Code of Ethics and Rules of the Expert Network.

Article 1 • Preamble and Aims

1.1 · Nature and Mission of OETC
The European Observatory for Transparency in Cooperatives (OETC) is a non-profit association, governed by the French law of 1901 and registered with the Répertoire National des Associations (RNA) under number W751280030. Its head office is located at 200 rue de la Croix Nivert, 75015 Paris (France). By virtue of its nature, OETC acts exclusively for the benefit of its Members and in the public interest of promoting good governance and transparency within the European cooperative world.

1.2 · OETC's Role in the Relationship between the Professional and the Member
OETC does not directly provide advisory services, but acts as an ethical intermediation platform and strategic facilitator. This role implies three fundamental consequences:

Direct Contract The professional mandate, including economic conditions and responsibilities, is always concluded directly between the Member and the Expert. The OETC is not a party to this contract and cannot guarantee the result of the action undertaken.
Operational Immunity The OETC cannot be held responsible for any professional errors committed by the Expert. However, in the most serious cases affecting the collective interest (e.g., fraud or extortion against a Member), the Observatory reserves the right to bring a civil action.
Transparency towards the OETC With the Member's explicit consent, the Expert undertakes to provide the OETC with periodic updates on the status of judicial or extra-judicial action. This supervision mechanism enhances the protection of the Member and guarantees compliance with ethical principles.

1.3 · The European Register of Cooperative Governance (ERGC)
The ERCG is a protected database, designed and managed by OETC, which collects the results of judicial or extrajudicial actions initiated through the Network. To guarantee compliance with the GDPR while ensuring the effectiveness of the tool, data is processed in pseudonymized form. This means that information relating to individuals (e.g., the name of the reporting member) is replaced by an identifier and stored separately and securely.

Aims Map recurring problems by sector and by country, identify cooperatives presenting the greatest governance risk, guide OETC's advocacy activities, and provide useful data for supervisory authorities to target their inspections.
Controlled Access Experts cannot freely consult the ERCG. However, they can ask on a case-by-case basis whether a given cooperative has already been reported. Pseudonymized data (including the name of the cooperative and details of the dispute) are made available to the competent public authorities (ministries, supervisory bodies, public prosecutors) on their reasoned request.

1.4 · Confidentiality of the Expert Network
The cases we handle may involve important economic and political interests. To protect our Experts from possible pressure or reprisals, the complete list of Network members is not public. Each Professional may nevertheless, at their own discretion, present themself as a "Member of the OETC Network of Experts," provided that they scrupulously respect the present Code.

1.5 · Purpose of this Document
This Code establishes in a binding manner the conditions of admission, the application procedure, the ethical and deontological rules, the sanctions in the event of violation, and the transparency mechanisms that govern the OETC Network of Experts.

Article 2 • Legal and Ethical Reference Principles

The work of OETC and its Network is based on a solid legal and ethical framework:

Freedom of Association and Proportionality In accordance with Article 12 of the EU Charter of Fundamental Rights and the Law of 1901, OETC enjoys broad autonomy in the choice of its members. The selection criteria, made public by this Code, are proportionate and strictly linked to the objective of guaranteeing independence and competence.
Prohibition of Discrimination Under no circumstances are admission criteria based on gender, age, ethnic origin, political or religious orientation. Conflict of interest, on the other hand, is a legitimate evaluation criterion that is fundamental to our mission.
Subsidiarity with National Codes of Ethics This Code supplements and does not replace the codes of ethics of national professional bodies (e.g., bar associations, chartered accountants, psychologists), which remain fully applicable.
Fair Competition The OETC does not pursue aims that restrict competition. Any exclusion criteria are objective, balanced, transparent, and proportionate (OBTP test), with the aim of protecting the integrity of the Network.

Article 3 • Strategic Use of Artificial Intelligence (AI)

OETC adopts international AI best practices, in line with the EU AI Act and GDPR, to strengthen its action.

Application Areas AI is used for the triage of reports, textual analysis of large volumes of documents (articles of association, balance sheets), support for ERCG management, and aggregated reporting. Interactions can be both text-based (via the website, e-mail, chat) and voice-based (via dedicated assistance or reporting phone numbers). This multi-channel approach is fundamental, given the European nature of the entity, to eliminate language barriers and maximize the scope of action in all EU countries.
Accredited Suppliers We only use technology suppliers (e.g., OpenAI, Google, Anthropic) that offer the highest guarantees of security and compliance to operate within the EU.
Human Supervision (Human in the Loop) No decision affecting the rights of a Member or the assessment of an Expert is fully automated. Any relevant AI results for decision-making purposes are always validated by a human member of the Ethics Committee or the Board of Directors.
Data Protection by Design Our technical infrastructure adopts the highest encryption standards and security procedures, "privacy by design" and "privacy by default."

Article 4 • Key Definitions

Professional/Expert Lawyer, chartered accountant, psychologist, or other consultant registered with a professional association in an EU/EEA member state, admitted or candidate to the OETC Network.
Firm Any form of company or professional association to which the Expert belongs.
Relevant Conflict of Interest Any mandate, current or concluded within the last 60 months, assumed by the Expert or their Firm in favor of a cooperative, which could reasonably compromise their impartiality in the protection of a member.
Level of Independence (Tier) :
- Tier A (Full Independence) Awarded to Experts who, over the past 60 months, have had no Relevant Conflicts of Interest.
- Tier B (Managed Independence) Awarded to Experts of very high specialization who, although presenting a potential conflict, adopt certified organizational measures ("Chinese walls") to isolate the OETC mandate and guarantee impartiality.
Transparency towards the OETC A mechanism, activated with the Member's explicit consent, which authorizes the Expert to share with OETC the progress and key documents of a dispute, in order to reinforce ethical supervision and strategic support.
Registre Européen de la Gouvernance Coopérative (REGC) The protected database, managed by OETC, which archives the results of judicial and extra-judicial actions in pseudonymized form.

Article 5 • Admission Criteria and Procedure

5.1. Conditions of Eligibility

Habilitation and Territorial Competence To be duly registered with the professional association of the country in which they practice, and to undertake to limit their activity for OETC to this jurisdiction.
Judicial and Disciplinary Integrity No final criminal convictions for offenses against property, public administration, or public trust. Candidates are required to declare any pending criminal proceedings or disciplinary sanctions received from their professional order in the last five years. Failure to do so will result in immediate exclusion.
Independence (Tier A or B) Meet the requirements for one of the two levels of independence.
Economic Transparency Provide, in confidential format, a list of major customers (>10% of sales) over the last 24 months, for the sole purpose of assessing potential conflicts.
Acceptance of the Code Digitally sign the present Code.

  
      Step
      Description
      Timeframe
    
      1. Application
      Upload CV, registration certificate, self-declaration of conflicts, customer list, acceptance of Code on dedicated portal.
      Day 0
    
      2. Verification
      Document authenticity checks, preliminary checks against blacklists and legal databases.
      ≤ 10 days
    
      3. Hearing
      Interview (video/face-to-face) with the Ethics Committee to discuss values, complex cases and the use of AI.
      optional, +5 days
    
      4. Decision
      Governing Board vote. In the event of a tie, the President has the casting vote.
      ≤ 45 days in total
    
      5. Notification
      Official e-mail with result, assigned Tier and any limitations.
      Day of decision
    
      6. Trial (12 months)
      The admitted Expert operates on a trial basis. Random audit of 1 case; feedback from the Member.
      Months 6-12
    
      7. Confirmation
      Final result communicated. In the event of rejection, reapplication possible after 24 months.
      Day 365

Article 6 • Expert's Code of Conduct

6.1 · Integrity, Impartiality, Diligence
The Expert undertakes to pursue the Member's legitimate interests exclusively, to refuse any outside pressure, and to handle the case with the utmost care.

6.2 · Conflicts of Interest
Independence is the founding value of the Network. It is strictly forbidden for the Expert or any member of his firm to have ever represented, in the past or at present, a cooperative in a dispute against its own members. This criterion of "historical purity" is essential and admits of no derogation, guaranteeing that the professional's loyalty is unequivocal and solely on the member's side. The Expert is obliged to report any new potential conflict within 5 days.

6.3 · Confidentiality and Security
The Expert protects all sensitive information and uses only encrypted channels approved and made available by the Observatory for the exchange of documents.

6.4 · Transparency of Fees
The Expert must present a detailed written estimate before accepting the mandate, informing the Member of any significant discrepancies and avoiding pacts that could compromise their independence.

6.5 · Personal Conduct
Any harassing, discriminatory behavior or behavior that undermines the dignity of the Member or other colleagues is prohibited.

6.6 · Internal Reporting Obligation
Any violation of the Code, by oneself or others, must be promptly reported to the Ethics Committee.

Article 7 • Remuneration and OETC Legal Support Fund

7.1 · Autonomy of Negotiation
In accordance with the principle of transparency (Art. 6.4), remuneration for professional activity is negotiated and agreed directly between the Expert and the Assisted Member.

7.2 · Economic Support Mechanisms
The OETC, aware that the cost of legal action can be an insurmountable obstacle, strives to create economic support mechanisms. In particularly serious cases, and in the face of proven economic difficulties on the part of the Member, the Observatory reserves the right to assess forms of support to fully cover or co-participate in the legal and expert fees required to initiate legal action.

7.3 · Decision-Making Process
The decision to grant a contribution is subject to the sovereign appraisal of the OETC Board of Directors, which examines each request on a case-by-case basis, in compliance with internal regulations guaranteeing fairness and consistency. The aim is to give even the most economically disadvantaged members access to justice.

7.4 · Acceptance by the Expert
By joining the Network, the Expert accepts the possibility of operating within the framework of this support mechanism, collaborating with OETC in defining mandates and justifying expenditure in approved cases.

Article 8 • Monitoring, Sanctions and Appeals

Monitoring The OETC carries out monitoring through an annual declaration of conflicts of interest and random audits.
Sanctions Violations of the Code may result in a written warning, suspension (1-24 months), or permanent revocation of Network membership, with possible reporting to the national professional association.
Appeal Procedure The Expert has 15 days to present their defense. An appeal against the revocation decision is possible within 30 days by way of arbitration under the rules of the International Chamber of Commerce (ICC) in Paris.

Article 9 • Reporting Channel for Members

Members who believe that an Expert has violated the Code may send a report (even anonymously) to the following address ethics@oetc-rights.eu. OETC guarantees a response within 30 working days.

Article 10 • Revision of the Code

The present Code is published on the OETC website. Any modification comes into force 30 days after its communication to the Experts.