BdP Governor Álvaro Santos Pereira Bought Galp and Jerónimo Martins Shares After Taking Office — ECB Code of Conduct Forced Him to Reverse the Trades

Álvaro Santos Pereira, the Portuguese economist who took the keys at Banco de Portugal on 6 October 2025, walked into a code-of-conduct collision within weeks of arriving. Público reports today that in December 2025 — barely two months into his five-year mandate — the new governor placed orders for shares in Galp Energia and Jerónimo Martins, two of the heaviest weights in the PSI index, while already a member of the European Central Bank's Governing Council.

The trades surfaced when the governor filed his annual declaration of interests with the ECB in early 2026. Frankfurt's compliance office reviewed the entries and flagged them. Under Article 7 of the Single Code of Conduct for High-Level Officials of the ECB, members of the Governing Council are barred from short-term trading and from holding positions in firms whose securities the central bank can buy under its asset-purchase programmes. The remedy was unambiguous: reverse the operations. Santos Pereira complied, unwinding both trades.

Why Galp and JM Are Off-Limits

Both names sit in the ECB's eligible-issuer universe. Galp issues investment-grade corporate bonds that the ECB has historically held under its Corporate Sector Purchase Programme; Jerónimo Martins, the Pingo Doce and Biedronka owner, has been a recurring name in Eurosystem holdings. That places them squarely inside the perimeter the ECB code carves out for Governing Council members. The rule is not about whether a governor would ever vote to influence a specific issuer — it is about removing the question altogether.

The Banco de Portugal has its own Conduct Committee that mirrors the ECB framework and applies it to all senior staff. Under the BdP rulebook, board members must report personal transactions, observe a no-trading window around monetary-policy decisions, and in practice hold equities only through diversified collective vehicles. Single-name purchases of Portuguese listed companies sit outside that perimeter for the institution's most senior official.

A Governor Already Under Parliamentary Scrutiny

The disclosure lands at an awkward moment for the new governor. Earlier this month Parliament's economy committee approved a hearing for both Santos Pereira and his predecessor Mário Centeno over the BdP's purchase of a new headquarters in Lisbon — a file the opposition has dragged through six months of accusations about cost overruns. On 1 April the governor publicly censured Portugal's banking sector for what he called "unacceptable" prescription practices, calling the major lenders a de-facto cartel. He has spent his first six months building a profile of independence.

The ECB compliance episode complicates that posture. The trades were not concealed — they were declared on schedule, caught by the system that exists exactly for this reason, and corrected without delay. But the optics of a sitting governor buying single-name PSI listings two months into office land hard in a country still litigating the BES, Novo Banco and CGD legacies.

What Happens Next

The ECB does not publicly sanction members for first-instance code breaches that are reversed; the public record will be the next interests declaration, due in early 2027, which should show the positions cleared. The Banco de Portugal has not, at the time of writing, issued a comment on the episode. The Galp and Jerónimo Martins share prices were unaffected on Monday's open.

Santos Pereira's term runs to October 2030. He sits on the Governing Council that will decide the next phase of ECB rate cuts, and he chairs a national supervisor that is preparing to absorb the Novo Banco-BPCE deal closing and the BES creditor compensation file simultaneously. The trade reversal closes a procedural loop. The political loop on whether the governor's first six months have been clean enough is now in Parliament's hands.