Conduct is a critical component of all of HSBC’s business activities. It is embedded within the Group’s strategy, business models and planning, our culture and behaviours, interaction with customers, products and services, financial markets operations, and governance and oversight processes.

We have established a Global Conduct Framework with five pillars and 15 outcomes describing the behaviours to which we aspire. It increases our understanding of how the decisions we make affect customers and other stakeholders, helping us to strengthen our business.

Each global business and global function must ensure that its policies are designed to deliver the outcomes set out in the Global Conduct Framework.

The Conduct Framework

The Global Approach for the management of conduct has been approved by HSBC’s Group Risk Management Meeting, and the Conduct & Values Committee of the HSBC Holdings plc Board.

Conduct is defined as ensuring we deliver fair outcomes for our customers and that we do not disrupt the orderly and transparent operation of financial markets.

Global Business Lines, Global Functions and HSBC Operations, Services and Technology are each responsible for conduct within the scope of their activities, and must develop, maintain, and be able to evidence approaches to conduct, tailored to their markets and operations, which deliver the required Global Conduct Outcomes set out within the Global Approach.

The Global Conduct Outcomes are organised around five Pillars which categorise where conduct issues may crystallise. The pillars and Global Conduct Outcomes are outlined in the table below.


The Pillars Global Conduct Outcomes
Pillar 1: Strategy and Business Models - Our strategy, business models, and the decisions we make deliver fair treatment of customers and do not disrupt market integrity
Pillar 2: Culture and Behaviours - Our culture supports our people and empowers them to consistently do the right thing for our customers and markets in which we operate

- Our people are competent and committed to the fair treatment of customers and not disrupting the integrity of markets

- We are open to challenge, we acknowledge when things go wrong, we fix things and we learn from our mistakes

- We reward and incentivise performance, behaviours and attitudes which deliver the fair treatment of customers and uphold market integrity
Pillar 3: Customer - We know our customers and understand their needs - we actively listen to them and ask the right questions

- Our products are designed to meet the different needs of our customers, to be competitive and to be understandable

- Our products and services provide a balanced exchange of value between HSBC and our customers

- Throughout our sales and servicing we are efficient, transparent and customer-focused

- We manage our products and services so that our customers’ experience is in line with the expectations we set
Pillar 4: Markets - We seek to prevent and will proactively identify actions and behaviours that constitute market misconduct, and respond appropriately

- Trades are executed in a timely, clear and controlled manner ensuring that optimal execution is achieved for our customers and that HSBC trades are not manipulative

- We manage conflicts of interest and appropriately handle information to reduce the opportunity for misuse
Pillar 5: Governance and Oversight - Our governance framework provides effective oversight of how we fairly treat customers and uphold market integrity

- We engage with regulatory bodies in a timely, open and transparent manner

The Conduct & Values Committee provides Board oversight of our efforts to raise standards of conduct and to embed the values we stand for. Further detail on the broad range of activities we undertake to enhance conduct is provided in the Annual Report and Accounts.

Related content

Our values

At HSBC, how we do business is important as what we do. We seek to build trust-based and lasting relationships with our many stakeholders.

Reputational risk

Any lapse in standards of integrity, compliance, customer service or operating efficiency represents a potential reputational risk.

Board committees

The Board has appointed a number of committees consisting of certain Directors, Group Managing Directors and certain co-opted non-director members.