UBS has just set out a new Code of Business Conduct and Ethics on its webpage (under corporate governance matters). The introduction on the webpage states that these are "principles and practices that UBS expects all of its employees and directors to follow unreservedly both in letter and in spirit. In the preface to the document, it adds that "the Code is a tangible demonstration of the importance the new UBS attaches to responsible corporate behaviour." It adds that the "new UBS" "will uncompromisingly treat our reputation as our most valuable asset." Note the use of "new UBS"--an acknowledgement that this is certainly not something the "old UBS", which seemed to value money above everything else, would have thought very important.
Here are a few noteworthy "practices and principles" in the Code:
- "All UBS employees and Directors are expected to comply with the laws, rules and regulations of the countries in which we operate."
- "UBS takes its responsibility to preserve the integrity of the financiaol system, and its own operations, seriously."
- "UBS complies with all applicable laws and regulations regarding tax records and tax reporting and does not provide assistance to clients in acts aimed at breaching their fiscal obligations."
This last is of course an area in which UBS foundered, in its willingness to facilitate tax evasion by wealthy US taxpayers who hid their assets offshore with UBS's eager help. Now it is claiming that it will report as required by "the spirit as well as the letter of any applicable laws" and states that it will "not provide assistance to clients or colleagues in acts aimed at deceiving tax authorities nor ...support transactions where the tax efficacy relies on assumptions that are inconsistent with the commercial facts or on non-disclosure of material facts."
If the bank will truly take these words to heart, so that it is more than mere window-dressing, this will be a good start on the road to a better reputation and better international citizenship. I give them a thumbs-up for recognizing the importance of turning this around, and I hope that, a year or two down the road, we won't be seeing repeats of the banks' willingness to assist tax scams .