Anti-Bribery and Corruption Statement

Corruption contributes to economic under-performance, undermines democracy and leads to violations of human rights. BNP Paribas UK and its Senior Management has, and continues to adopt, a zero tolerance attitude towards bribery and corruption in whatever form, circumstance or manner it may occur within and (or) outside the United Kingdom.

BNP Paribas UK will uphold all laws relevant to countering bribery and corruption in all jurisdictions and sectors in which we operate. BNP Paribas will decline to enter into any business relationship if it considers that to do so might expose it to any activity, which might be corrupt, fraudulent or otherwise illegal.

BNP Paribas UK has in place rigorous procedures and robust systems and controls designed to detect and prevent financial crime, including bribery and corruption. Its staff are trained to identify and evaluate financial crime risks and such risks are routinely considered in deciding whether to enter into business relationships and transactions.

BNP Paribas UK operates to the highest standards of honesty and integrity and expects its clients, business partners and Third Parties to observe the same standards in all business dealings with BNP Paribas.

Particular care is taken when dealing with (a) public officials, (b) intermediaries such as introducers, distributors and brokers and (c) suppliers of goods and services. Where the relationship poses an increased risk BNP Paribas may wish to understand the adequacy of the anti-bribery procedures and controls of its counterparties.

BNP Paribas also carries out detailed due diligence on both clients and transactions. Due diligence includes bribery and money laundering checks.

Gift and Entertainment

BNP Paribas UK accepts normal and appropriate gesture of gift and/or entertainment (whether given or received) as long as they are not considered excessive or intended to influence the outcome of any business transaction or arrangement.

Facilitation Payments

BNP Paribas UK does not accept and will not make any form of facilitation payments of any nature. BNP Paribas UK recognise that facilitation payments are a form of bribery that involves expediting the performance of a public official to secure the performance of a governmental action.

Reporting

If you are aware of any BNP Paribas UK related non-compliance with this statement or applicable bribery and corruption laws and regulations, you can report it to our Compliance team – sars@uk.bnpparibas.com