Quintet Private Bank (Europe) S.A Anti-Corruption and Bribery Policy
Introduction
This document outlines the Quintet Private Bank (Europe) S.A stance on corruption, bribery, and related practices. The policy provides a framework for preventing and addressing these issues within the organization.
Definition of Key Terms
- Corruption: A system based on dishonesty and illegal behavior by people in positions of authority or power.
- Bribery: Paying money or giving a benefit to someone in order to obtain commercial, administrative, or political advantage.
- Gifts: Benefits offered or received from external persons without consideration or value in return.
- Corporate Hospitality: The invitation or participation to any event, such as meals, drinks, visits, tickets, private journeys, travels, or accommodation.
- Facilitation Payments: Small payments made to facilitate routine government action to which the payer is already legally or otherwise entitled.
Key Principles
The Quintet Private Bank (Europe) S.A Anti-Corruption and Bribery Policy is based on the following key principles:
- Zero Tolerance for Corruption and Bribery: The bank has a zero-tolerance policy towards corruption and bribery.
- Prevention of Corruption and Bribery: The bank will implement measures to prevent corruption and bribery, such as training employees on anti-corruption policies and procedures.
- Detection and Reporting of Corruption and Bribery: Employees are encouraged to report any suspected cases of corruption or bribery to the Compliance department.
- Investigation and Discipline: Any reports of corruption or bribery will be thoroughly investigated, and disciplinary action will be taken against anyone found guilty.
Guidelines for Employees
The following guidelines are provided for employees on how to handle gifts, corporate hospitality, and facilitation payments:
- Gifts:
- Gifts should not be offered or accepted without prior approval from the Compliance department.
- Gifts should not be excessive or have a value that could be seen as an attempt to influence a decision.
- Corporate Hospitality:
- Corporate hospitality events should be organized in accordance with the bank’s policies and procedures.
- Employees should not accept invitations to corporate hospitality events unless they are necessary for business purposes.
- Facilitation Payments:
- Facilitation payments should only be made in accordance with the bank’s policies and procedures.
- Employees should keep records of facilitation payments, including the purpose and amount.
Reporting Suspected Cases
Employees are encouraged to report any suspected cases of corruption or bribery to the Compliance department. Reports can be made anonymously, but it is recommended that employees provide their contact information so that they can be contacted for further information.
Conclusion
The Quintet Private Bank (Europe) S.A Anti-Corruption and Bribery Policy demonstrates the bank’s commitment to maintaining high standards of integrity and preventing corruption and bribery. The policy provides a framework for preventing and addressing these issues within the organization, and it is essential that all employees understand their role in upholding this policy.