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Governance · Committee

Compliance & Conduct Committee

The Compliance and Conduct Committee owns the conduct record of the group. It reviews client classification and eligibility, financial crime screening, sanctions questions, complaints and the training record of every person who faces a client. Nothing is sold to a retail client in any jurisdiction, and the Committee tests that perimeter in each of the eight regions twice a year.

Chair
Fenella Marsh-Adeyemi
Members
4
Meets
Quarterly, with a further sitting whenever a breach, a sanctions question or a complaint requires one.
Reports to
The Board of Directors.

Remit

It approves the local variation that a domicile requires to a group policy, and it approves the perimeter analysis before the group registers anywhere new. Complaints reach it within five working days, and it reports the pattern rather than the count alone. A breach arrives with a named owner, a remedy date and the control that failed, or it is sent back.

Decisions reserved to the committee

  • Local variations to a group policy in a domicile.
  • Client classification decisions that are finely balanced.
  • Sanctions and financial crime escalations.
  • Remedy plans and named owners for conduct breaches.
  • The annual training and competence plan.

Membership

4 members.

MemberRoleBased
Sable Okonjo-LindqvistChief Operating OfficerLuxembourg
Beatrix Oduya-FerranteHead of Private WealthNassau
Aurelio Marchbanks-TanChief Financial OfficerGeorge Town
Yumiko Sandoval-ReyesIndependent DirectorTokyo
GovernanceAll nine committeesLeadershipBoard and Executive CommitteeGroup policiesThe forty policies