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 2.0, 12 June 2025

1.1 Introduction

1.1.1 TP ICAP recognises its responsibility to protect and preserve the environment and understands the critical role that environmental performance plays in long-term business resilience and stakeholder trust. We are committed to integrating environmental sustainability into our core business strategy, operations, and decision-making. To this end, the Company endeavours to carry out all reasonably practical measures to meet our responsibilities whilst reducing our impact on the environment.

The Company makes a commitment to:

Compliance and governance

• Ensure full compliance with all applicable environmental legislation and maintain continuous monitoring of emerging regulations to ensure timely adherence.
• Publish an annual Sustainability Statement outlining our environmental strategy, performance and progress. This will include disclosures on energy usage, greenhouse gas emissions, and progress toward relevant targets.
• Conduct regular materiality assessments to identify and address environmental dependencies, impacts, risks, and opportunities across our operations and value chain.

Climate and energy

• Integrate climate-related risks and opportunities into business planning, consistent with the recommendations of the Task Force on Climate-related Financial Disclosures (TCFD), including the use of scenario analysis to assess the resilience of our strategy under different climate futures.
• Improve the management and reduction of our greenhouse gas emissions across our Scope 1, 2, and 3 footprint. This includes actions aligned with our target to achieve carbon neutrality across Scopes 1 and 2 emissions by the end of 2026.
• Expand the use of renewable energy across our global office network.

Resources and circular economy

• Responsibly manage our resource use – including water and waste – by allocating resources to support continuous improvement, prevent pollution, and promote responsible consumption. We commit to aligning our approach to the circular economy principles: reduce, reuse, recycle, and recover.

Supply Chain and Procurement

• Adopt sustainable procurement practices, prioritising suppliers with strong environmental credentials and encouraging emissions reductions through engagement across our supply chain. 

Nature and Biodiversity

• Respect nature and biodiversity by committing to avoid negative impacts on threatened and protected species. While TP ICAP’s operations have limited direct impact on nature, we recognise the intrinsic value of the natural environment and support broader efforts to protect biodiversity through responsible business practices and environmental stewardship.

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 Board actively oversees sustainability performance and associated risks and opportunities. The Group Chief Executive Officer is responsible for the Company’s Environment Policy.

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

1.2.3 The ESG Forum, reporting to the Group Executive Committee, ensures that ESG is integrated across business functions, providing oversight and advice in relation to ESG strategy, policy development, implementation, communications, and disclosures.

1.3 Review and continuous improvement

1.3.1 TP ICAP will continue to monitor the effectiveness of measures implemented under the Environment Policy. We will regularly review and improve this policy and related environmental documentation to ensure alignment with emerging best practices and stakeholder expectations.
In particular the Company will:

• Support the CRE function in coordinating 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.
• Integration of ESG metrics into management reviews, decision-making, and executive remuneration schemes.
• Annual performance assessments for energy, emissions, waste and natural resource use across our core businesses to support management review, reporting to stakeholders and legislative compliance.
• Review energy and emissions performance trends across our core businesses. Leverage findings to implement energy efficiency initiatives, including low-carbon technologies, smart building systems, and operational best practices.
• In reviewing our environmental performance and strategy, we will consider the broader environmental, social, and economic linkages and potential trade-offs. This ensures our actions are context-sensitive, balanced, and aligned with long-term sustainability goals.
• Consider amendments to the Environment Policy as part of an annual environmental management review, incorporating stakeholder feedback, regulatory developments, and internal performance to implement amendments as necessary.

1.4 Communication and stakeholder engagement

1.4.1 TP ICAP is committed to transparent, inclusive, and regular communication of the Company’s Environment Policy and progress to employees, contractors, suppliers and other interested parties. We will: 
Engage suppliers, clients, and partners to promote collaborative environmental performance improvements.

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.