Our Code of Conduct

The world in which we live and work is changing. Digitalisation is playing a key role in this. As digitalisation advances, values such as reliability, human centricity, flexibility, responsibility and expertise will become even more important to our people and our clients.


In an age of information overload, embedding values in everyday life can help develop security and trust. They are the building blocks for creating new partnerships or continuing existing ones and the foundation for a well functioning market economy.


As we have explained in our “WHY”, we want to be a reliable partner and create added value for our clients, our people and the society in which we live. But economic success is not BDO’s sole objective – whether for our clients or ourselves.


Success should come from responsible behaviour, because only then can we ensure that the company will perform well and in a sustainable manner.


We can only satisfy these valid demands if we comply with the applicable laws, regulatory requirements and our own internal policies, all the time and in every situation. The tone at the top – set by management – is critical.


But this Code of Conduct is not just about complying with laws, regulatory requirements and employment law rules. It also contains clear guidelines for responsible, ethical and integrity-based behaviour.


A code of conduct cannot cover every conceivable situation and govern all our business activities exhaustively. But in cases that are not clearly provided for, we can account for our own conduct by asking a simple question: “Do I believe my conduct is right and would outsiders have that impression as well?” We should ask ourselves this self-critical question regularly because the answer can be used to guide us in all our activities.


Our conduct is the basis for maintaining and strengthening the confidence and trust of clients and the public in the BDO brand, in us as advisers, accountants and auditors, and in our work. But it is only through our actual conduct that together we all express what BDO stands for.


This Code of Conduct will help us make the right decision in every situation.

Thomas Studhalter
CEO BDO
OUR CORPORATE VALUES

Our Code of Conduct

This Code of Conduct is based on our corporate values and must be observed by all of us in all our decisions and actions. Ask questions if anything is unclear. Misconduct can be reported anonymously without fear of legal consequences. Violations of this Code of Conduct will not be tolerated.

Scope

This Code of Conduct applies to all full and part-time employees and all executive bodies of BDO Ltd and its subsidiaries.

Our Code of Conduct in everyday working life

It is important that we all use the following principles for good conduct as a benchmark for our behaviour in all our professional activities. These general principles cannot provide a specific answer for every conceivable situation. But it is important that the meaning and purpose of these instructions are always reflected in our actions.

Managers have an important role to play in putting this into practice in everyday business: they exemplify the BDO values and the principles of this Code of Conduct and ensure compliance in their area of management.

Questions and uncertainties

Questions? Questions! We support all our people so that they can make objective, ethical and professional decisions. If you are uncertain about anything, ask yourself the following questions as a first step:

  • Is my conduct in line with BDO values?
  • Is my conduct legally irreproachable and does it comply with the rules of my profession?
  • Have I sought advice from the persons responsible and competent for taking decisions (qualified dual control principle)?
  • Could my actions impair BDO’s reputation?
  • Could I easily cope if my actions were reported in the media?
  • Do I treat others as I would like to be treated by them?

If you still have questions about complying with or interpreting this Code of Conduct, you can contact the following:

  • Your immediate line manager
  • Managers of the product areas and product groups
  • P&C managers
  • Ethics & Independence Leader
  • General Counsel

Reporting conduct

BDO offers employees and external parties the opportunity to report justified and reasonable suspicions of violations of the Code of Conduct and breaches of rules and laws relating to BDO, thereby protecting the reputation and integrity of all parties.

If a report is made by external parties , they themselves are responsible for complying with any confidentiality obligations.

A reporting platform is available for reporting substantiated and verifiable violations of laws or regulations, which offers an option for anonymous reporting and anonymous communication via the platform.

The report is submitted via the reporting platform to the General Counsel and the Ethics & Independence Leader (EIL).

Link for legal and regulatory violations (external individuals)

If a report is made anonymously, it is possible to communicate with the reporting party via the reporting platform if the information in the report is insufficient to determine whether misconduct has occurred. Anonymous reports should, as far as possible, be submitted with provable facts. It is more difficult, if not impossible, to process and/or investigate anonymous reports. BDO therefore encourages the person submitting the report to disclose their identity, which will be treated confidentially as far as possible.

However, it cannot be guaranteed that anonymity can be maintained at all times, for example if doing so is precluded by overriding interests or legal requirements, or if the identity of the reporting party becomes known in the course of internal or external proceedings, particularly in the context of further investigations or any legal proceedings (criminal and/or civil proceedings).

The person submitting the report will receive confirmation that it has been received. They are not entitled to any further information regarding the status or outcome of the proceedings and/or any sanctions.

All the reported facts and information provided, including the identity of the person making the report, will be kept confidential. Regardless of the outcome of proceedings, employees who report suspected or actual violations in good faith will not be prejudiced as a result. This does not apply to cases of abuse of rights.

Offences and sanctions

If we do not comply with the instructions in this Code of Conduct, the reputation of our company and our industry and our personal reputation will be tarnished. We run the risk of the trust placed in us being undermined or lost and that the quality of our work will no longer meet our requirements or the demands of the market.

We will therefore not tolerate any violations of this Code of Conduct. Violations of the Code of Conduct or of laws and regulations will result in sanctions by BDO and may lead to disciplinary action. Serious violations can also lead to civil or criminal prosecution.

Our conduct, our commitment

We consider quality and value for the client in everything we do. We perform the engagements entrusted to us with the necessary care and to the best of our knowledge.

  • We carefully select our existing and potential future clients. We also assess their integrity and the market in which they operate. They should be proud to work with BDO – and BDO should be proud to work for such clients. We decline to work for companies or individuals that do not meet our requirements for integrity and probity.
  • We accept mandates only if we can provide the service to the high quality standard we require. 
  • The tasks assigned to us must always be carried out carefully, based on specialist knowledge and professional experience and in compliance with any instructions.
  • We apply appropriate quality assurance measures (care in selecting, instructing and monitoring).
  • We always keep our expert knowledge up to date.
  • We protect the legitimate interests of our clients.
  • We charge an appropriate fee for the services we provide, taking into account the level of difficulty and responsibility.
  • We take responsibility for all our actions.

We comply with all applicable laws, professional standards and internal policies.

  • We are committed to free competition and comply with the applicable competition laws. This means:
  • We do not enter into unlawful competition agreements with rivals and business partners.
  • We do not behave unfairly or dishonestly in competitive situations and we reject any fraudulent conduct or conduct that is otherwise contrary to the principle of good faith.
  • We conduct ourselves honestly and transparently in business, trust in the quality of our services and reject bribery and corruption. This means:
  • We do not promise or grant undue advantages to business partners and government agencies in order to win a mandate (active bribery).
  • We do not accept undue advantages for us (passive bribery).
  • We only accept invitations and gifts to the extent customary in society, and in doing so we comply with existing policies.
  • We observe all regulations on combating money laundering and terrorism financing.
  • We comply with all local and foreign tax regulations. We do not encourage tax evasion or tax fraud. We also do not assist in either.

We uphold our independence and objectivity of thought and action in everything we do.

  • We avoid any commitment or action that endangers or could endanger our freedom to make decisions and be impartial.
  • We do not allow ourselves and our professional decisions to be improperly influenced by third parties.
  • We avoid conflicts of interest. If they do occur, we disclose them internally and take appropriate measures to rectify the situation.
  • We form our judgements and make our decisions based on factual and objective criteria.
  • We clarify all independence issues before accepting a man- date and do not accept mandates that are incompatible with the legal, professional and internal rules on independence. The same applies to handovers from other companies or of mandates from third parties.

We treat all data and information of our clients and our company confidentially and adhere to the statutory confidentiality obligations.

  • We treat all sensitive information of our clients, our employees, our business partners and BDO as confidential. We apply the same standards everywhere.
  • We do not pass on confidential information and business secrets to unauthorised persons either internally or externally.
  • We comply with data protection requirements and protect the personal data of our clients, employees and business partners with appropriate security measures.
  • We use the data of our clients, employees and business partners exclusively for the purpose for which the data were entrusted to us.
  • Even after a mandate or employment agreement ends, we comply with the existing confidentiality and secrecy obligations.

We safeguard the health of everyone we work with, protect BDO’s property, respect the property of third parties and treat the company’s equipment with care.

  • We refrain from doing anything that could endanger or harm employees, clients, business partners or visitors.
  • We provide safe, modern and ergonomic workplaces.
  • We handle equipment such as devices, furnishing and other assets of BDO and our clients with care and responsibly.
  • We use company equipment exclusively for business or other approved purposes.
  • We respect the intellectual property of third parties and ensure that BDO’s intellectual property is protected and safeguarded.
  • We protect and strengthen the “BDO” brand and contribute to BDO’s reputation.

We treat each other with respect, honesty and appreciation, uphold the principle of equal treatment and refuse to tolerate discrimination.

  • We treat all our employees, clients and business partners with dignity and respect.
  • We communicate transparently, honestly, comprehensibly and in a way that is appropriate to the purpose and level.
  • We encourage our employees’ development and give them honest recognition, appreciation and appropriate remuneration.
  • We are committed to the principle of equal treatment, i.e. we avoid any discrimination on the basis of sex, origin, ethnicity, language, sexual orientation, sexual identity, sexual characteristics, age, social position, lifestyle, religious beliefs or physical, mental or psychological impairment.
  • We protect the personal integrity of our employees and abuse, assault, sexual harassment, violence, bullying or discrimination.
  • We are committed to diversity and inclusion, as this also enables us to better understand our clients, deliver bespoke solutions and become an even more attractive employer.

Our conduct is geared towards people, sustainable actions and long-term success.

  • We put people first and seek lasting relationships with employees, clients and business partners.
  • We handle the natural resources we use with care and consideration.
  • We have set ourselves the target of reducing our annual CO2 footprint even in light of corporate growth.
  • We also contribute to the wellbeing of society through our work, e.g. by supporting charitable institutions and NPOs and carrying out “pro bono” mandates.
  • We seek to achieve a balance between economic, social and ecological commitments so that future generations can also enjoy a prosperous economy and an intact environment.
  • We set ourselves long-term goals that support our endeavour to achieve sustainable success.