HSBC public statement of anti-bribery and corruption

The HSBC Group is committed to preventing bribery and corruption and to consistently apply the letter and spirit of applicable anti-bribery legislation in all markets and jurisdictions in which it operates. This includes, but is not limited to, the UK Bribery Act 2010, the US Foreign Corrupt Practices Act 1977 and the HK Prevention of Bribery Ordinance 1970 (as amended). This is consistent with the Group's commitment to high behavioral standards, doing the right thing and acting with courageous integrity.

The HSBC Group has in place a Group Business Policy and Principles for Countering Bribery (BPPs) designed to prevent the occurrence of bribery. The HSBC Group has a zero-tolerance policy with respect to the giving or receiving of bribes, including the making of facilitation payments. We expect all employees, associated persons and other third parties with whom HSBC works, to comply with these principles in the performance of their services for or on behalf of the HSBC Group.

The BPPs prohibit any HSBC Group employee or contract staff from, directly or indirectly, offering, promising, soliciting or receiving any payment that is in the nature of a bribe, kickback, advantage or other inducement in any form. This applies where the payment has the purpose or effect of public or commercial bribery or encouraging the improper performance of one’s functions or activities. Additionally, it prohibits the use of other routes or channels to provide improper advantages to customers, agents, contractors, suppliers or employees of any similar party or to government officials.

This prohibition applies also to third parties who are retained to perform services or conduct business for and on behalf of an HSBC entity or those conducting business together with an HSBC entity (including, but not limited to, agents, finders, representatives, intermediaries, introducers, brokers, advisors, contractors, suppliers, consultants and joint venture entities).

Our BPPs are summarised below:

  • Bribery and facilitation payments: All forms of bribery, including facilitation payments (except in order to protect against loss of life, limb or liberty), are prohibited, whether they take place directly or indirectly through another party

  • Public officials: Dealings involving public or government officials require heightened care, diligence and transparency and a need for appropriate disclosures and approvals ahead of such dealings

  • Political contributions: Funds, property or facilities of the HSBC Group must not be used to provide support for, or contribute to, any political organisation or political candidate

  • Charitable contributions and sponsorships: Charitable contributions and sponsorships are not to be used as a subterfuge for bribery

  • Gifts and hospitality: HSBC's employees must not offer or accept any advantages to or from any person which are likely to lead to, or be perceived as leading to, improper performance of their duties of good faith, impartiality or a breach of trust. HSBC has similar expectations of its associated persons and other third parties with whom it works

  • Payments and financial controls: HSBC's expenses and payments procedures and authorisation processes require a clear understanding of why payments are made and to whom, ensuring that there is a clear business rationale. HSBC has similar expectations of our third parties

  • Communication: HSBC Group senior management is committed to maintaining a culture in which bribery is never acceptable and intends that its zero-tolerance policy is clearly communicated to all employees and all relevant third parties