Skip to content

Fighting financial crime

Bribery and corruption

We’re taking action

Find out what we do to fight bribery and corruption

Home > About us > Fighting financial crime > Bribery and corruption

Underpinned by the UK Bribery Act (UKBA) and US Foreign Corrupt Practices Act (US FCPA), there is a Code of Conduct, Group Anti-Bribery & Corruption (ABC) Policy and ABC Standards in place preventing our employees from accepting or receiving bribes in any form.

Our Group ABC Policy and Standards are developed in line with the minimum requirements of the UKBA and the US FCPA. In addition, employees must ensure that their actions do not create the perception of bribery or corruption. We also prohibit bribery by third parties that act on our behalf, with a Group ABC Compliance programme and adequate procedures in place aligned with industry and regulatory guidance to reduce the risk of corruption.

In addition, we encourage employees, and anyone else who has a concern about misconduct, to raise it through our Speaking Up programme.

What is bribery and corruption?

When someone gives a benefit to someone else to influence that person’s relevant function or activity, that is a bribe. When someone takes improper advantage of their position to make a gain for themselves, they are acting corruptly.

Bribery and corruption are illegal, dishonest and extremely damaging to the markets and communities where they take place. Corrupt governments take away from communities instead of serving them.

A bribe can be anything of value

A bribe is not always a cash payment and can include improper gifts, entertainment, charitable and political contributions or offers of employment or internships. Offering anything of value as a means of influence can be considered a bribe.