BRIBERY & CORRUPTION

UK Bribery Act 2010

SMBC Group is committed to preventing bribery and corruption and to consistently applying the letter and spirit of applicable anti-bribery legislation in all markets and jurisdictions in which it operates. This includes, but is not limited to, full compliance with the Bribery Act 2010 of the United Kingdom, in accordance with the bank’s commitment to truth and fair dealing and the highest standards of business integrity.

PDF Statement of anti-bribery principles (SMBCE)

Foreign Exchange & Treasury

Foreign exchange

Foreign exchange (FX) currency remittance rates are published at the start of each business day for customers to determine the conversion rate applied for low value remittances.

Wholesale FX

The wholesale FX disclosure sets out the main terms of SMBC Group for FX dealing with its customers and other market participants in principal-to-principal transactions, whether by voice or electronic means, in the wholesale FX markets with respect to FX spot, options, swaps and deliverable and non-deliverable forwards.

PDF Wholesale FX disclosure

FX Global Code

SMBCE acknowledges that the FX Global Code represents a set of principles generally recognised as good practice in the wholesale foreign exchange market. As a market participant, SMBCE is committed to conducting its activities in a manner consistent with the principles of the code.

PDF Full statement of commitment to the FX Global Code (SMBCE)

UK Money Markets Code

The United Kingdom Money Markets Code represents a set of principles generally recognised as good market practice in the UK money markets. As a market participant, SMBCE is committed to conducting its activities in a manner consistent with the principles of the code.

PDF Full statement of commitment to the UK Money Markets Code (SMBCE)

GENDER PAY GAP

PDF Gender pay gap report (SMBCE – 2018)

PDF Gender pay gap report (SMBCE – 2017)

SMBC Group is an equal opportunites employer. See diversity and inclusion for more information.

INACTIVE ACCOUNTS

French Eckert law

Disclosure of inactive bank accounts in relation to French law number 2014-617 of 13 June 2014, known as Eckert law.

En français (in French)

PDF Publication des comptes inactifs (SMBCE Paris – 31 décembre 2017)

Intragroup market exemption

European Market Infrastructure Regulation

SMBC Group has submitted applications to the relevant European Union regulators in respect of the exemption from margin requirements for intragroup transactions under Article 11 of European Market Infrastructure Regulation (EMIR) and Commission Delegated Regulation (EU) 2016/2251 supplementing EMIR with regard to regulatory technical standards on risk mitigation techniques for over-the-counter (OTC) derivative contracts not cleared by a central counterparty. The exemptions apply to initial and variation margin requirements.

PDF Intragroup market exemption (SMBCE)

PDF Intragroup market exemption (SMBC EU)

MONEY LAUNDERING

Wolfsberg questionnaire

The Wolfsberg Group is an association of 13 global banks which aims to develop frameworks and guidance for the management of financial crime risks. The Wolfsberg questionnaire has been developed in order to assist firms conducting due diligence, allowing them to assess the financial crime risk consistently across the financial industry. In line with industry best practice, SMBC EU has completed the questionnaire as an aid to the due diligence process.

PDF Wolfsberg questionnaire (SMBC EU)

SLAVERY & HUMAN TRAFFICKING

UK Modern Slavery Act 2015

The Modern Slavery Act 2015 of the United Kingdom requires certain businesses to provide disclosure concerning their efforts to address the issues of slavery and human trafficking in their supply chain. The disclosure is intended to assist customers with the ability to make better, more informed choices about the products and services they buy and the companies they support.

Slavery and human trafficking refers to a variety of offences, including but not limited to:

  • Slavery, servitude and forced or compulsory labour
  • Sexual exploitation, including all offences contemplated in Part 1 of the UK Sexual Offences Act 2003
  • Removal and trafficking of organs outside the context of authorised health treatments
  • Securing services or other type of benefits by force, threats or deception
  • Securing services or other type of benefits from children and vulnerable persons.

SMBCE's stance on slavery and human trafficking

SMBCE continues its commitment to maintaining and improving systems and processes to mitigate the risk that it might be involved, wittingly or unwittingly, in the commission of slavery and human trafficking in any part of its operations, supply chain (including customers, contractors and suppliers), products, services and staff activities. SMBCE also expects its staff, suppliers and business partners to adhere to the same high standards and to take reasonable steps to ensure that other third parties they do business with adhere to those standards as well.

Governance

Appropriate anti-slavery and human trafficking policy and procedures have been introduced within SMBCE. These provide detailed guidance to SMBCE staff on what constitutes an offence and the controls in place to mitigate the risk that SMBCE may be directly or indirectly involved in the commission of slavery and human trafficking.

Supply chain

SMBCE takes appropriate steps to verify, evaluate and mitigate the risk that slavery and human trafficking may occur in its supply chain. In particular, SMBCE performs due diligence on suppliers and contractors at the start of a business relationship and subsequently on a periodic basis. This due diligence process includes, but is not limited to, an analysis of the activity carried out by the suppliers and contractors and a detailed review of publicly available information, in order to identify instances that may give SMBCE cause for concern.

Customers

SMBCE takes appropriate steps to verify, evaluate and mitigate the risk that its products and services may be used by a customer for the commission of slavery and human trafficking. SMBCE conducts a series of checks on its customers, including, but not limited to, an analysis of the activity carried out by the customers and a detailed review of publicly available information,in order to identify instances that may give SMBCE cause for concern in relation to slavery and human trafficking. As part of its onboarding and periodic customer due diligence processes, all customers are assessed to determine if they fall within the scope of the act, and if so, a copy of their anti-slavery statement is sought and retained. Furthermore, in relation to trade finance, all transactions are subject to checks to ascertain that the goods and country of origin are not prohibited under the SMBCE anti-slavery and human trafficking policy.

Staff

In order to ensure proper understanding of the risks posed by slavery and human trafficking in the context of SMBCE’s supply chains and business, SMBCE staff have received training on slavery and human trafficking and the requirements of the act. Members of staff are encouraged to report any instances of suspected slavery and human trafficking identified in any part of SMBCE’s business activities, either through their standard reporting line, or through the SMBCE whistleblowing programme.

Statements

PDF Full statement on slavery and human trafficking (SMBCE – 2018)

PDF Full statement on slavery and human trafficking (SMBCE – 2017)

PDF Full statement on slavery and human trafficking (SMBCE – 2016)

Questions, comments and requests are welcome

For further information regarding slavery and human trafficking, please contact SMBCEMSA@gb.smbcgroup.com

UNITED KINGDOM TAX STRATEGY

UK Finance Act 2016 Schedule 19

The British government introduced legislation in 2016 which requires large businesses operating in the United Kingdom to publish their tax strategy. The tax affairs of SMBC Group in the UK are managed in a manner that is consistent with the bank’s philosophy on corporate social responsibility.

PDF United Kingdom tax strategy

UNITED STATES FOREIGN BANK CERTIFICATION

USA Patriot Act 2001

The information contained in this certification is sought pursuant to sections 5318(j)(k) of title 31 of the United States code, as added by sections 313 and 319(b) of the USA Patriot Act 2001 (public law 107-56).

PDF Patriot Act Certification (SMBC EU)