Important information

Anti-bribery and corruption

Anti-bribery and corruption

Policy statement

SG Hambros Bank Limited and its subsidiaries (collectively SGPB Hambros Group – SGPBHG) is committed to ensuring that:

It implements policies and procedures to minimise  the risk that a bribe is made by an associated person on its behalf;

It implements policies and procedures to minimse the risk that it is used to facilitate the payment or receipt of a bribe or the proceeds of corruption;

It acts as a responsible member of the community in deterring, preventing and, where necessary, reporting Bribery and Corruption to the relevant authorities; and,

Its employees at all levels abide by the highest standards of moral and ethical behaviour.

SGPBHG will comply with both the spirit and specific provisions of all relevant Anti-Bribery and Corruption laws, regulations and rules.

Objectives of the Anti-Bribery and Corruption Strategy

The objectives of the SGPBHG Anti-Bribery and Corruption Strategy are as follows:

SGPBHG minimises the risk that an associated person pays or receives a bribe for or on its behalf;

SGPBHG minimises the risk that it is used to facilitate the payment or receipt of a bribe or the proceeds of corruption;

SGPBHG will take and enforce a zero tolerance attitude to Bribery and Corruption, whether committed by external third parties, any member of staff, its clients or any combination of these parties colluding together.

SGPBHG will protect the reputation and integrity of itself, its parent company in France, Société Générale and of the financial markets within which it operates.

SGPBHG will constantly measure, monitor and report on Bribery and Corruption risk to enable Senior Management to better understand that risk and to enable them to maintain the appropriate policies and procedures required.

SGPBHG will proactively apply industry best practice with regards to Bribery and Corruption prevention and liaise as appropriate and where necessary with any industry bodies.

In the event that SGPBHG is exposed to Bribery and Corruption activity, it will ensure that investigations and actions are in accordance with the documented SGPBHG investigation process; including consideration of "self-reporting" incidents to the Serious Fraud Office.