Ethical Compliance Memorandum

This template is provided to support advisors and collaborators in documenting the ethical reasoning underlying proposed financial operations.

The Ethical Compliance Memorandum is a standard and integrated component of the decision-making process. It is not intended as an obstacle or evaluative test, but as a structured instrument to ensure clarity, alignment, and shared understanding.

1. Operation Overview

Brief description of the proposed operation

2. Application of Ethical Principles

Explain how the core ethical principles have been assessed and applied in the context of this operation.

3. Risk & Proportionality Assessment

Identify relevant risks (structural, reputational, asymmetry) and explain how proportionality has been considered.

4. Conflicts of Interest & Incentives

Disclose any economic incentives, compensation arrangements, or potential conflicts of interest related to the operation.

5. Alternatives Considered

Summarize alternative approaches evaluated and explain why the proposed solution was selected.

6. Ethical Defensibility Statement

Confirm that the operation would remain defensible under regulatory review, public transparency, and long-term reputational scrutiny.

Advisor Declaration

Name, role, date, and signature (if applicable)

For clarification or discussion regarding this memorandum or the ethical framework, advisors are encouraged to contact:

Ignacio Cemeli Duran
Owner and Processes Coordinator
contact@id-wealthgroup.com
+34.695.689.571

The absence of this memorandum, or the submission of an insufficient or superficial version, may result in suspension or invalidation of the proposed operation.