HSBC Group Anti-Bribery and Corruption Policy Statement

HSBC Holdings plc and the entities that form the HSBC Group (HSBC) are committed to high standards of ethical behaviour and have zero tolerance towards 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 the UK Bribery Act, the US Foreign Corrupt Practices Act and the HK Prevention of Bribery Ordinance, as well as other similar laws and regulations in the countries where we operate.

HSBC’s Anti-Bribery and Corruption (AB&C) compliance programme and policies are overseen by the HSBC Holdings plc Board. Policies incorporate the results of regular risk assessments and emphasise that books and records must be fair, accurate and kept in reasonable detail. HSBC requires all employees, including the Board of Directors and Associated Persons, to comply with the principles in these policies in the performance of their services for or on behalf of HSBC.

HSBC’s Global AB&C Programme includes the following statement of principles:

  • It is unethical, illegal, contrary to HSBC principles and good corporate governance to bribe or corrupt others, including to:

    • Offer, provide, agree to accept or accept anything of value to induce recipients to act improperly, whether directly or indirectly (eg to a close family member or other closely connected person); or

    • Offer or provide a facilitation payment. Exceptions may be permitted in limited circumstances where an employee’s health, safety and/or liberty is at risk;

    • Influence or attempt to influence Public Officials in order to obtain or retain business or an advantage in business.

  • Based on the principles above, the AB&C Programme imposes the following requirements:

  • Associated Persons: All HSBC entities and individuals are required by policy to ensure that appropriate due diligence and controls are applied, according to policy, 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 charitable giving: All HSBC entities and individuals are required by policy to avoid offering, accepting or permitting any gift, entertainment, charitable giving, sponsorship or other advantage to be offered or accepted 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 third parties or to obtain or retain business or an advantage in business.

As part of the prevention, identification and remediation of AB&C issues, mandatory training is conducted throughout HSBC with the content tailored to the roles of the participants. HSBC carries out regular, risk based assessments, monitoring and testing of its AB&C programme.

HSBC also maintains clear whistleblowing policies and processes to ensure that individuals can confidentially, with no fear of retribution, report concerns to be investigated and remediated appropriately. Further details can be found in the Environmental, Social and Governance (ESG) update published on the Measuring our impact page.