CORPORATE DISCLOSURES

BRIBERY & CORRUPTION

UK Bribery Act 2010

SMBC Group is committed to preventing bribery and corruption in accordance with applicable anti-bribery legislation in all markets and jurisdictions in which it operates. This includes, but is not limited to, full compliance with the UK Bribery Act 2010. The SMBC BI, SMBC DP and SMBC Nikko statement of anti-bribery principles sets out the requirements for employees and third parties in relation to bribery and corruption and ethical conduct. 

^PDF Statement of anti-bribery principles (SMBC BI, SMBC DP and SMBC Nikko)

GENDER PAY

^PDF Gender pay report (SMBC Group London – 2023)

^PDF Gender pay report (SMBC Group Paris – 2023)

^PDF Gender pay report (SMBC Group London – 2022)

^PDF Gender pay report (SMBC Group Paris – 2022)

^PDF Gender pay report (SMBC BI London – 2021)

^PDF Gender pay report (SMBC BI Paris – 2021)

^PDF Gender pay report (SMBC BI London – 2020)

^PDF Gender pay report (SMBC BI Paris – 2020)

^PDF Gender pay report (SMBC Nikko – 2020)

^PDF Gender pay report (SMBCE London – 2019)

^PDF Gender pay report (SMBCE Paris – 2019)

^PDF Gender pay report (SMBC Nikko – 2019)

^PDF Gender pay report (SMBCE London – 2018)

^PDF Gender pay report (SMBCE London – 2017)

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

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)

^PDF Intragroup market exemption (SMBC Nikko)

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 BI, SMBC EU and SMBC Nikko have completed the questionnaire as an aid to the due diligence process. 

^PDF Wolfsberg questionnaire (SMBC BI)

^PDF Wolfsberg questionnaire (SMBC EU)

^PDF Wolfsberg questionnaire (SMBC Nikko)

SLAVERY & HUMAN TRAFFICKING

UK Modern Slavery Act 2015

The Modern Slavery Act 2015 ("the Act") 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.

SMBC UK entities' stance on slavery and human trafficking

SMBC BI, SMBCL and SMBC Nikko UK (collectively referred to as SMBC UK entities) support the SMBC Group Human Rights Report and Statement on Human Rights, based on the United Nations Guiding Principles on Business and Human Rights (UNGPs). As such, SMBC UK entities are committed to protecting and respecting human rights in accordance with international human rights standards.

The main principle guiding SMBC UK entities' approach to slavery and human trafficking is that they should not be involved, directly or indirectly, in the commission or facilitation of the offences specified by the act.

SMBC UK entities demonstrate an ongoing commitment to maintaining and improving systems and processes to mitigate the risk that they might be involved, wittingly or unwittingly, in the commission of slavery and human trafficking in any part of their operations, supply chain (including customers, contractors and suppliers), products, services and staff activities.

SMBC UK entities also expects their 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

SMBC UK entities' senior management are responsible for establishing a culture in which modern slavery is not tolerated in any form, ensuring that all staff are aware of the risks, so that informed decisions are made in a timely way, which mitigate and manage these risks.

SMBC UK entities have established an anti-slavery policy, which sets out the processes through which they seek reasonable assurance that none of their customers, business partners, suppliers and other third parties are involved in the commission or facilitation of slavery or human trafficking.

Risk assessment

SMBC UK entities have conducted a risk assessment of countries, industry sectors, goods and products, which have been reported to be involved in the potential commission or facilitation of slavery and human trafficking. Specifically, the assessment of goods and industry sectors has been updated in line with the UNGPs.

Due diligence

All departments involved in due diligence processes are required to conduct appropriate checks in order to obtain reasonable assurance that customers, business partners, suppliers, and other third parties are not involved in the commission or facilitation of slavery and human trafficking.

SMBC UK entities require specific anti-slavery due diligence to be undertaken on all their counterparties, and apply consistent due diligence measures for slavery and human trafficking, whereby suppliers, contractors, customers and any other business partners are all subject to the same level of identification, verification, and risk evaluation.

In addition, in the course of conducting due diligence processes, all customers, business partners, suppliers and other third parties are subject to adverse news screening, incorporating specific terms relevant to slavery and human trafficking.

Supply chain and customers

SMBC UK entities expect their suppliers and customers to undertake ethical business practices, particularly in, but not limited to, economic sectors where there are higher risks of slavery and human trafficking.

SMBC UK entities take appropriate steps to mitigate the risk that slavery and human trafficking may occur in their supply chain, or that their products and services may be used by a customer for the commission or facilitation of slavery and human trafficking.

Any instances where it is identified that the supplier, customer, or transaction may present a heightened ESG risk, or may be involved in the commission or facilitation of the relevant offences due to their core activities, line of business, business relationships, country of establishment and/or operations, will require enhanced due diligence measures, more detailed investigation, and senior management approval.

Employees

In order to ensure proper understanding of the risks posed by slavery and human trafficking in the context of SMBC UK entities' supply chains and business, training is provided to employees on slavery and human trafficking and the requirements of the Act.

Employees are encouraged to report any instances of suspected slavery and human trafficking identified in any part of SMBC UK entities' business activities. The options for raising concerns and reporting are incorporated within the 'Speak Up' framework, including internal reporting lines, and whistleblowing programme.

It is equally important for SMBC UK entities to demonstrate that no relevant offences are committed within their premises or in relation to their own employees. Human resources have the responsibility to demonstrate, through the introduction of appropriate controls, that SMBC UK entities' own employees are being treated in line with local laws and regulations, and are not victim of any of the relevant offences as a result of their employment.

Statements

^PDF Full statement on slavery and human trafficking (SMBCL – 2024)

^PDF Full statement on slavery and human trafficking (SMBC Nikko – 2024)

^PDF Full statement on slavery and human trafficking (SMBC BI – 2024)

^PDF Full statement on slavery and human trafficking (SMBC BI – 2023)

^PDF Full statement on slavery and human trafficking (SMBC Nikko – 2023)

^PDF Full statement on slavery and human trafficking (SMBCL – 2023)

^PDF Full statement on slavery and human trafficking (SMBC BI – 2022)

^PDF Full statement on slavery and human trafficking (SMBCL – 2022)

^PDF Full statement on slavery and human trafficking (SMBC Nikko – 2022)

^PDF Full statement on slavery and human trafficking (SMBC BI – 2021)

^PDF Full statement on slavery and human trafficking (SMBC Nikko – 2021)

^PDF Full statement on slavery and human trafficking (SMBC BI – 2020)

^PDF Full statement on slavery and human trafficking (SMBCE – 2020)

^PDF Full statement on slavery and human trafficking (SMBCE – 2019)

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

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

Contacts

Questions, comments and requests regarding this statement are welcomed and should be addressed to smbcbimsa@gb.smbcgroup.com

• SMBC BI smbcbimsa@gb.smbcgroup.com
• SMBCL leaseadmin@gb.smbcgroup.com
• SMBC Nikko bruce_railton@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