Code of Conduct
We require that all our leadership and all employees, representatives, independent contractors and consultants comply with an institutionalised code of conduct to provide general guidance regarding conduct and ensure the observance of corporate governance best practices throughout the firm. The code lays out the responsibilities of each person with regards to confidentiality, disclosure, protection and use of information and transparency, and serves as the foundation for our firm-wide practice of international standard corporate governance practices.
Staff Dealing Policy
We strictly prohibit the buying or selling of securities while in possession of material non-public “inside information,” as well as the communication of that information to others. We define inside information as material, non-public information about securities, activities, or financial conditions of a corporation, public entity or other issuer of securities. Material, non-public information concerning market developments may also be construed to be inside information.
Information should be considered "non-public" unless it is clearly public. Information is deemed public once it has been publicly announced or otherwise disseminated in a manner that makes the information available to investors generally.
If our employees are aware of inside information,
- They may not buy or sell securities that may be affected by that information, either for their own account or any account over which they exercise control, alone or with others.
- They may not pass along any inside information expressly or by way of making a recommendation for the purchase or sale of such securities based upon inside information.
These prohibitions are applicable no matter how inside information is acquired. They are applicable to the securities of EFG Hermes as well as other companies.
Group Compliance Policy
Our Compliance policy allows senior management to maintain best practice control standards and to fulfill regulatory requirements. More importantly, Compliance safeguards the Company against undue risk, whether reputational or financial.
Compliance policies, procedures and controls are continuously updated, reviewed, and communicated to all departments, branches and subsidiaries. Employees undergo annual AML – Anti Fraud and Risk awareness training, an additional ad-hoc trainings for new hires.
Whistle Blowing Policy
EFG Hermes is committed to maintaining a work environment with the highest standards of transparency and accountability. An important aspect of transparency and accountability is having a mechanism that enables employees to voice any concerns in a confidential, safe and effective manner. Employees should be empowered to share any information they may discover that highlights potential fraud and any failure to comply with a law, regulatory requirement, internal rule, regulation or policy or any workplace malpractice without fear of being reprimanded.
This policy is intended to assist employees who believe they have discovered fraud or malpractice; it is not designed to allow employees to question financial or business decisions taken by the company.
Information Disclosure and Business Continuity Policies
Appropriate management of information is essential for EFG Hermes to keep the trust of our clients and shareholders and world-class systems are in place to manage personal and corporate information that we store for our business operations. EFG Hermes adheres to the highest international standards for information disclosure and protection of sensitive information and we voluntarily choose to comply with stringent standards above and beyond those required by regulators in all our countries of operation. Our institutionalised disclosure and documentation procedures are reinforced by our commitment to raising awareness about the importance of these issues at the firm through employee training and information campaigns.
Chinese Wall Policy
Anti-Money Laundering Policy
We are committed to safe guarding confidential information against conflicts of interest arising from unstructured interactions between the firm’s divisions. Chinese Walls (sometimes referred to as "information sharing barriers") are in place to prevent the flow of inside information from "insider" areas to a "public area" of EFG Hermes. The Chinese Wall policy prohibits anyone in an insider area from communicating inside information to anyone in the public area.
A set of regulations and procedures is followed to regulate breaches of the wall, which are approved by a control room. Employee trading blackouts are strictly enforced during the lead up to major corporate announcements to prevent the improper use of confidential information. Any request for wall-crossing must be approved by compliance.
Furthermore, all sensitive or potentially sensitive developments are shared strictly on a “Need to Know” basis, to limit any risk of the spread of insider information.
We believe that having sufficient information about our clients is the best way to minimize the Firm’s risk of being used for illicit activities. It also protects us against fraud and enables us to recognize suspicious activity. Our Anti-Money Laundering (AML) Policy is based upon the strict adherence to the following procedures:
- The verification of the identity of new clients
- The receipt and payment of funds directly to / from the client (not from third parties)
- The reporting system of suspicious transactions
- The maintenance of complete and accurate records
- The education and training of all employees on the AML manual with regular updates
Due Diligence Processes
Our stringent due diligence processes, which are applied to individual and corporate clients alike, ensure that investments are made in keeping with each client’s specific profile and that accounts are protected by strict access regulations and documentation standards.
Our due diligence processes are implemented across business lines at EFG Hermes to ensure that our investment platforms are not used for illegal transactions. Potential clients are required to fill out a detailed questionnaire, and investor names are checked against international sanctions lists like OFAC and United Nations lists to protect the firm from entering into business with sanctioned individuals. Politically sensitive clients undergo a strict screening process and their accounts are subjected to stringent requirements to ensure compliance with international best practices in all areas.
Business Continuity Policy
EFG Hermes’ has invested time and money into developing a disaster recovery and business continuity plan that will protect the Firm’s data and IT infrastructure from fires, natural disasters and other unforeseeable events. All our regional offices have business continuity policies and procedures for notification and recovery. The business continuity plan will enable full operation of all lines of business in the event of natural or manmade disasters including accidents, sabotage and burglaries. A special Crisis Management Team composed of senior management and a Business Risk Coordinator responsible for all internal communication are also in place to implement disaster recovery procedures in a smooth and efficient manner.
KSA Pillar III Disclosure
For more Information about EFG Hermes KSA Pillar III Disclosure click here