UIB Holdings (UK) Limited

Section 172 statement

The group’s success rests on the contributions of its directors, officers and employees, who develop and implement plans and actions to achieve the goals set by the group from time to time.  In doing so, the group’s directors, officers and employees are required at all times to respect national and international laws and observe the highest standards of integrity in the conduct of the group’s business.

The group’s Board will always act in an ethically correct way.

The group seeks always to comply with the law in all places where it is present or transacts business.  The group has a zero tolerance policy towards corrupt behaviour of any kind, bribery, economic and financial crime of all kinds and fraud (including tax evasion) in any shape or form, and in particular no one connected with the group may offer or accept bribes, or be involved in, or facilitate, tax evasion.

The group makes full, fair, accurate, timely, and understandable disclosure in reports and documents filed with regulators and all other public authorities throughout the world, as well as in all other public communications.

The group views transparency as an essential element of its relationship with stakeholders, and accordingly the group is strongly committed to the production and retention of truthful, accurate and complete information.

The group’s first and foremost concern are its clients.  Clients are the focus of everything that the group does.  The client’s interests always come first.

The group responds to ever changing client needs and requirements with speed and care, and to that end it has drawn up a Client Service Charter (which is available on the web site) which sets out the minimum client service level to which the group aspires.

The group bases all commercial decisions exclusively on commercial criteria.  The group directors, officers, and employees providing or receiving third party gifts and entertainment when representing the group are expected to exercise good judgement in each case, taking into account pertinent circumstances.  All expenditure for gifts and entertainment provided by the group must be promptly, fully, and fairly recorded in its books and records.

The group’s directors, officers, and employees must avoid any actual or apparent conflict between their own personal interests and the interests of the group.  The group itself has systems and controls in place to help avoid and deal with any conflict between the interests of the group and any of its clients, and also as between the interests of multiple group clients should they conflict.

The group complies with applicable national and international laws, rules and regulations to prevent, detect and report money laundering and to ensure that it is not involved in financing terrorism, and the group has processes in place to apply all sanctions rules that apply to it (including when they are linked to deterring terrorist financing).

The group and its directors, officers, and employees must comply at all times with the antitrust and competition laws of each country or group of countries which are applicable to its businesses.

The group and its directors, officers, and employees must observe all laws and regulations for the protection of client and personal data applicable to its businesses.

The group seeks to attract, develop and retain a diverse workforce by providing an inclusive and supportive working environment, and guarantees each employee equal opportunities to develop without discrimination in all aspects of the employment relationship, including recruitment, hiring, work assignment, work-time allocation, working conditions, training, professional development, promotion, transfer, dismissal, wage and salary administration, and selection for training. The group seeks at all times to treat employees fairly and consistently.

The group has a policy of zero toleration of any kind of direct or indirect discrimination, including because of race or ethnic origin, gender, beliefs (including religion), politics, sexual orientation, age or disability.

The group prohibits all forms of harassment in its workplace, including any form of harassment by or towards employees, clients, suppliers and visitors.

The group has a zero tolerance towards modern slavery and human trafficking, and expects its employees, and those it deals with, to uphold its high values.

The group is fully committed to ensuring that there is no modern slavery or human trafficking in its supply chains, and that everyone’s fundamental rights are respected.

The group respects the privacy of the individuals it deals with, in particular that of its employees (but also clients and others), and has procedures in place to comply with all applicable privacy, confidentiality and data protection laws relating to the protection of personal data.

Where an individual discovers information which he or she believes shows serious malpractice or wrongdoing within the group, it is the group’s policy that that information should be disclosed internally without fear of reprisal.

The group does not permit alcohol to be consumed on its premises, except for the purposes of entertaining its business partners in the designated hospitality areas or staff parties which have been pre-authorised by senior management.  The misuse of legitimate drugs, or the use, possession, distribution or sale of illicit or unprescribed controlled drugs on the group’s business or premises, is strictly prohibited.

The group strives at all times to provide all employees, and all others who visit its premises – including third parties who may work with the group – with a secure work environment and to secure its assets from improper interference or use

The group restricts directors, officers and employees from holding office in non-affiliated, for-profit organisations, and prohibits any director, officer or employee from accepting any such office which would, or might, involve a conflict of interest with, or interfere with, the discharge of the director’s, officer’s or employee’s duties to the group.

The group requires its directors, officers, and employees to protect its tangible and intangible assets and use them efficiently to advance its interests.

The group’s directors, officers, and employees are required to respect the ownership rights, and intellectual property rights, of third parties.