Obligations of senior financial officers

The HSBC Values and Statement of Conduct are applicable to all HSBC employees and set out the fundamental standards to be followed by them in their everyday actions on behalf of the Company.

Sarbanes-Oxley Act Compliance

In addition to the Group Code, the Group Chief Executive, Group Chief Financial Officer and Group Chief Accounting Officer or persons performing similar functions (the ‘Senior Financial Officers’) are subject to and must comply with the following principles:

  • Each Senior Financial Officer shall engage in honest and ethical conduct, including the ethical handling of actual or apparent conflicts of interest between personal and professional relationships.
  • Each Senior Financial Officer shall avoid conflicts of interest and shall disclose to the Chairman 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.
  • Each Senior Financial Officer shall take such measures as appropriate to ensure that HSBC 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 Financial Conduct Authority and the Securities and Exchange Commission and in other public communications it makes.
  • Each Senior Financial Officer shall report promptly to the Chairman of the Group Audit Committee any violations of this statement of Sarbanes-Oxley Act principles of which they are aware.

Each Senior Financial Officer shall be accountable for adherence to this statement of Sarbanes-Oxley Act principles.

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