Anti-bribery

The HSBC Group has in place an Anti-Bribery & Corruption Policy (the "Policy") supported by relevant Controls designed to prevent the occurrence of bribery. The HSBC Group and its senior management has a zero tolerance policy with respect to corruption, influence peddling, extortion by public officials, unlawful taking of interest, misappropriation of public funds, favouritism, or facilitation of payments. We expect all employees and third parties to comply with these principles in the performance of their services for or on behalf of the HSBC Group.

The Policy prohibits any HSBC Group employee or contract staff from, directly or indirectly, offering, promising or receiving any bribe, financial or other advantage, making any payment, transfer for value, non-monetary benefit of any kind, or other inducement in any form which has the purpose or effect of public or commercial bribery, or acceptance of or acquiescence in bribery, extortion, influence peddling, facilitation payments or other unlawful or improper means of obtaining or retaining any business or commercial advantage or bringing about the improper performance of any person's business or public function or activity.

This prohibition applies also to third parties, who are retained to perform services or conduct business for and on behalf of an HSBC entity or those conducting business together with an HSBC entity (including, but not limited to our agents, representatives, intermediaries, introducers, brokers, contractors, suppliers, consultants and joint venture entities) ("third parties").

Our Policy is summarised below:

• Bribery and Facilitation Payments: All forms of bribery, including facilitation payments (except in order to protect against loss of life, limb or liberty), are prohibited, whether they take place directly or indirectly through another party.
• Public Officials: Dealings involving public or government officials require heightened care, diligence and transparency and a need for appropriate disclosures and approvals ahead of such dealings.
• Political contributions: Funds, property or facilities of the HSBC Group must not be used to provide support for, or contribute to, any political organisation or political candidate.
• Charitable contributions and sponsorships: Charitable contributions and sponsorships are not to be used as a subterfuge for bribery.
• Gifts and hospitality: HSBC's employees must not offer or accept any gifts or inducements (personal benefits) to or from any person which are likely to conflict with their duties to any customer or any office of the HSBC Group. It shall be granted without any intention of any reciprocity or of unduly influencing any decision, be reasonable, proportionate and transparent, do not generate any conflict of interest and do not give rise to any risk of undermining the reputation of the HSBC Group. We have similar expectations of our third parties.
• Payments and Financial Controls: HSBC's expenses and payments procedures and authorisation processes require a clear understanding of why payments are made and to whom. We have similar expectations of our third parties.
• Communication: HSBC Group senior management is committed to maintaining a culture in which bribery is never acceptable and intends that its zero tolerance policy is clearly communicated to all employees and all relevant third parties.
• Whistleblowing: Any potential or actual breach of the Policy can be reported via dedicated escalation channels.