Code of Conduct

Operating with Integrity

EDW’s Code of Conduct shapes the company’s operations, reputation, and overall attitude to how we do business. It defines the expectations we have of our employees, consultants, contractors, suppliers, subsidiaries, and affiliates.

Our Code addresses four main areas: Conduct towards our customers, Conduct towards our employees, Conduct towards our business and Conduct towards society. It underpins all actions and requires employees to comply with all other applicable rules, laws, codes, policies, and procedures that govern EDW’s business.

At EDW, our people care deeply about doing the right thing and they take pride in the company’s culture of compliance, ethical conduct, and accountability. As such, they are committed to adhering to the standards of behaviour set in our Code of Conduct which call for:

  • due respect for the applicable laws and regulations;
  • integrity and transparency;
  • a level of professionalism aligned with the confidence placed in us by our customers and shareholders.

Obeying the law, both in letter and in spirit, is the foundation on which the company’s ethical standards and values are built. Employees are not only expected to understand the laws, rules, and regulations applicable to themselves and their duties with the company, but also the regulatory environment in which the company operates.



A message to our employees from EDW GmbH CEO and EDW Ltd Managing Director:

European DataWarehouse has a rich tradition, with company roots dating back well over 10 years, at the pinnacle of creating trust and certainty in financial markets. Throughout EDW’s history, our dedicated, consistently ethical approach has been, and continues to be, the cornerstone of the company’s culture and underpins our ability to deliver superior services to our clients. 

Because our people are our most valued resource, our standards of behaviour are crucial to EDW’s continued success and to being the most trusted financial market infrastructure provider in Europe.  Our reputation is our our greatest asset; therefore, this Code is critical to everything we do, wherever we do it. The collective reputation of European DataWarehouse depends on the individual decisions we all make.

This Code outlines our commitment to upholding the highest ethical standards in our individual behaviour as well as in our relationship with clients, business partners, regulatory authorities, and each other. In addition to this Code, our values shape our attitudes, actions, and behaviours allowing us to identify, mitigate, and manage areas of risk to the company as well as violations of the Code. In some situations, it is difficult to ascertain if a violation has occurred. Since we cannot anticipate every situation, it is important to have a way in which to approach a new question or a problem.

Here are some helpful steps to keep in mind:

  1. Make sure you have all the facts. In order to find the right solution, you must be as informed as possible.
  2. Ask yourself: What am I specifically being asked to do? Does it seem unethical or improper? This will enable you to focus on the specific question you are faced with, and the alternatives you have. Use your judgement and common sense. If something seems unethical or improper, it may well be.
  3. Clarify your responsibility and role. In most situations, there is shared responsibility. Are your colleagues informed? It may help to get others involved to discuss the problem.
  4. Discuss the problem with your manager or the Compliance Officer. This is the basic guidance for all situations. Your manager or the Compliance Officer will have prior experience with the situation and will appreciate being brought into the decision-making process.
  5. You may report ethical, legal, or regulatory violations in confidence and without fear of retaliation.

Each of us must take accountability for upholding the Code, company polices, regulations, and the law by performing our daily tasks in an honest and ethical manner. To that end, we ask you to partner with us to continue building upon the foundation that has been created for our company.

While our Code covers many topics, it can be summarised by one simple idea: ACTIVELY DOING WHAT IS RIGHT.

Please join us in committing to reflecting the Code of Conduct and our values in all our day-to-day decisions and business activities.

CEO, Dr. Christian Thun

Managing Director, Markus Schaber

Corporate integrity, responsible sourcing, and the safety and wellbeing of workers across the global supply chain are also of paramount importance to EDW. These core principles are reflected in our Supplier Code of Conduct, which establishes the minimum standards that must be met by any organisation or entity that supplies products or services to any part of EDW.

Click below to download EDW’s Supplier Code of Conduct.