Subject Index A - HSBC careers site

As part of your job, you may be required to be registered as an Approved Person with
the FSA by way of a formal agreement. If so, this will require you not only to abide
by the FSA’s principles and rules but additionally to accept personal responsibility for
certain actions under the FSMA.
3.8.4 Dealing Rules - UK Employee Dealing Procedures
Personal dealing in securities by all employees is subject to specific procedures,
which may be amended from time to time, and which must be strictly observed at all
times. If you are a new employee, a copy of the guidelines to employees will be made
available to you when you commence employment, and you should read them on
receipt.
If you wish to buy or sell securities (e.g. stocks and shares, but see the procedures for
a full list of what is deemed to be a security) you must observe the UK Employee
Dealing Procedures. These set out procedures and conditions to ensure that
employees' dealings comply with the Group's policy, the Financial Services Authority
regulations and the Criminal Justice Act 1993. It is very important for you to
understand the implications of these regulations.
In particular, you should read carefully the restrictions which apply if you are in
possession of inside information. Dealing when in possession of such information,
passing such information to others or procuring others to deal while in possession of
such information are criminal offences under Part V of the Criminal Justice Act 1993.
This is a complex piece of legislation and it is essential that the advice of your line
manager is sought before dealing if you have any doubt about the transaction.
There are special rules for dealing in HSBC Group Securities which affect certain
employees.
A full copy of the UK Employee Dealing Procedures is contained in the Business
Instruction Manual which can be accessed through the HR Procedures Manual
(Dealing procedures (UK employee)).
Failure to observe the UK Employee Dealing Procedures may result in disciplinary
action, including dismissal, being taken against you. You may also be subject to
criminal prosecution.
3.8.5 Money Laundering Deterrence
You must abide by all published money laundering rules, regulations and procedures.
'Money Laundering' is the name given to the process by which the identity of illegally
obtained money is changed so that it appears to have originated from a legitimate
source. Banks and other financial institutions may be used unwittingly as
intermediaries for the transfer or deposit of funds derived from criminal activity.
Criminals and their associates use the financial system in order to hide the source and
beneficial ownership of money by making payments and transfers of funds from one
account to another, purchasing monetary instruments such as drafts and travellers
cheques and using safe-deposit facilities to provide storage for banknotes. The process
is also used in the financing of terrorism although the funds involved may not in
themselves be the proceeds of a criminal act.
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