Anti-Bribery, Gifts & Conflicts of Interest

As a regulated financial company we hold ourselves to a high standard of integrity — and that includes never letting a gift, favour, or personal interest improperly influence a business decision. Most gifts and hospitality are innocent; the rules exist so the rare improper one is easy to recognise and refuse. When in doubt, declare it and ask.

Bribery and corruption are serious crimes, and financial firms are held to strict anti-bribery laws. In day-to-day work this shows up as gifts and hospitality from suppliers or customers, and conflicts of interest (where a personal relationship or interest could sway a decision). The risk is not usually a bag of cash — it is the expensive dinner before a contract decision, or steering business to a friend's company.

You don't need to be an expert. The principles: nothing of value to obtain or reward improper advantage, be transparent (declare gifts and conflicts), and if something feels like it could look wrong, it probably needs declaring. This connects to Professional Ethics & Integrity.

Gifts & hospitality

• DoKeep gifts and hospitality modest, occasional, and transparent — and declare anything beyond the trivial through the proper process.
• DoBe especially cautious about gifts or hospitality around the time of a decision (a tender, contract, or approval) — timing can make even a normal gesture look improper.
• ConsiderPolitely declining anything that could create a sense of obligation, or check with your manager/compliance first.
• NeverGive or accept anything of value — money, gifts, hospitality, favours — intended to influence, reward, or secure an improper business advantage.
• NeverMake a facilitation payment or any payment to improperly speed up or secure a decision.

Conflicts of interest

• DoDeclare conflicts of interest — a personal relationship, outside role, or financial interest that could affect (or appear to affect) a work decision — and step back from decisions where you're conflicted.
• DoMake business decisions (suppliers, hiring, approvals) on merit, and be able to show they were.
• DoRaise it early if you're unsure whether something is a conflict — declaring is always safe; hiding it is the problem (see Professional Ethics, Speaking Up).
• AvoidPutting yourself in a position where a personal interest and a company decision quietly overlap without anyone knowing.

Ask yourself

• AskCould this gift, hospitality, or favour look like it's meant to influence a decision?
• AskDo I have a personal interest or relationship that could affect — or appear to affect — this decision?
• AskHave I declared it, or am I hoping no one asks?
• AskWould I be comfortable if this were fully visible to compliance or a regulator?