public policy engagement Open and transparent dialogue
We believe in having an open and transparent dialogue with all our stakeholders
At Standard Chartered our purpose is to drive commerce and prosperity through our unique diversity. To do so, we need to take a long-term view. Listening and responding to stakeholder issues or concerns is critical to achieving this and to delivering on our brand promise which is to be Here for good. We strive to maintain open and constructive relationships with a wide range of stakeholders including regulators, lawmakers, clients, investors, civil society and community groups to help us operate as a responsible and sustainable business. This helps inform our business strategy and build sound relationships in the markets where we operate. The engagement with policymakers and other stakeholders is overseen by the Bank’s Board and involves various functions at Group, regional and country levels. Our Board and Management Team members also engage with policymakers regularly.
On a day-to-day basis, our Compliance and Public Affairs functions are responsible for identifying changes to financial services regulation, ensuring that we comply with all requirements, and helping to manage relationships with policymakers. Responsibility for our public policy engagement rests with the Group Head Conduct and Financial Crime and Compliance.
We have strict governance procedures in place across the Group, and expect high standards of conduct and behaviour from all our staff, directors and contractors in dealing with political stakeholders. This is outlined in our Code of Conduct which all employees are required to recommit to annually. All our staff also complete a range of training on joining the Bank and recertify many of these yearly to highlight the importance of observing and delivering high standards of conduct and behaviour. Modules include Conduct, Sanctions, Rejecting Bribery and Corruption (RBC), and Anti-Money Laundering and Counter Terrorist Financing (AML). In addition to modules that all staff complete, we provide specialist training in specific financial crime and conduct topics to identified parts of our population based on role, including front line, operations and Financial Crime Compliance staff. There are specific modules on Politically Exposed Persons (PEPs) as part of Client Due Diligence (CDD) certifications. Managers are also required to undertake specific training to drive a culture of good conduct and governance. This is mandatory, tracked and impacts performance reviews if not completed within defined time periods. In 2019, we engaged with policymakers at all levels on topics such as prudential rules, markets and conduct regulation, Brexit, trade promotion, FinTech, cyber security and fighting financial crime.
Our valued behaviours
We are committed to ethical behaviour, integrity and responsibility in all our activities. Our internal policies and procedures for public policy activities are designed to meet these values and the laws, norms and stakeholder expectations for integrity and ethical behaviour across our markets. This also ensures that our public policy activities are carried out consistently across our Group and third parties acting on our behalf. We recently re-set expectations for every employee of the Group, based on three new valued behaviours: Do the right thing, Never settle, and Better together. Taken together these behaviours will help us to continuously challenge the way we do things, make better decisions, and hold each other accountable.
Engaging with governments, regulators and other policymakers
We engage with relevant authorities to play our part in supporting the effective functioning of the financial system and the broader economy. We comply with legislation, rules and other regulatory requirements applicable to our businesses and operations in the jurisdictions within which we operate. Our compliance with legal and regulatory frameworks ensures that the Group meets its obligations and supports the resilience and effective functioning of the broader financial system and economy. As an organisation, we are committed to ethical behaviour, integrity and responsibility in our engagement with officials. Deeply embedding a culture of ethical banking ensures we are able to deliver for our investors, our clients, our colleagues and our communities. Good conduct – doing business in the right way – can, and will, be a powerful differentiator for our Group. You can read more about our approach to stakeholder engagement in our Annual Report on pages 109 – 115.
We actively engage with government officials, regulators and policymakers at a global, regional and national level to share insights and to support the development of best practice and the adoption of consistent approaches across the markets in which we operate. We are committed to engaging with government officials and regulators in a transparent and timely way, and do so through a variety of channels, including through ongoing dialogue, submission of responses to formal consultations and by joining and participating in industry working groups. In 2021, we engaged with policymakers at all levels on topics such as Covid-19, international trade, financial services, sustainable finance and climate change, digital innovation, data privacy, artificial intelligence and cybersecurity.
The Group has signed up to the EU transparency register which is operated jointly by the European Parliament and the European Commission and discloses our key interests related to EU policymaking.
The Group’s engagement with government officials, policymakers and regulators is conducted directly by its staff and through industry associations. We do not retain the services of any public affairs consultancy to represent our interests at Group level or in our markets. Where we do retain public affairs consultants, they provide political and policy monitoring and intelligence.
The Group recognises the need to deal with policymakers and politically exposed persons in an appropriate and transparent way given the influence they may have over laws and regulations of material interest to the Group. As such, we have policies and standards in place to guide staff on how to engage with such parties and staff are required to undergo training, to ensure that our engagement with policymakers is ethical and responsible.
Further, the Group does not employ the services of serving politicians for advocacy or political engagement on behalf of the organisation. The Group operates in a highly regulated sector and its senior staff and individuals in roles of significant influence are subject to scrutiny and approval by the Group’s regulators before they may be appointed.
We are members of a wide range of financial services and other relevant professional and trade associations, some of which may engage with political stakeholders on topics that are of relevance to our business. We are members of an estimated 200 associations globally.
- Asia House
- Asia Securities Industry and Financial Markets Association
- Association for Financial Markets in Europe
- Association of Banks in Malaysia
- British American Business
- Chatham House
- China Banking Association
- China Britain Business Council
- Council on Foreign Relations
- Ghana National Banking College
- Global Financial Markets Association
- Institute of International Bankers
- Institute of International Finance
- International Swaps and Derivatives Association
- Kenya Bankers Association
- Loan Syndications and Trading Association
- National Futures Association
- Payment Association of South Africa
- Private Wealth Management Association – Hong Kong
- Securities Industry and Financial Markets Association
- Singapore Business Federation
- The Hong Kong Association of Banks
- The Thai Bankers' Association
- Uganda Bankers Association
- UK-UAE Business Council
- UK Finance
- UK India Business Council
- US Chamber of Commerce
- US India Business Council
- World Economic Forum
The Group has a policy in place which prohibits donations being made that would: (i) improperly influence legislation or regulation, (ii) promote political views or ideologies, and (iii) fund political causes. As an organisation, we are strictly non-political and do not allow political spending. We do not get involved in political activities, support political parties or have any political links.
More on our approach to banking
We’re committed to promoting social and economic development in our markets through our core business of banking