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. The policy incorporates the results of regular risk assessments and emphasises 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 the policy in the performance of their services for or on behalf of HSBC.
HSBC’s Global AB&C Programme includes the following statement of overarching key principles:
Must be conducted without intent to bribe or corrupt;
Must be reasonable and transparent;
Must not be considered lavish or disproportionate to the professional relationship;
Must be appropriately documented with business rationale; and
Must be authorised at an appropriate level of seniority.
Furthermore, it is unethical, illegal, and contrary to HSBC principles and good corporate governance to bribe or corrupt others, including to:
Offer, promise, give or authorise others to give anything of value, directly or indirectly, to any party, or to influence any Public Official; or
Solicit or receive anything of value, directly or indirectly, from any party; 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);
in order to obtain or retain business or otherwise gain an unfair advantage in business.
Based on the principles above, the AB&C Programme imposes requirements under four risk pillars:
Employee Risk: All HSBC entities and individuals are required by policy to have appropriate controls in place to manage risks and maintain records when offering or accepting any gift, entertainment, political contribution, sponsorship, event, travel and accommodation or other advantage or when engaging in charitable giving or recruitment.
In connection with recruitment, it must be merit-based, fair, and in keeping with the stringent hiring standards applied by HSBC. Hiring, in 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.
Third Party Risk: All HSBC entities and individuals are required to ensure that appropriate due diligence and controls are applied to any third party they engage, to ensure that they comply with the letter and spirit of applicable anti-bribery legislation and regulation. When a third party performs services for or on behalf of HSBC, additional controls are applied to manage the enhanced risks from Associated Persons.
Strategic Risk: Controls are applied in order to protect against bribery and corruption risks, in areas such as strategic proprietary investments, acquisitions, disposals, joint ventures and products & services.
Customer Risk: Bribery & Corruption risks identified from customer behaviour are effectively managed through the application of controls.
As part of the prevention, identification and remediation of AB&C issues, mandatory training is conducted throughout HSBC in addition to targeted training tailored to the roles of the individuals. 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.
To view the statement on HSBC’s whistleblowing arrangements see the Environmental, Social and Governance (ESG) update published on the Measuring our impact page.