Code of Conduct & Business Ethics

Version 1.0 · Effective Date: 1 January 2026 · Owner: Elena Scheller, CEO

1. Introduction

Virtue Compliance GmbH is a Swiss compliance services firm specialising in anti-money laundering (AML), know-your-customer (KYC/KYB), and regulatory advisory services for financial intermediaries subject to Swiss regulatory requirements.

This Code of Conduct sets out the ethical standards and principles that govern the conduct of Virtue Compliance GmbH and its representatives in all business activities and client relationships. Adherence to these principles is mandatory and non-negotiable.

2. Scope

This Code applies to:

3. Core Principles

3.1 Integrity and Honesty

We conduct all business with the highest standards of integrity. We are truthful in all communications, avoid misleading statements, and act in the genuine interest of our clients and the regulatory framework we serve.

3.2 Compliance with Laws and Regulations

We comply fully with all applicable laws, regulations, and professional standards, including:

3.3 Confidentiality

We treat all client information with strict confidentiality. Non-public data accessed in the course of our mandates is used exclusively for the stated compliance purpose and is never disclosed to unauthorised third parties. Data protection obligations under Swiss law (nDSG) are observed at all times.

3.4 Conflict of Interest

We identify, disclose, and actively manage any real or potential conflicts of interest. Where a conflict cannot be adequately managed, we decline or withdraw from the relevant engagement. We never allow personal interests to compromise the quality or independence of our professional judgement.

3.5 Anti-Bribery and Anti-Corruption

Virtue Compliance GmbH has a zero-tolerance policy toward bribery and corruption in any form, including:

This policy applies to all interactions with public officials, private-sector clients, counterparties, and third parties.

3.6 Professional Independence

Our compliance assessments and recommendations are based solely on applicable laws, regulatory requirements, and professional best practice. We do not allow commercial pressure, client preferences, or third-party interests to distort our professional judgement.

3.7 Fair and Respectful Conduct

We treat all clients, partners, and counterparties with respect, fairness, and professionalism, without discrimination on any grounds.

4. Reporting of Concerns

Any concerns regarding potential violations of this Code, applicable law, or regulatory requirements may be raised directly with the CEO of Virtue Compliance GmbH:

Elena Scheller
CEO, Virtue Compliance GmbH
info@virtue-compliance.ch

All concerns raised in good faith will be treated seriously and handled with appropriate confidentiality.

5. Consequences of Non-Compliance

Violations of this Code may result in termination of mandates, reporting to relevant authorities, and other appropriate measures as required by law or regulatory obligation.

6. Review

This Code of Conduct is reviewed at least annually and updated as necessary to reflect changes in applicable law, regulatory requirements, or business activities.

Approved by:
Elena Scheller, CEO
Virtue Compliance GmbH · 1 January 2026