Statement of Business Principles and Code of Conduct

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Statement of Business Principles and Code of Conduct HSBC Holdings plc Statement of Business Principles and Code of Conduct Table of contents Summary 2 Introduction from our CEO 3 HSBC Group values and principles 4 Managing conduct 6 Managing risk 7 Respect for the law 8 Respect for all 11 Protecting company assets 12 Conflicts of interest 14 Doing the Right Thing for Our Customers 16 Supporting sustainability 17 Compliance, reporting violations and asking questions 18 1 Summary Our Statement of Business Principles and Code of Conduct (referred to as “the Group Code”) applies to the directors of HSBC Holdings plc (“Directors”), its officers and employees of the HSBC Group. For the purposes of the Group Code: “HSBC Group” or the “Group” means HSBC Holdings plc and its wholly owned subsidiaries; and HSBC Holdings plc executive directors and officers are also employees of the HSBC Group. Regional and country requirements may also apply and members of the HSBC Group are required to establish Codes of Conduct that apply to their executive directors and employees. Such Codes must be aligned to the Group Code to the extent permitted by local law and regulation. 2 Introduction from our CEO Our purpose is to be where the growth is, connecting customers to opportunities. We help enable businesses to thrive and economies to prosper, helping people to fulfil their hopes and dreams and realise their ambitions. For over 150 years, this purpose has underpinned all that we do. It continues to guide us as we seek to adapt to changing customer expectations in an evolving economic, political and increasingly digital world. To achieve our purpose, we seek to build strong relationships with all our stakeholders, including customers, colleagues, suppliers and the communities we operate in. This helps enable us to deliver our strategy in line with our long-term values and operate the business in a sustainable way. Our success as a leading international bank serving customers and society for more than 150 years is guided by a set of principles. Our Global Principles set an overarching standard for all our other policies and procedures, and are fundamental to the HSBC Group’s risk management structure. They inform and connect our purpose, values, strategy and risk management principles, guiding us to do the right thing and treat our customers and our colleagues fairly at all times. Our Global Principles outline that our people must treat each other with dignity and respect, creating an inclusive culture to support equal opportunities. We do not tolerate any discrimination, bullying, harassment and victimisation. Good conduct is key to winning and retaining our customers’ trust. Through our actions and behaviour, we aim to deliver fair outcomes for our customers and support the orderly and transparent operation of financial markets. Conduct is a critical component of all of HSBC’s activities. It is embedded within the HSBC 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. Noel Quinn Group Chief Executive HSBC Holdings plc 3 HSBC Group values HSBC’s values reflect how we interact with customers and colleagues, regulators and the wider community. Our values define who we are as an organisation and what makes us distinctive. HSBC brings these values to life through our day-to-day actions. We are committed to putting our values at the heart of how we behave. HSBC’s values guide us in what is important. We are: Open Dependable Connected to different ideas and cultures and we do the right thing to customers, communities, regulators and each other Communicating openly, Standing firm for what is Building connections, being honestly and transparently, right, delivering on externally focused, collaborating welcoming challenge and commitments, being across boundaries learning from mistakes trustworthy Caring about individuals and their Listening, treating people Taking personal progress, behaving respectfully, fairly, being inclusive, valuing accountability, being decisive, being supportive and responsive different perspectives using good judgement and common sense, empowering others 4 Our values shape our relationship with and our approach to our customers, each other and society. We aim to: Customers Each other Society actively listen and ask the treat individuals with dignity conduct our business in an right questions so that we and respect. We value them ethical and responsible way understand our customers' for the contributions they manage financial crime risk to needs make help safeguard the financial treat customers fairly. We encourage and embrace system and the communities we only offer them products and diversity serve services that meet their collaborate with each other, recognise our wider obligations needs, and always act in their inviting different perspectives towards communities and best interests and views. We welcome and understand that economic ensure our products and respond positively to growth must be sustainable standard of service live up to challenge take into account the long-term the expectations we set help our people enhance their effects of our business and speak up if we make a own physical, mental and strategy on society, the mistake, fix it and learn from it emotional well-being. We environment and communities care about our customers and support work-life choices are empathetic to their where we can circumstances. We are as support our colleagues to supportive as possible during realise their aspirations and adversity achieve their potential provide a safe environment provide colleagues with a safe for our customers when they working environment visit our premises empower people to do the right thing encourage colleagues to speak up where they have concerns 5 Managing conduct The HSBC Group expects its people to behave professionally at work. Speaking up Good conduct at HSBC means delivering fair outcomes for customers and maintaining the orderly and transparent operation of financial markets. HSBC continues to create a The conduct framework provides a set of outcomes to achieve across speak-up culture. In line with everything HSBC does. It covers key areas where conduct issues can Our Global Principles, HSBC arise: promotes open and honest Strategy and Our strategy, business models, plans and communication, supporting business models decisions always aim to treat customers fairly people in raising concerns and to not disrupt market integrity about anything that goes against HSBC Group values, Culture and Our culture empowers our people and breaks the law, breaches behaviours rewards them for doing the right thing for our customers and markets and always learning regulations or policies, or that from any mistakes simply feels wrong. HSBC does not condone or tolerate Customer We know our customers and understand their any acts of retaliation against needs; we deliver appropriate, competitive those who speak up. products they understand, supported by efficient customer service HSBC encourage individuals Markets We seek to identify and prevent actions and to raise concerns through all behaviours that can result in market misconduct whilst ensuring we execute our usual escalation channels, transactions promptly and efficiently and including via Line Managers, safely handle any information we have HR or Compliance. However, we understand there are Governance and We carefully manage and oversee the way we circumstances where oversight treat customers, ensuring it is fair and that we individuals may wish to raise uphold market integrity; we always maintain timely, open and transparent engagement concerns discretely. HSBC with our regulators Confidential, our global whistleblowing platform, For more information on our approach to Conduct, visit enables concerns to be raised https://www.hsbc.com/our-approach/risk-and-responsibility/our- confidentially, ensuring all conduct cases are thoroughly and impartially investigated. 6 Managing risk HSBC faces many risks. Some we accept as part of The focus of our Risk Management Framework is to: doing business, but there are others we must avoid so Manage risk consistently across the HSBC Group we can protect our business, customers, colleagues, shareholders and the communities we serve. Have a strong risk culture: managing risk is simply part of how we work HSBC’s Risk Management approach, which is underpinned by our values, outlines our overall Be aware of risks, identify our material risks and approach to managing risk. It is used throughout the take better decisions as a result HSBC Group, including by all our subsidiaries, Have controls in place to ensure we only take the countries, global businesses and functions. right type and amount of risk to grow our business safely and within our appetite Deliver fair outcomes for customers and help protect market integrity HSBC's Risk Management approach Govern the risks through analysis, Govern 5 challenge and remediation Aggregate and analyse data Aggregate and Report 4 Report to enable decision making Manage and control our risks within Manage 3 appetite Identify and record risks to our business Identify and Assess 2 Assess the potential impact Define risk appetite and controls Define and Enable 1 Enable risk culture and accountability 7 Respect for the law Directors and employees are expected to respect laws, Sanctions rules and regulations applicable to them. A large number of laws and regulations around the world
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