HSBC Group Anti-Bribery and Corruption Policy Statement

All wholly owned or controlled HSBC Group of companies (“HSBC”) are committed to the highest level of ethical behaviour and have zero tolerance for bribery and corruption. HSBC requires compliance with all anti-bribery and corruption laws in all markets and jurisdictions in which it operates. These laws include, but are not limited to, the UK Bribery Act, the US Foreign Corrupt Practices Act and the HK Prevention of Bribery Ordinance.

HSBC’s Anti-Bribery and Corruption Compliance Programme includes global Anti-Bribery & Corruption (“AB&C”) Policies, with Holdings Board oversight, which emphasise that HSBC does not tolerate the giving or receiving of bribes, including the making of facilitation payments.  HSBC emphasises that books and records must be fair and accurate and reasonably detailed.   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 HSBC.

HSBC’s Global AB&C Programme includes the following global standards:

  • No HSBC entity or individual shall engage in bribery or corrupt practices in any form, whether direct or indirect;

  • No HSBC entity or individual shall engage in bribery with a public official or private party. This includes any advantage provided to a close family member or other closely connected person of the public official or private party; and

  • No HSBC entity or individual shall engage in the provision of a facilitation payment. Facilitation payments are typically small, unofficial sums made to secure or expedite a routine government action by a government official.  Exceptions may be permitted in extraordinary circumstances to protect against loss of life, limb or liberty.

The AB&C Programme also imposes the following requirements on activities of HSBC employees and Associated Persons:

  • Associated Persons: All HSBC entities and individuals must ensure that appropriate due diligence and controls are applied, according to policy, relating to any Associated Persons they engage to ensure that they comply with the letter and spirit of applicable anti-bribery legislation and regulation;

  • Gifts, Entertainment and other Advantages: No HSBC entity or individual shall offer or permit any gift, entertainment or other advantage to be offered without the appropriate controls being applied;

  • Recruitment: All recruitment must be merit-based, fair, and in keeping with the stringent hiring standards applied for all employees. Hiring, for paid or unpaid, temporary or permanent roles, must not be used to influence business;

  • Charitable Giving: No HSBC entity or individual shall offer or permit any charitable giving to be used as a subterfuge for bribery; and

  • Political Contributions: No HSBC entity or individual can use HSBC funds, property or facilities to provide support for, nor contribute to, any political organisation or political candidate as HSBC is politically neutral.

As part of the prevention, identification and detection of AB&C issues, mandatory training and risk assessments are conducted throughout HSBC.

HSBC also maintains clear whistleblowing policies and processes to ensure that individuals can confidentially report concerns and to ensure that such concerns are investigated and remediated appropriately.