July 8, 2021

We would like to inform you that the BNP Paribas Group’s Anti-bribery and Corruption Policy has been recently updated. In this communication we present the updated policy along with the other policies for your easy reference. It always helps to have the golden rules of professional ethics handy.

Sharekhan has an established set of codes of professional ethics to help guide its staff in performing their functions according to sound and consistent ethical principles. These are the policies and procedures, some of them derived from the BNP Paribas Group’s policies and procedures like the Anti-bribery and Corruption Policy, that govern the behaviour of all Sherus.

Updated Anti-bribery and Corruption Policy of the BNP Paribas Group
To maintain the highest level of ethical standards, BNP Paribas adopts a complete zero-tolerance policy to any bribery, corruption or related unethical issues. As such, we would like to draw your attention to the overseas anti-bribery and corruption laws, code of conduct on fighting corruption, Sharekhan’s gifts and invitations and whistleblowing policies and procedures. BNP Paribas complies with the law relating to transparency, anti-corruption and the modernisation of the economy (“Sapin II”), with the UK Bribery Act and with the US Foreign Corrupt Practices Act.

The French law for fighting against corruption, namely “Sapin II”, was published in late 2016. The law has an extraterritorial reach which obliges large corporates, like BNP Paribas and their representatives, to put in place a framework for preventing and detecting corruption. French Anti-Corruption Agency is empowered to penalise individuals and the bank if non-compliance is detected. Group Compliance enhanced and updated the Global Anti-Corruption Policy (CPL0183EN) in February 2021 in connection with the 8 pillars of Sapin II law and its impact and procedures on BNP Paribas.

Updates on 8 pillars of Sapin II law
Pillar 1: Code of Conduct, Gifts and Invitations and Conflict of Interest
Pillar 2: Whistleblowing
Pillar 3: Risk Mapping
Pillar 4: Procedures to assess Third Parties (KYC/KYI/KYS)
Pillar 5: Accounting Control Procedure
Pillar 6: Training & Communication Process
Pillar 7: Disciplinary Regime
Pillar 8: Internal Control mechanism
Please review the updated Global Anti-Corruption Policy and related guidelines by clicking the below links:

CPL0183EN - Global Anti-Corruption Policy (Updated Version)
French Anti Corruption Agency Guidelines 2021
Sapin II Law Basic 1
Sapin II Law Basic 2
Sapin II Law Basic 3

Group Code of Conduct with the ABC Addendum
Employees must not, directly or indirectly, give, promise, offer, ask for or accept from any individual or third party, any advantage in return for an actual or alleged favour or influence. Any attempt to perpetrate such acts is likewise strictly forbidden. Sharekhan’s product or services must not be offered or provided under such circumstances.

• Comply with the Gifts & Invitations Policy
• No facilitation and other cash payments allowed
• Data Confidentiality
• Conflicts of Interest

For details refer the Group Code of Conduct with ABC Addendum

Gifts and Invitations Policy
The Gifts and Invitations Policy is a critical component of the compliance device for fighting corruption. This procedure aims to make the employees aware of their own responsibilities in a field where non-compliant behaviours could expose them to legal and highly challenging reputational risks. It describes the conditions under which the received or offered gifts and invitations can be accepted, authorised or refused:

• Gifts and invitations in any form offered to/received from regulators, government authorities, holders of public function etc are prohibited unless specifically approved by the Business Head and the responsible Compliance Officer.
• No gift or invitation exceeding Rs.3,000 can be given/received to/from clients unless approved by the Function Head and the responsible Compliance Officer.
• Offering/Receiving cash or cash equivalent gifts to/from clients is strictly prohibited.
• It is strictly prohibited to give/solicit any gift in the broadest sense to/from any client, supplier intermediary or tied agent.
• In addition, the frequency of entertainment invitations shall comply with the Group Policy of four times a year (ie over four times per person per year requires pre-approval).

Refer to the Gifts and Invitation Policy for details of the gifts and invitations approval requirements and relevant restrictions.

Whistleblowing Procedure
Due to recent regulatory developments in France (ie Sapin II, Duty of Vigilance Law, MAD-MAR, MiFID 2 and GDPR), a revised Group Whistleblowing Procedure and updated Sharekhan Whistleblowing Level 3 Procedure have been released. This policy is effective from July 10, 2018. Link: CPL0038EN

Significant changes in the Whistleblowing Policy

• All whistleblowing cases will be handled with utmost care and confidentiality of all information collected in connection with a reported case will be guaranteed.
• Information will only be disclosed on a “need to know” basis with the objective to perform investigations. All staff involved in the initial review and investigation are committed to confidentiality and required to sign a “Confidentiality Charter”.

The scope of reporting can include but is not limited to the following alleged situations:

• acts of corruption and influence peddling;
• acts of fraud;
• inappropriate behaviour or lack of respect for persons, diversity and equal opportunity;
• infringement of the rules of professional ethics, financial security, market integrity, protection of interest of clients;
• anti-competitive practices;
• unauthorised communication of confidential information;
• breaches potentially constituting a crime or an offence;
• violation of law and regulation, international norm, etc;
• violation of internal policy or procedures; and
• violation of the Group Code of Conduct.

You may use any of the below channels for whistleblowing:

Find details of the procedure here: Sharekhan-L3 Whistleblowing Instruction

Note the process flow for reporting a concern

Contact the Compliance EIT Team in case you have any questions related to the procedure.

Best Regards
Team Compliance