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Policies and Procedures

Code of Conduct

EFG Hermes requires that all leadership, employees, representatives, independent contractors and consultants comply with an institutionalized 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. It serves as the foundation of the firm-wide commitment to 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,
Staff is strictly prohibited from 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. Inside information is defined 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 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

The firm’s 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 anti-money laundering, anti-fraud and risk-awareness training, and additional ad-hoc trainings are held 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 made by the company.

Information Disclosure and Business Continuity Policies

Appropriate management of information is essential for EFG Hermes to maintain 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 institutionalized 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

The firm is 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 "public” areas of EFG Hermes. The Chinese Wall policy prohibits anyone in an insider area from communicating inside information to anyone in a 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 on a strictly need-to-know basis to limit any risk of the spread of insider information.

Anti-Money Laundering Policy

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. Having this information also protects us against fraud and enables us to recognize suspicious activity. Our Anti-Money Laundering Policy is based upon strict adherence to the following procedures:

  • Verification of the identity of new clients
  • Receipt and payment of funds directly to / from clients (not from third parties)
  • Reporting suspicious transactions using a specific system
  • Maintaining complete and accurate records educating and training all employees on the AML manual and regularly sharing updates

Due Diligence Processes

The firm’s stringent due diligence processes, which apply 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.

Due diligence processes are implemented across all business lines at EFG Hermes to ensure that its 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 sanction lists like the Office of Foreign Asset Control 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.

Anti-Fraud and Corruption Policy

EFG Hermes aims to conduct its business with honesty and integrity, and strives to promote an organizational culture that endorses ethical conduct, conforms to best practices and treats all employees, suppliers and the community with respect and takes into consideration their interests when doing business. Fraud and corruption adversely affect all of EFG Hermes stakeholders, including employees, Shareholders and the clients. This policy aims to educate EFG Hermes employees on fraud and corruption, set the framework for fraud prevention and anti- corruption actions and define each employee’s role in fighting any potential fraud and corruption within EFG Hermes. This policy applies to all employees irrespective of their position with the firm, and should be read in conjunction with the EFG Hermes Code of Conduct. Compliance with this policy is mandatory and non-compliance may lead to disciplinary action including dismissal. Read more...

EFG Hermes Group Sanctions Policy Statement

The EFG –Hermes Group (“EFG” or “Group”) is committed to complying with relevant sanctions restrictions or prohibitions imposed by laws and regulations which target economic, diplomatic, financial and trade activities with specific countries, governments, entities, organisations or individuals in all jurisdictions in which it operates through identifying, mitigating and managing the risk. Read more...

EFG Hermes Proxy Voting Policy

The EFG –Hermes Group (“EFG” or “Group”) recognises its fiduciary obligation to act in the best interests of all clients. One way EFG represents its clients in matters of corporate governance is through the proxy voting process. Read more...

EFG Hermes Supplier Code of Conduct

EFG Hermes is a signatory of the United Nations Principles for Responsible Investment. In our efforts to become a sustainable company, EFG Hermes’ Supplier Code of Conduct (“Code”) requires its suppliers to uphold the principles listed herein and with all applicable laws and regulations regarding labor and human rights, health and safety, Climate Change and ethics practices wherever they make products or perform services for EFG Hermes. Read more...

ESG Policy

EFG Hermes believes that integrating ESG considerations into its investment processes enhances business and financial performance over the medium and long-term. It assists investment professionals in reducing exposure to non-financial risks, and therefore enhancing risk-adjusted returns. Read more...

Health and Safety at EFG Hermes

Wellbeing is one of the essential beliefs of EFG Hermes. Having this commitment in mind, the firm establishes this corporate health and safety policy. EFG Hermes believes that health and safety of our employees, visitors and customers is essential to our sustainable success. The Group’s commitment to the effective implementation of its Health and Safety Policy and related management systems will help the Group create a healthy and safe work environment. Read more...

EFG Hermes' Statement On Human & Labour Rights

EFG Hermes complies with the UN Guiding Principles on Business & Human Rights, acknowledges its corporate responsibility towards the principles articulated within the framework and ensures the principles are captured in all its policies and rules governing employees at EFG Hermes. Read more...

EFG Hermes Statement on Modern Slavery and Human Trafficking

EFG Hermes recognizes its responsibility to support the protection and advancement of human rights and to ensure that modern slavery and human trafficking and their associated outcomes, such as the laundering of illicit gains, do not take place within our sphere of influence. EFG Hermes has been a participant in the United Nations Global Compact (UNGC) since 2011 and became a signatory of the United Nations Principles for Responsible Investment (PRI) in 2018. EFG Hermes’ goal is to uphold the UNGC principles on human rights by engaging with stakeholders and committing to policies that minimize risk on human rights issues and improve living standards in the communities where it operates. Key areas of engagement are as follows. Read more...

EFG Hermes Statement on Climate Change

Climate change is perhaps the most significant threat facing our planet today. It poses severe threats to food security, coastal and rural communities, and economies as a whole. Nowhere is this more apparent than in Egypt, where the Nile Delta—the country’s fertile breadbasket—is facing water scarcity, increased soil salinity and rising sea levels. Economic sectors across the country, from agriculture and fishing to tourism and manufacturing, are all being forced to adjust to dwindling resources and harsh new realities. Not to mention the toll on human health and wellbeing. Read more...

EFG Hermes Statement on Child Labour

Workforce Commitment

EFG Hermes does not tolerate child labour. The firm employs individuals recognized as adults by the law and on a purely voluntary basis. EFG Hermes believes that children should be in school, not at work; no child should be deprived of a childhood, safety, health or education. Read more...

EFG Hermes Statement on Gender Equality and Gender Equity

EFG Hermes is an equal opportunity employer. We value diversity in all its forms and work hard to incorporate conscious gender equality in how we operate. We pride ourselves on providing clear career paths and a supportive, equitable environment for women at all levels throughout the Group. From training opportunities to mentorship and inclusive policies, we create, grow and maintain a welcoming working environment where women can grow and thrive. Read more...

EFG Hermes Statement on Sexual Harassment

EFG Hermes is committed to providing a safe environment for all its employees free from discrimination on any grounds and from all types of harassment, including sexual harassment. Read more...