleagues and give them advice and recommendations on the moral and professional aspects of work in the treasury. They should also ensure a proper understanding of common values ​​and practices and their application in everyday work.
A member of the Association who performs managerial functions, will provide a vocational training plan for all his subordinates and will strive to raise professional standards in his environment.

3. Operation in accordance with ethical standards
Members of the Association are obliged to act in accordance with ethical standards and respect their colleagues and third parties. They cannot offer or accept bribes or use any form of bribery. They must avoid harming others, their property, reputation or professional status, whether by providing false or false information, or by intentional or unintentional acts or omissions.

4. Competence
Members of the Association should be aware that they are responsible for developing their own knowledge and for sharing best practices.
Continuous improvement of professional knowledge is a key element in raising the level of competence of Association Members, in accordance with changing market conditions and applicable law.

5. Private benefits
Treasury employees, by participating in the process of purchasing financial and other services of a similar nature, may face ethical dilemmas. They can take place especially when gifts, entertainment, material benefits or private services are offered at a price lower than the market price. Similarly, if a trade employee translates a private benefit into a business relationship with a financial service provider or other similar services. In these situations a member of the Association should act in accordance with the following principles:

  • it is forbidden to accept gifts, services or entertainment if it could have any impact on judgment or loyalty or proper performance of official duties,
  • professional integrity and independence of opinion is required, especially when choosing contractors on behalf of your employer,
  • it is required for the Association Member to make sure that the employer has approved his personal business contacts with the employer's business partners,
  • it is required to disclose the employer and to make sure that the employer has obtained full information about the private benefits of the Association Member, which he gained in contacts with the employer's business partners.

A member of the Association should work for the introduction of benefits register in their employer, assuming:

  • keeping records of gifts and benefits received by employees and offered to them; and
  • regular reviews of such records and applicable policies in this regard by the management of the enterprise.

A member of the Association should promote the existence of a register of benefits at least in his immediate environment and encourage his subordinates to use it if it is not possible to implement this solution in the entire organization.

6. Applicability
The Code of Ethics applies to all Members of the Association, regardless of their position in the area of ​​treasury, and regardless of whether it is a professional or private area of ​​a given member. We encourage all members to share this document with all their contractors in the financial sector.
A member of the Association should feel obliged to maintain the reputation of the profession of a corporate treasurer and not take any action that could damage this reputation.

7. Infringements
In the event of becoming aware of a breach of the provisions of this Code, the Management Board of the Association shall meet immediately to establish and examine the facts. If the violation is confirmed, the Board of the Association will take appropriate steps to determine the severity of such violation.
Violations of this Code of Conduct are considered a disciplinary violation and will be subject to the following sanctions, depending on the severity of the violation:

  • temporary suspension of membership, or
  • exclusion from the list of members in the manner provided for in paragraph 8 of the Association's statute.

    Download PCTA Code of Ethical Conduct  [pdf 377 KB]