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2 Failure to adopt policies consistent with the Group Standards Manual. 3 Fraud or deliberate error in the preparation, evaluation, review or audit of any financial statement. 4 Fraud or deliberate error in the recording and maintaining of financial records of any Group company. 5 Deficiencies in or non-compliance with any Group company’s internal accounting controls. 6 Deviation from full and fair reporting of any Group company’s financial condition. 7 Misrepresentation or false statement to or by a Group Executive Officer or Accountant regarding a matter contained in the financial reports or audit of any Group company. You can make a protected disclosure by reporting the matter to your line manager or Human Resources. However, any disclosures falling within categories 2-7 must, due to our legal obligations, be reported to Group Compliance. If you feel unable to raise the matter with your line manager, or Human Resources, for whatever reason, you should call the Group Compliance telephone 'hotline' on 799 12155 (Internal) or 020 7991 2155 (External). Alternatively, you may send an e-mail to: compliancedisclosureline@hsbc.com or make a protected disclosure in writing, to the Head of Group Compliance, HSBC Holdings plc, Level 42, 8 Canada Square, London, E14 5HQ. However, if your concern relates to your personal position, rather than a concern about malpractice, it will normally be more appropriate for you to use the bank’s grievance procedure, which is set out in the HR Procedures Manual (Grievance Procedure) and can be accessed through the bank’s intranet. Full details of the ‘Whistleblowing’ procedure, along with the HSBC Group’s general policy on disclosure, are contained in the HR Procedures Manual. 3.10 Data Protection 3.10.1 Personal Data and Sensitive Personal Data The type of personal data that we hold will include information relating to payroll processing, references, family and other contact details and records (including, for example, job applications, and when relevant, details of any grievance and disciplinary procedures) relating to your recruitment and career with us. Information may also be disclosed to and from other members of the HSBC Group for payroll and administrative purposes, for purposes connected with your career, and for audit requirements. 50
We will only collect and process data in a fair and lawful manner. Sensitive personal data will only be processed with your agreement, unless required to meet statutory obligations. The types of sensitive data we hold about you may comprise of: (i) Information about your health, which would be used to ensure compliance: • with health and safety and occupational health obligations; • when considering any health issues that may affect your ability to work; • if you are disabled; • should you require time off work or special arrangements to look after a family member or friend, we may keep a record of such absences; • for administration and management of insurance, pension, sick pay and other similar benefits. (ii) Recording racial or ethnic origin or religious beliefs. This data is held to fulfil our statutory obligations to ensure equality of opportunity at work. (iii) Information for security, fraud prevention, and regulatory purposes. We may in the course of your recruitment and periodically during your career undertake appropriate security and credit reference checks. In some instances we may be required by law to provide certain information to a third party, such as the HM Revenue & Customs, governmental or non-governmental regulatory bodies or the Offshore equivalents. Information may also be exchanged with other members of the HSBC Group for purposes connected with your career, and for audit requirements. Information may also be processed on our behalf by members of the HSBC Group, and/or third parties. However, whether or not such information is processed outside the European Economic Area (where there may be less stringent data protection laws) it will be protected by a strict code of secrecy and security and will only be used in accordance with our instructions. If your (sensitive) personal data is transferred or held overseas, we will ensure your rights as an individual are protected. In order to give you information about products and services we provide together with products supplied by selected third parties, we may use, analyse and assess information that is held about you. We may pass information to other members of the HSBC Group and such selected third parties so that they may do the same, but your name and address will not be disclosed for marketing purposes unless you have given your consent. Under Data Protection legislation, you can ask in writing for a copy of certain personal records we currently hold about you. A charge of £10 will be made. 3.10.2 Employees' Responsibilities The relevant data protection legislation is the Data Protection Act 1998 (UK), the Data Protection Act 2002 (Isle of Man), the Data Protection (Jersey) Law 2005 and the Data Protection (Bailiwick of Guernsey) Law 2001. Under the data protection legislation, all employees have a responsibility to ensure that their own personal data is accurate, upto-date and kept secure. Unauthorised disclosure of third party personal data is a serious offence and can result in prosecution. Therefore you must ensure that you: 51
Page 1 and 2: Dear Colleague Welcome to HSBC Bank
Page 3 and 4: Section 6 - Security of Employment
Page 5 and 6: Clerical employees Previous Grade S
Page 7 and 8: details on this are set out in the
Page 9 and 10: In the event that the overpayment i
Page 11 and 12: Guernsey GY1 3AZ Tel: 01481 724711
Page 13 and 14: The parameters set out above apply
Page 15 and 16: (ii) Management and Salesforce Grad
Page 17 and 18: If your working arrangements includ
Page 19 and 20: You may be asked to give your conse
Page 21 and 22: *** Calculation of maximum period o
Page 23 and 24: 1.10 Cars 1.10.1 Management Car Sch
Page 25 and 26: The pension benefits detailed in th
Page 27 and 28: egarding the handling of informatio
Page 29 and 30: Notice periods applicable when the
Page 31 and 32: or suppliers and you must not retai
Page 33 and 34: about this and the steps that follo
Page 35 and 36: 2. CODE OF BUSINESS ETHICS AND RESP
Page 37 and 38: • Observing the spirit and letter
Page 39 and 40: 3. RULES AND REGULATIONS Whilst the
Page 41 and 42: Permission will not be granted for
Page 43 and 44: The following points must be consid
Page 45 and 46: You are referred to Compliance Guid
Page 47 and 48: activities can be found on the bank
Page 49: • care should be taken to verify
Page 53 and 54: • take photographs or video image
Page 55 and 56: • ensure each employee accepts he
Page 57 and 58: 4. BENEFITS AND FACILITIES You may
Page 59 and 60: 4.1.7 Mortgage Subsidy Scheme The M
Page 61 and 62: 4.2.4.3 The HSBC Childcare Scheme a
Page 63 and 64: information resources and a key par
Page 65 and 66: • for HIUL employees childcare fa

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