Coronavirus (COVID-19): Recommendations to supervised entities on telework and a possible return to the office

The recent easing of the lockdown by the Luxembourg government has not signaled the end of the COVID-19 pandemic. Given the number of staff directly employed in financial services, in excess of 50,000, CSSF firmly recommends to supervised entities to remain extremely careful when considering allowing the return to the office, so as to contribute keeping the infections at a low rate and to ensure business continuity. It is thus recommended that:

1. Teleworking continues, wherever possible
2. The return to the workplace is limited to a minimum, e.g. when tasks cannot be performed remotely. One example would be branches with client interaction
3. External meetings are held by video or audio conferencing, rather than physical meetings

Where staff is allowed to return to the office, strict staff health protection guidelines should be established in writing, discussed with staff or their delegates, and published to all staff. These guidelines should address the following issues:

1. Identification of vulnerable staff, or part of a household with a vulnerable person, that should stay at home. Please refer to the recommendation of the Conseil supérieur des maladies infectieuses
2. Selection criteria for returning staff for the whole entity and by department
3. Maximum number of staff able to work safely, at a distance of at least 2m each side (unless there is a hard separation). Available and unavailable workstations should be clearly marked
4. Rotation of staff working at the office, if such rotation is planned
5. Access to, and departure from the office
6. Circulation in the office, including items like wearing masks where a distance of 2m cannot be guaranteed, the use of elevators and staircases
7. Rules for internal meetings. Unless a distance of 2m can be guaranteed, they should be held by video or audio conferencing
8. Access to dining facilities, coffee corners and meeting areas
9. Cleaning of office space and equipment
10. Display of personal hygiene rules, as published by the Luxembourg government (version of 12 May 2020): https://msan.gouvernement.lu/dam-assets/covid-19/fiches_information/en/Fiche-GB-EN.pdf

We will revise the above recommendations depending on the evolution of the pandemic and the recommendations by the Luxembourg government.