Obligations of senior financial officers

Sarbanes-Oxley Act Compliance

HSBC has established specific obligations for its senior financial leadership, in accordance with the US Sarbanes-Oxley Act. These obligations supplement and apply in addition to (rather than in substitution of) HSBC’s purpose and values, the Statement of Business Principles and Code of Conduct (PDF 1.4MB) and applicable local laws.

For this purpose, covered ‘Senior Financial Officers’ in HSBC Holdings plc means the Group CEO, Group Chief Financial Officer, Global Financial Controller and any person performing a similar function. They are required to adhere to the following standards:

• Engage in honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships;
• Avoid conflicts of interest and disclose to the Chair of the Group Audit Committee any material transaction or relationship of which they are aware that reasonably could be expected to give rise to such conflict;
• Take such measures as appropriate to ensure that the HSBC Group complies with all applicable governmental laws, rules and regulations and provides full, fair, accurate, timely and understandable disclosure in reports and documents that it files with, or submits to, any securities regulatory authority including the UK Financial Conduct Authority and the US Securities and Exchange Commission and in other public communications it makes;
• Report promptly to the Chair of the Group Audit Committee any violations of this statement of Sarbanes-Oxley Act principles of which they are aware; and
• Be accountable for adherence to this statement of Sarbanes-Oxley Act principles.