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Should hospitality be received which after the event is valued at over £200 or more than
20% higher than the sum originally anticipated and approved, retrospective approval
should be obtained and documented.
You should actively, but sensitively, discourage customers and other third parties from
offering any gifts / hospitality / other personal benefits of any kind.
Additionally, you must conduct yourself in such a way as to avoid potentially
embarrassing situations and reduce the chances of incurring a presumption of
indebtedness.
You should actively, but sensitively, discourage customers, clients or suppliers from
offering personal benefits of any kind (including all types of gifts, favours, services,
loans or fees, or anything of monetary value).
3.6.2 Employees working for HBIB or for HSBC Bank Plc on the Offshore Islands
3.6.2.1 Gifts
You do not have to report gifts of promotional items (pens, paperweights etc), gifts of
up to £25 in value or ordinary business dinners and lunches.
You must not accept gifts over £150 in value and must report any gifts worth between
£25 and £150 to your line manager.
You cannot accept any gift, bequest or inducement from any person which is likely to
influence (or which other people may think likely to influence) your judgement and
similarly you cannot make gifts etc which would influence anyone else.
Invitations to parties, functions and events count as gifts. You should not accept such
invitations if you are receiving more than £150 in value (i.e. that is what you would
have to pay to go). Travel costs to and from the UK or between the Offshore Islands
may be disregarded.
Approval to accept items exceeding the limits may be given by senior management
(CEO or Deputy CEO) but this would be exceptional.
You are referred to the Compliance Officer Handbook for further details on the bank’s
policy in relation to bribery and corruption.
3.6.2.2 Inducements / Third Party Incentive Payments
From time to time product providers (referred to here as the “Third Party Company”)
whose products the bank distribute offer amounts of money or other non-monetary
incentives (referred to here as “incentives”) over and above what is paid to the bank in
the normal course of doing business together. This could include, but is not limited to,
making a direct payment to HBIB / HSBC Bank plc or subsidising or meeting the cost
of events and conferences at which HBIB / HSBC Bank plc employees attend.
For clarity, the term “Third Party” is deemed to refer to non-HSBC Group members.
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