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Dear Colleague Welcome to HSBC Bank - HSBC careers site

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The acceptance of incentives must be unconditional although it is permitted <strong>to</strong> earmark<br />

money <strong>to</strong> meet the wishes of the Third Party Company, provided such wishes do not<br />

infringe any of the rules set out here. For example, a Third Party Company may wish an<br />

incentive payment <strong>to</strong> be used for training purposes. Any divergence from this must be<br />

discussed with the Third Party Company and only used with its agreement. If<br />

agreement cannot be reached then the money must be returned <strong>to</strong> the Third Party<br />

Company or used as originally intended.<br />

Incentives can only be accepted from a Third Party Company who appear either on the<br />

Best of Breed list or are a recognized <strong>HSBC</strong> supplier.<br />

Consideration must always be given <strong>to</strong> the reputational risk of being associated with the<br />

Third Party Company who provide such incentives.<br />

The acceptance of such incentive must be approved by the CEO or Deputy CEO in the<br />

CEO’s absence.<br />

Any exceptional request <strong>to</strong> operate outside of any of the guidelines contained here must<br />

be agreed by the Area Compliance Officer and approved by the CEO (or Deputy CEO<br />

in his / her absence) in writing prior <strong>to</strong> acceptance.<br />

Branding/ naming of inducements may not be made by the Third Party Company<br />

except where it is part of an incentive programme with many Third Party Companies<br />

where parts of the programme may be sub-branded.<br />

Special rules applicable <strong>to</strong> employee incentives<br />

Third Party Companies are not permitted <strong>to</strong> directly incentivise HBIB / <strong>HSBC</strong> <strong>Bank</strong> plc<br />

employees, they may however fund an incentive provided by HBIB / <strong>HSBC</strong> <strong>Bank</strong> plc.<br />

Third Party Company funded incentives should not be awarded for production or sales<br />

performance related solely <strong>to</strong> the Third Party Company. The only exception <strong>to</strong> this is<br />

where we have exclusivity arrangements with a company. Great care however must be<br />

taken <strong>to</strong> ensure that any such incentive does not undermine existing HBIB / <strong>HSBC</strong><br />

<strong>Bank</strong> plc incentive schemes and targeting arrangements by encouraging employees <strong>to</strong><br />

focus on one single product type such as insurance sales.<br />

In all cases our established rules, designed <strong>to</strong> avoid the creation of product or product<br />

provider bias, apply. It is important <strong>to</strong> stress that qualification for any award so funded,<br />

is <strong>to</strong> be determined solely by HBIB / <strong>HSBC</strong> <strong>Bank</strong> plc and will only be ratified once<br />

confirmation is received that there is no evidence of inappropriate behaviour.<br />

Gifted money should not be earmarked for individual or specific rewards, for example,<br />

the cost of sending the <strong>to</strong>p performer on a holiday, or “the XYZ Company prize for the<br />

most improved sales person” etc. Any funding received should be included in the<br />

overall “incentive pot” which is then used <strong>to</strong> fund incentives determined by HBIB /<br />

<strong>HSBC</strong> <strong>Bank</strong> plc.<br />

44

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