The GFSB adopts to a large measure general policy recommendations of ESBA with some local quirks. Some of our policy on various issues can be found herein, namely:


How can we develop a cultural and political context encouraging entrepreneurship?

  • Recognise and foster entrepreneurship as a value in education systems
  • Neither the EU nor Member States should impose any barriers on self-employment
  • Cut red tape, lower the tax burden and reduce administrative costs
  • Encourage start-ups, improve access to finance and introduce measures facilitating a restart after bankruptcy


How can ethical business practices be fostered in European economies?

  • Develop an EU business ethics policy, in cooperation with NGO’s
  • Urgent action to tackle late payments between businesses, unfair contracts and predatory lending
  • Exempt SME’s from mandatory corporate social responsibility (CSR) initiatives. The size of many SME’s and their position in society often results in socially responsible behaviour of these companies already. Enforcing mandatory CSR initiatives can have an adverse effect as SME’s often lack the means to comply with specific criteria that are initially designed for large businesses


How can education and training systems better prepare people for an entrepreneurial career?

  • Entrepreneurship should be taught as a horizontal subject at all levels of education
  • Education systems should improve entrepreneurial quality by developing links with businesses, encouraging life-long learning, and teaching labour-market relevant skills


How can administrative bodies facilitate the work of SME’s and avoid burdening them?

  • Simplify and clarify all legislation, and reduce administrative burdens
  • Involve business stakeholders in drafting, approval, and implementation of all legislation
  • Undertake an early, publically available SME Impact Assessments for all new EU legislation and amendments
  • Create a pan-European body, composed of SME organisations, to monitor the progress of the EU on SME – relevant issues


How can access to finance be improved for small businesses which require

  • A coherent EU policy on business finance must recognise differences in financing micro, small, gazelle, and medium companies
  • Simpler and more SME-friendly procedure for applying for EU funding
  • Improved access to finance through public-private partnerships, a better venue capital market
  • Low interest rates, particularly while the effects of the crisis are still being felt


How can we prevent tax policies from burdening SME’s?

  • The EU should encourage Member States to make tax policies more business-friendly
  • This can be achieved through non-binding tax incentives and a tax simplification framework to be coordinated
  • Lowering of taxes on profits and labour, in order to encourage SME’s to employ new staff


Unfair competition can manifest itself in various guises such as illegal and unregistered labour, favourable treatment being afforded to some companies over others etc. How can this issue be tackled?

  • Governments and institutions must be completely transparent and accountable for its decisions
  • A direct and aggressive approach to illegal labour must be employed by the powers that be to address this
  • An independent Office for Fair Trading must be established that can carry out arms length investigations into unfair business practices or even complaints from consumers

GFSB Code of Conduct

About the Code of Conduct:

The GFSB Code of Conduct serves as an important resource to ensure our daily business interactions are conducted with integrity. The Code applies and  clearly conveys to each of the Board of Directors and GFSB Members that the manner in which we achieve our business results matters. 


It is the GFSB’s policy and practice to maintain the highest ethical standards, and to create an organisation that is free of inappropriate or unlawful behaviour, and in which all are encouraged to share their concerns without fear of retaliation. 


To whom the code applies:


GFSB Members  

GFSB recognises that the majority of members join GFSB solely to avail themselves of the excellent networking opportunities, support, services and benefits available to them as business owners. Having built GFSB to be a brand trusted by business owners and politicians alike, it is imperative that GFSB protects its brand from damage. In order to achieve this, GFSB asks that members and volunteers adhere to a Code of Conduct.  


This code is intended to direct the conduct of members in relation to their interaction with other GFSB  members, employees and any third parties where the member is perceived to be acting in the name of GFSB or where they or their business purports to be in some way associated with GFSB in addition to being a member.  


The code does not extend to the interaction between GFSB members and their customers/clients or any other third party where the GFSB member is not acting in the name/as a representative of, GFSB.  

The Code  

GFSB asks that members:  

  • Act and present themselves at all times in a professional and courteous manner to all  members, employees and external contacts of GFSB
  • Only use the GFSB member logo to signify their membership and not in any way to  suggest or imply that the logo represents any trade or professional qualification or standard
  • In the case of volunteers, comply with all statutory requirements and GFSB policy and  procedure – maintain confidentiality when required to do so and comply with the provisions of the prevailing GFSB data policies  

Do not: 

  • Claim to represent themselves as being approved or endorsed by GFSB in connection with their business activity, or being an approved supplier to GFSB, without having first obtained express written consent from the GFSB Board or appropriate Policy Portfolio Chair  
  • Proactively market their own business when representing GFSB  
  • Act towards any employee or member in a manner which may give rise to any claim  against GFSB 
  • Discriminate against any person because of a protected characteristic e.g. age,  disability, gender reassignment, marriage and civil partnership, pregnancy and maternity,  race (including colour, nationality and ethnic or national origins), religion or belief, sex or  sexual orientation 
  • Use threatening or abusive behaviour or language  
  • Make verbal or written statements that are contrary to the aims and objectives of GFSB including Policy objectives  
  • Use GFSB property, resources, equipment or records for any purpose other than the  purpose for which they are intended
  • Make any undeclared profit, benefit or advantage from being a member or elected officer of GFSB 
  • Do anything or omit to do anything which is prejudicial to the interests of GFSB or could  bring GFSB into disrepute


Board Members 

The Code  

The board of directors is committed to teamwork and effective decision-making and board members will: 

  • Endeavour to represent the broader interests of members and/or stakeholders 
  • Seek to balance their contributions both as advisors and learners. 
  • Be honest with others and true to themselves 
  • Refrain from trying to influence other board members outside board meetings that might have the effect of creating factions and limiting free and open discussion. 
  • Be willing to be a dissenting voice, endeavour to build on other director’s ideas, offer alternative points of view as options to be considered and invite others to do so too. 
  • On important issues, be balanced in their effort to understand other board members and to make themselves understood. 
  • Once a board decision is made, support the decision even if their own view is a minority one. 
  • Not disclose or discuss differences of opinion on the board with those who are not on the board. The board should communicate externally with “one voice”. 
  • Respect and adhere to the confidentiality of information on sensitive issues, especially government briefings or personnel matters
  • Be an advocate for the organisation and its mission wherever and whenever the  opportunity arises in their own personal and professional networks 
  • Disclose one’s involvement with other organisations, businesses or individuals where such a relationship might be viewed as a conflict of interest. 
  • Refrain from the use of abusive or offensive language always showing respect for fellow board members and the membership in general.
  • Conduct GFSB activities so as to fully comply with Gibraltar law. 

Political Affiliations 

GFSB is a non-party political organisation and board membership should not be used as a stepping stone for those who have political aspirations. Any board member who joins the executive of any political party should inform the board and step down with immediate effect. Failure to declare such involvement will be seen as a breach of their duties as a board director and they will be asked to step down whilst the board investigates and follows its discipline procedure. 

Conflict of interest – duty to declare

GFSB, whilst operating in a political environment as a lobbying organisation, maintains an apolitical position, leaving it free to lobby and campaign on behalf of the smaller business community, irrespective of party politics.  Members acting on behalf of GFSB have a role in maintaining this political neutrality and high standards of integrity and conduct are expected.


All elected members or volunteers have a duty to declare details, to the satisfaction of the Board any situation where they or an associated person, such as someone with whom they live, a family member or business partner, could have an interest that conflicts or may potentially conflict with the interests of GFSB.


Examples of what could constitute an ‘interest’ to be declared by Board members are provided below.  Please note the list of examples is not exhaustive.


  • Brief details, to the satisfaction of the Board of any sales/supplies/services or consultancy provided to GFSB ie where a financial benefit could be received by the member
  • Brief details, to the satisfaction of the Board of any sales/supplies/services or consultancy provided to the Government of Gibraltar which could impact the GFSB lobbying objectives
  • Brief details, to the satisfaction of the Board of gifts and hospitality received above a cumulative value of £50 in one year in connection with their GFSB volunteer activity
  • Details, to the satisfaction of the Board of any election to Public Office, joining any lobby group or the executive of any political party
  • Other appointments eg Chamber of Commerce


All Board members should advise the GFSB Chair or Vice-Chair of any ongoing interests upon election/appointment or as soon as a relevant interest arises.


Declarations of interest must be included as an item on every formal meeting to ensure that there is no specific conflict or potential for conflict with any items for discussion.

The other board members ie those not declaring an interest, will need to consider the issues (taking advice where appropriate) and decide how to manage the conflict that has been identified:

  • It may be decided that there would be no conflict of interest taking into account the particular circumstances.
  • Where a conflict is clearly identified, action may include the ‘conflicted’ person either leaving the meeting, not voting on the particular issue or, if relating to a meeting attendance, then ensuring that more than one Board member attends  

  The discussion and decision must be recorded in the notes of the meeting.

  • The need for such declarations is for openness and transparency – it is not to prevent/forbid such transactions or interests.

Grey Clause: If a Board member is in any doubt that there could be a conflict of interest, the onus is upon that Board member to raise those doubts and disclose the potential conflict of interest and seek clarification from either the Chair or Vice-Chair prior to attending the meeting, event or accepting gratuities. 

A failure to declare a conflict of interest will be seen as a breach of their obligations as a board director and they may be asked to step down whilst the board investigates and follows its discipline procedure. 



Board members should keep all written and verbal communications and information discussed by the board members confidential unless otherwise agreed upon by the rest of the board. Any breach of confidentiality may result in the board member being asked to step down whilst the board investigates and follows its discipline procedure. 


Data Protection

GFSB respects the privacy of its employees, members, suppliers and other third parties with whom the GFSB has a business relationship and therefore, commits to handling personal data responsibly and in accordance with all applicable data privacy and data protection laws. 

Discipline procedure 

Any allegations of any breach of this code of conduct including a failure to declare appropriately a conflict of interest will be assessed and determined on the balance of probabilities by a quorum of four members including the Chair by a simple majority vote, in accordance with paragraph 22 of the Constitution.  The formal decision will be recorded by the Chair.  Such a process should be proportionate to the seriousness of the allegation(s) made. 

  • A first breach will result in that Board member receiving an informal verbal reminder from the Chair of the GFSB of their obligations under the code of conduct. 
  • A  second breach will result in a formal written warning and any necessary steps to rectify the breach. 
  • A third breach will result in the Board voting on whether the Board member who has breached the code of conduct should remain on the Board. At this meeting, the Board member concerned will be permitted to make written and verbal submissions and present evidence themselves or can ask another Board member to make representations on their behalf. Formal legal representation will not be permitted.  
  • Voting will be by ballot and the Board member concerned will be permitted a vote and will be asked to leave the room whilst the vote is conducted. Voting will be In accordance with paragraph 25 of the Constitution.  In the case of a tie, the Chair will hold the casting vote. 
  • Any disputes arising under this procedure will be referred to mediation in the first instance.

If you know of, or have a good reason to suspect, a violation of the Code or other Company policies, you are required to immediately report that information to the Chair or other Officer on the Board