Anti-Bribery & Corruption - Policy Document - Finastra
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Global Risk Management
Anti-Bribery &
Corruption
Policy Document
10 October 2017
© Finastra | 10 October 2017 | Title XXXXXXXXXXX 0
CONTENTS DOCUMENT CONTENT 2 INTRODUCTION 2 REQUIREMENTS 2 MONITORING / REPORTING 3 EXCEPTIONS / ESCALATIONS 3 APPROVAL / OVERSIGHT 3 RELATED RESOURCES 3 QUESTIONS 3 APPROVAL AND VERSION HISTORY 4 Finastra | 10 October 2017 | Global Risk Management | Anti-Bribery & Corruption 1
Policy: Anti-Bribery and Corruption
Document Content 1. Introduction
2. Requirements
3. Monitoring/Reporting
4. Exceptions/Escalations
5. Approval/Oversight
6. Related Resources
7. Definitions
8. Questions
9. Approval and Version History
1. Introduction The actions and conduct of Finastra employees, as well as others acting on
Finastra’s behalf, are essential to maintaining our high standards.
All Finastra employees are required to read, become familiar and comply with this
Policy, which should be read together with the Code of Conduct, the Gifts and
Entertainment Policy, and the Selection and Appointment of Customer Facing
Third Party Policy.
Protecting Finastra’s reputation and business integrity is vital to the ongoing
success of our business. Failure to comply with this policy may result in
disciplinary action.
2. Requirements Compliance with Anti-Bribery Laws
Finastra has zero tolerance on bribery and corruption, regardless of who is
involved or where in the world it occurs.
Ensuring we comply
The United Kingdom, the United States and many other countries have adopted
and enforce laws prohibiting the payment of bribes for the purpose of obtaining or
retaining business opportunities. Finastra is committed to ensuring that its
employees and those who do work on its behalf do not violate anti-corruption and
bribery laws.
In order for activities of Finastra to comply with the law:
Finastra representatives must conduct business in compliance with the
highest professional and ethical standards and in compliance with the
relevant laws of the country in which they operate.
Finastra representatives must not give, offer or receive any money, gift or
thing of value which could affect the outcome of any business decision or
act as a reward for favourable act or exercise of influence.
Finastra funds must not be used for any unlawful, improper or unethical
purpose.
Finastra representatives must not pay, give or receive any money, gift or
thing of value in return for unlawful, improper or unethical conduct. It
does not matter whether such payments or gifts are made directly or
indirectly by Finastra (i.e. through consultants, sub-contractors, agents,
suppliers or other third parties).
All payments made and received in the course of Finastra work must be
properly documented and be accountable.
Conduct
Be aware of situations which can create greater risks for non-compliance.
Recognizing potential situations
A history of corruption within the country;
Request for cash payments;
Finastra | 10 October 2017 | Global Risk Management | Anti-Bribery & Corruption 2 Giving of cash or cash equivalent gifts (i.e. vouchers);
Requests for payment of unusually high levels of commission to agents
which do not correspond with the services being provided by such party;
Requests for payments to be made to a third party or other unusual
payment requests;
Requests for reimbursement of vague or extraordinary expenses;
Over-invoicing;
Prospective agent, representative or joint venture partner having a
personal or business tie with the individual putting forward their name;
Requests for charitable or political donations to be made by Finastra
during the course of negotiations;
Requests to entertain foreign public officials involved in tenders or
negotiations in which Finastra is participating; or
Requests for “speed payments”, “grease money” or “facilitation
payments” to be paid in order to speed up transactions or secure deals.
In these situations, and others similar in nature, Finastra employees must seek
guidance from their manager and Finastra Group Legal.
Reporting Suspicions
If you become aware of any non-compliance, raise your concerns immediately.
How to report your concerns
You should raise your concern with your manager or function head, and Finastra
Group Legal.
You are also able to report your concerns via our Raising Concerns Helpline (toll-
free phone numbers listed in the Raising Concerns Policy) or via the internet at
www.intouchfeedback.com/finastra. The helpline is operated by an independent
company that specializes in helping businesses respond to concerns. It is staffed
by experienced operators who will log you concern and report it to our Raising
Concerns Committee for investigation. Information is held in confidence and only
shared on a need to know basis.
Finastra will do everything it can to protect your anonymity at your request, unless
prohibited by law.
Finastra does not tolerate retaliation against those who raise concerns and it will
take measures to protect you when you raise your concern.
3. Monitoring / This Policy is reviewed and approved annually or more frequently as needed if
Reporting significant changes occur, to confirm the continuing suitability, adequacy, and
effectiveness of the Policy.
4. Exceptions / Requests for exceptions to this Policy must be submitted to the Chief Risk Officer
Escalations (“CRO”). Any exceptions to this Policy must be approved by the CRO and the
Risk Committee. Exception approval must be obtained prior to taking any action
that would result in non-compliance with this Policy. Exceptions must be
documented and tracked by GRM and approved on an annual basis.
5. Approval / The Policy is owned by Global Risk Management and is reviewed annually by
Oversight designated Management Committees. Upon approval, any non-adherence to the
Policy requirements are registered with Global Risk Management - Policy
Governance.
6. Related Code of Conduct
Resources Conflicts of Interest Policy
Finastra | 10 October 2017 | Global Risk Management | Anti-Bribery & Corruption 3 Gifts & Entertainment Policy
Raising Concerns Policy
7. Questions For questions about the Policy, contact Global Risk Management at
risk.management@finastra.com.
8. Approval and Version Date Approver Author Description of Changes
Version History 1.0 05.10.2017 Tom Kilroy, Chief Dan Bailey Initial
Administrative Officer
Finastra | 10 October 2017 | Global Risk Management | Anti-Bribery & Corruption 4About Finastra Finastra unlocks the potential of people and businesses in finance, creating a platform for open innovation. Formed in 2017 by the combination of Misys and D+H, we provide the broadest portfolio of financial services software in the world today—spanning retail banking, transaction banking, lending, and treasury and capital markets. Our solutions enable customers to deploy mission critical technology on premises or in the cloud. Our scale and geographical reach means that we can serve customers effectively, regardless of their size or geographic location—from global financial institutions, to community banks and credit unions. Through our open, secure and reliable solutions, customers are empowered to accelerate growth, optimize cost, mitigate risk and continually evolve to meet the changing needs of their customers. 48 of the world’s top 50 banks use Finastra technology. Please visit finastra.com. Finastra | 10 October 2017 | Global Risk Management | Anti-Bribery & Corruption 5
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