Patrimonial management is inherently collective. Regardless of the clarity of the asset owner’s values, outcomes are shaped by the conduct, competence, and integrity of all professionals involved in the process.
The ethical standard of the whole is determined by the weakest link in the chain. For this reason, selection and oversight of collaborators is a core governance responsibility, not a secondary operational task.
Collaborators are selected based on demonstrated competence, independence of judgment, and alignment with declared ethical standards. Technical expertise without ethical discipline is insufficient and, in many cases, a source of systemic risk.
Preference is given to professionals who demonstrate clarity in communication, transparency in incentives, and a documented history of acting in the client’s long-term interest.
All actual or potential conflicts of interest must be disclosed, documented, and actively managed. Undisclosed conflicts are considered incompatible with participation in the patrimonial structure.
Compensation models that incentivize complexity, opacity, or unnecessary transactions are treated with heightened scrutiny.
Collaborators are expected to act with loyalty, discretion, and professional rigor. Recommendations must be defensible not only technically, but ethically and reputationally.
The willingness to advise against a transaction — even at the cost of reduced fees or delayed execution — is considered a marker of integrity, not obstruction.
Engagement does not end at appointment. Performance, conduct, and alignment are subject to ongoing review. Misalignment, persistent opacity, or erosion of trust constitute grounds for disengagement.
Accountability is continuous, reciprocal, and inseparable from professional collaboration.
Any material financial operation, structuring decision, or strategic recommendation shall be accompanied by a dedicated Ethical Compliance Memorandum (ECM) as a precondition for execution.
The ECM constitutes a substantive governance requirement. Its absence, insufficiency, or inadequacy may result in the immediate suspension or invalidation of the proposed operation, irrespective of its technical, legal, or financial merits.
Minimum Mandatory Structure of the ECM:
1. Principle Application Analysis
Explicit explanation of how each core ethical principle defined in this
framework has been assessed and applied in the specific context of the
proposed operation.
2. Risk & Proportionality Assessment
Identification of reputational, structural, and asymmetry risks, together
with a proportionality justification.
3. Conflict & Incentive Disclosure
Full disclosure of economic incentives, compensation structures, and any
actual or perceived conflicts of interest connected to the transaction.
4. Alternatives Considered
Summary of alternative approaches evaluated and justification for the
selected course of action.
5. Ethical Defensibility Statement
A clear statement confirming that the operation would remain defensible
under regulatory scrutiny, public transparency, and long-term reputational
review.
Generic, formulaic, superficial, or circular reasoning shall be deemed non-compliant. Ethical reasoning must be demonstrably substantive.
The ECM may be subject to independent review by a professional specialized in ethics, governance, or fiduciary oversight, selected for this purpose. Such review may be conducted at the discretion of the asset owner.
No execution shall occur prior to satisfactory completion of the ECM review process.