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Version 3.0, May 2023
TP ICAP does not tolerate bribery, whether active or passive, or corrupt behaviour of any kind. We also expect the same from any third parties providing services for, or on behalf of, TP ICAP globally. Management are committed to ensuring there are robust frameworks in place to manage ABC risk. The Global Head of Compliance is the Group ABC Policy Owner and the Accountable Executive is the Group General Counsel.
A bribe is the offer of “anything of value” to a person in exchange for that person to provide an undue business advantage or other advantage. This advantage may be in connection with the improper performance of a position of trust, or a function that is expected to be performed impartially or in good faith.
The offer, payment or promise of anything of value does not have to be successful in order for it to be a bribe.
An inducement is the offer of “anything of value” which persuades or incentivises someone to give another an unfair business advantage.
Corruption is the abuse of entrusted power for personal/commercial gain. To this end, bribery is a specific form of corruption and such activity undermines social and economic development.
All Employees have a personal responsibility to not only adhere to the TP ICAP Global Anti-Bribery and Corruption Policy, but report any suspicions of bribery and corruption. Each region has a Responsible Manager who is responsible for the effective regional ABC risk management.
Where a employee wishes to seek guidance or raise a concern, the employee may do so by contacting their local Compliance department or via the Whistleblowing process which allows those who work with or within TP ICAP to report a concern about past, current or future workplace malpractice relating to bribery and corruption.
Depending on the local regulatory framework, a material ABC breach may be reported to the relevant authority as required.
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