Purpose

This process provides information to Clients (“Clients” or “you” or “your”) of TP ICAP (“TP ICAP” or “we” or “us” or “our”) who wish to register a complaint. We value our relationship with our Clients and it’s important that we can help resolve any issues you may have. That’s why we are committed to supporting your experience in a way which is fair, clear and not misleading. Therefore we encourage you to let us know if you are not satisfied with any of the services or products that we provide. If you have a complaint about any of our services, please share your concerns right away so we can help you and resolve your complaint as quickly as possible.

Scope

This process applies to any Client of TP ICAP who is not satisfied with the service provided in our capacity as an FCA regulated institution. If an order has been sent to TP ICAP for execution via an affiliated TP ICAP entity, you should contact the relevant TP ICAP affiliate who will liaise with TP ICAP on your behalf.

How do you file your complaint?

If a Client wishes to make a formal complaint, the notification must be made via email or letter to TP ICAP’s Compliance Department and include the information stated below:

Contact address:

Email: complaints@tpicap.com
Letter: Head of Compliance, 135 Bishopsgate, London EC2M 3TP

Information to include:

• Name of the Client and the name of Client’s contact person
• Client’s contact details: postal address, e-mail address and telephone number(s)
• Information regarding your complaint: date, service, product, issue, trade references
• The name of your TP ICAP sales representative or contact person.

Version 1.0, 28 March 2018

1.1 Our commitment

1.1.1. TP ICAP group supports fundamental principles of human rights across all our lines of business and in each region of the world in which we operate. TP ICAP’s respect for the protection and preservation of human rights is guided by the principles set forth in the United Nations Universal Declaration of Human Rights. In addition, we support the UN Guiding Principles on Business and Human Rights. This includes implementing our obligations. We have a defined set of values that underpin everything we do. We are known in the market for our honesty, integrity and excellence in the provision of service to our clients. Above all else, we respect our clients and each other, without bias.

1.1.2. TP ICAP complies with applicable international and local legal requirements in the countries in which we operate.

1.1.3. TP ICAP also looks to promote best practice through its supply chain and uses the UK’s Modern Slavery Act as a basis to help hold our suppliers accountable through regular checks and attestations in relation to Human Rights (see our Procurement and Modern Slavery statement).

1.1.4. TP ICAP is committed to promoting a responsible employee environment respecting the human rights of our employees through our internal employment policies and practices. As part of our broad effort to ensure that respect for human rights is integrated into the business of the firm, TP ICAP has adopted policies and procedures designed to ensure compliance with legal requirements and which seek to prevent our products and services from being used for improper purposes. Such policies and procedures include those contained in our Code of Conduct, our Anti-Corruption, Anti-Money Laundering, Anti-Bribery, and Know Your Customer and counter-terror financing policies.

1.1.5. TP ICAP is dedicated to exemplifying good corporate citizenship through our commitment to respecting human rights and through our broader commitment to corporate responsibility generally.

TP ICAP is committed to building an inclusive place to work, where everyone has an equal opportunity to succeed within our Company.

As signatories of the Women in Finance charter, we have made a public commitment to increase the representation of women in senior leadership and management roles. We are pleased to report that we have met our target to have women comprise 25% of our senior management roles by the end of 2025 ahead of schedule. 

This represents progress, but we know that we have more to do. Our gender pay gap remains material given that we have more men than women in front office broking and senior management roles. Both these roles attract higher rates of pay relative to other positions. This therefore significantly increases average male pay – in the market and at TP ICAP – creating an overall pay and bonus gap. 

Increasing the number of women in senior and front office roles across the business is therefore central to closing our Gender Pay Gap over time. To this end, we are focusing our eff orts on three core areas – recruitment, development and culture. In so doing we will build a more diverse and inclusive workforce that will help drive our sustainable growth ambitions. 

I confirm the information and data reported is accurate.

Sue Maple
Group Head of Human Resources

Version 1.0, 28 March 2018

1.1 Introduction

1.1.1. TP ICAP recognises it has a responsibility to help protect and preserve the environment. To this end the Company endeavours to carry out all reasonably practical measures to meet its responsibilities to reduce its impact on the environment.

The Company makes a commitment to:

• Ensure compliance with all current environmental legislation.
• Seek to identify forthcoming environmental legislation to ensure timely compliance with such new legislation.
• Seek to improve its management of energy, emissions, use of resources and waste
• performance to prevent pollution and provide resources to support effective improvement opportunities.
• Monitor and report the Company’s annual energy usage and greenhouse gas emissions, as appropriate.
• Adopt sustainable procurement practices and work with customers and suppliers to improve energy performance throughout the Company’s supply chain.
• Review this statement and other relevant environmental documentation at regular intervals.

1.2 Responsibilities

1.2.1.  Responsibility for social, ethical and environmental matters rests with the Board, and is included in its terms of reference. The Chief Executive Officer is the Board member responsible for Corporate and Social Responsibility, and as such is responsible for the Company’s Environmental Policy.

1.2.2.  The Chief Operating Officer (COO) has line management responsibility for delivery of the Company’s Environmental Policy through the Facilities Management function, which reports to the COO. The Facilities Management function is responsible for implementing and maintaining the Company’s Environmental Management System (EMS) to ensure the Environmental Policy commitments are met.

1.3 Review and improvement

1.3.1. TP ICAP will continue to monitor the effectiveness of measures implemented under the Environmental Policy. In particular the Company will:

• Support the Facilities Management function in co-ordinating and monitoring the implementation of necessary good practice standards, including the Environmental Management System across the Company’s offices, as appropriate and as required by legislation in each country.
• Produce an accurate annual assessment of the Company’s energy and emissions performance, in its core businesses, for the purposes of management review, voluntary reporting to stakeholders and legislative compliance.
• Produce an accurate annual assessment of the Company’s waste and natural resources use performance, in its core businesses, for the purposes of management review, voluntary reporting to stakeholders and legislative compliance.
• Review actual energy and emissions performance and trends, in its core businesses, and consider amendments to the Environmental Policy as part of an annual environmental management review, and to implement amendments as necessary.

1.4 Communication

1.4.1. TP ICAP is committed to communicating the Company’s Environmental Policy to employees, contractors, suppliers and other interested parties.

Version 3.0, May 2023

1    Introduction

1.1    Statement on the Global Anti-Bribery and Corruption (ABC) Policy

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.

1.2   What is a Bribe?

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.

1.3   What is an Inducement?

An inducement is the offer of “anything of value” which persuades or incentivises someone to give another an unfair business advantage.  

1.4   What is Corruption?

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.

2   TP ICAP ABC Programme

2.1   TP ICAP’s Global ABC Policy requires that employees:

• Are prohibited from accepting, or offering a bribe in any form;
• Must not accept or provide “anything of value” with the purpose of persuading or incentivising an unfair business advantage;
• Must ensure risk-based due diligence is conducted on all third-party relationships;
• Must seek to prevent Gifts and Entertainment being used as a subterfuge for bribery;
• Must be aware of the inducement risk of Charitable Giving and the firm’s policies and procedures relating to Charitable Giving;   
• Must be aware of the blanket ban on all Political Giving;
• Must not make Facilitation Payments unless there is a perceived threat to life, limb or liberty. A Facilitation (or “grease”) Payment is an unofficial payment that secures or speeds up the performance of a routine or necessary action where a employee already has a legal or other entitlement to the action.;
• Must disclose any potential Conflicts of Interests;
• Must understand the higher risk of Public Officials and the internal processes in place to manage this risk;
• Must periodically complete ABC training;
• Must ensure the inducement and conflicts risk of the recruitment process is understood and managed as per internal procedures; and
• Must report any suspicions of bribery and corruption as detailed in the firm’s policies.

2.2   TP ICAP ABC Policies and Processes are designed to:

• Protect the integrity and stability of financial markets and national economies;
• Comply with the UK Bribery Act 2010, the US Foreign Corrupt Practices Act 1977 and other applicable legislation and regulations in all jurisdictions in which we operate; and
• Help combat bribery and corruption.

2.3   Reporting Channels

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.
 

Version 1.1, 16 September 2024

1.1 Our Commitment

TP ICAP is Committed to Equal Opportunity and the Prevention of Discrimination and Harassment

1.1.1. Promoting Equality and Diversity

The TP ICAP Group is committed to promoting Equality and Diversity, encouraging a culture that actively values difference. We recognise that employees from diverse backgrounds and experiences bring valuable insights to the work environment, enhancing our operations. TP ICAP’s goal is to create a positive, cohesive and inclusive culture, where diversity is valued, respected, and built upon. We aim to recruit and retain a diverse workforce that reflects the global markets in which we operate.

1.1.2. Prohibition Against Discrimination

TP ICAP is committed to ensuring that it does not directly or indirectly discriminate against employees, ex-employees, or candidates based on any protected characteristics - whether actual, perceived, or associative - or through personal relationships. We will not tolerate any unlawful discrimination by our employees, nor will we tolerate favouritism based on personal relationships (anti nepotism).

Prohibited Harassment

1.1.4. Ensuring a Harassment-Free Environment 

TP ICAP is also committed to respecting ensuring that the backgrounds, beliefs, and cultures of all its eEmployees are respected and to and ensuring that the working environment is free from discrimination, harassment, bullying or any other conduct which causes an Employee’s suffering. We are The Group also is committeddedicated to encouraging diversity amongst our its current workforce and candidates. 

Controls to Prevent Discrimination and Harassment

1.1.5. Protective Measures

TP ICAP operates a number of controls to protect employees from discrimination:

• We recognise that employees, ex-employees, or candidates subjected to discrimination, harassment or bullying are vulnerable and may be reluctant, or afraid, to raise the issue. We encourages anyone who believes they have been subjected to any form of discrimination, harassment, or bullying to report this to the local or regional HR function (for employees, in accordance with the local Grievance Policy).
  Similarly, any Employee who observes conduct which they believe, in good faith, would reasonably be regarded as discrimination, harassment, or bullying, is encouraged to report it to their local or regional HR function. 
• We appropriate training, development, and support to employees involved in line manager activities

For more information on harassment in the workplace, please visit the GOV.UK definition of harassment in the workplace.

Inclusion

1.1.6. Promoting Diversity and Inclusion

In addition to formal controls and processes TP ICAP is committed to promoting diversity and inclusion across the company. We have developed an employee-led networking forum called “Connect”, tasked with promoting and celebrating diversity across the company. This includes hosting events, co-ordinating training and development, and networking to ensure any employee, from any background, feels supported in the working environment.

 

Version 3.0, February 2024 

1.1 Introduction

Statement on Anti-Money Laundering (AML), Counter Terrorist Financing (CTF) and Sanctions.

TP ICAP is committed to:

• Not being used by criminals to launder the proceeds of crime or by terrorists or sanctioned individuals and entities;
• Protecting the integrity and stability of financial markets and national economies;
• Complying with applicable legislation and regulations that work towards maintaining the integrity and stability of financial markets and national economies;
• Helping combat terrorist financing;
• Preventing the facilitation of tax evasion;
• Fully adhering to international sanctions programs as issued by relevant authorities.  
   

2 AML/CTF Control Framework

The Group assesses the threat of being used in connection with money laundering, terrorist financing and/or the facilitation of relevant predicate offences.

To maintain an effective AML/CTF framework, the Group has established and maintains risk-based policies and procedures which:

a)    Recognise the money laundering/terrorist financing/facilitation of tax evasion threat to the Group varies across clients, jurisdictions, products and delivery channels;
b)    Allow management to differentiate between their clients in a way that matches the risk in their business; and
c)    Allow senior management to tailor the Group’s procedures, systems and controls, and arrangements in particular circumstances.
 

3 Sanctions Control Framework

The Group complies with applicable economic and financial sanctions laws, regulations, embargoes or restrictive measures. The Firm will not conduct business, maintain relationships with clients or engage in any transactions or dealings that could result in a violation of applicable Sanctions Laws, including activity that could constitute evasion or attempted circumvention of applicable Sanctions Laws.  

4 AML/CTF and Sanctions programme

TP ICAP applies the following controls to manage the risk of AML, CTF and Sanctions:

• AML and Sanctions Risk Assessment;
• Locally documented policies and procedures to implement the Global Policy, as well as local regulatory requirements;
• Client, Vendor and Employee screening to identify financial crime red flags and when identified, mitigating those risks;
• All clients are subjected to AML/KYC client due diligence prior to the provision of services and on an on-going basis thereafter;
• AML, CTF and Sanctions training;
• Financial Crime Management Information presented to relevant Governance Forums;
• Monitoring of business relationships, including client transactions for potentially suspicious activity, and
• Where required, filing a Suspicious Activity Report with the relevant law enforcement authority. 
   

5 Governance

TP ICAP’s Group AML/CTF and Sanctions Policy is approved by the relevant Governance Forum and applies to all TP ICAP’s businesses globally.

TP ICAP’s internal audit function carries out regular Anti-Financial Crime (AFC) audits which provide Senior Management with the necessary assurance regarding the operational effectiveness of the AFC Policies and the related systems and controls.