The ECB 'Supplementary Code of Ethics Criteria for the members of the Executive Board' states;
 
Ethics Officer

In order to ensure a consistent application of this Code, members of the Executive Board should, in case of doubt about the practical application of any ethics criterion laid down in this Code and the ethics framework for members of staff, to the extent applicable to them, consult the ECB’s Ethics Officer.

// Mr Hildebrand complied with this approach.

Compliance with rules on insider trading

Members of the Executive Board are subject to the comprehensive compliance rules on insider trading and the monitoring regime in force at the ECB. They are strongly recommended to place their investments under the control of one or more recognised portfolio managers with full discretion. This recommendation does not apply to current accounts, deposits accounts, saving accounts and money market funds or comparable short-term instruments. This recommendation is also without prejudice to the possibility to occasionally mobilise funds for the purchase of certain goods or for investing in real estate. (underlining by editor)

// In hindsight it remains questionable whether the Ethics Officer at the SNB would have given the all clear to keeping the August purchase, had he known that only 2 months later a nearly identical sized position would be closed.