Compliance
One standard,every jurisdiction.
Forty group policies apply everywhere the institution operates. Each of the twenty-eight domiciles publishes six regulatory notices that adapt the standard to local provisions. Every policy and notice is available as a document.
- Group policies
- 40
- Regulatory notices
- 168
- Jurisdictions
- 28
- Documents
- 114
How it is organised
Compliance is a function of the group, owned by the General Counsel and overseen by the Compliance & Conduct Committee.
Policies are written once, at group level, and adopted by every local entity without dilution. Where a jurisdiction requires more, the local notice records the addition. Where a jurisdiction requires less, the group standard still applies. The result is that a client is treated the same way in Nassau, Luxembourg and Singapore.
Breaches are reported to the Committee within one business day of discovery. Whistleblowing reports go to an independent director, not to management. Complaints are acknowledged within five business days and answered within twenty.
Group policies
Forty policies in seven families.
Financial crime
Conduct and clients
Markets and trading
Data and technology
Governance and risk
People and culture
