Imprint

Company:

Vontobel Holding AG
Gotthardstrasse 43
CH-8002 Zurich
Phone +41 (0)58 283 59 00
Fax +41 (0)58 283 75 00

E-mail

Company number:

CH-020.3.928.014-4

Entry in the commercial register

Unique Identification Number for Businesses (UID):

CHE-116.300.767

Competent Governmental Authority:

Swiss Financial Market Supervisory Authority FINMA
Einsteinstrasse 2
CH-3003 Bern

www.finma.ch

Vontobel statement of anti- bribery and anti-corruption

Vontobel is committed to preventing bribery and corruption and to consistently comply with anti-bribery laws, rules and regulations that are applicable to its business activities. This is consistent with Vontobel's commitment to behave honestly and ethically in all its business dealings.

Vontobel has in place a Group Policy designed to prevent the occurrence of bribery and corruption. Vontobel applies a zero-tolerance policy with respect to the giving or receiving of bribes, including the making of facilitation payments, taking or granting undue advantage, and corruption. We expect all employees, persons who perform services for or on behalf of Vontobel and other third parties with whom Vontobel has a business relationship, to comply with these principles in the performance of their services for or on behalf of Vontobel.

Vontobel’s Group Policy prohibits any Vontobel employee, directly or indirectly, offering, promising, soliciting or receiving any payment that is in the nature of a bribe, kickback, facilitation payment or other undue advantage in any form. This applies where the payment has the purpose or effect of bribery or encouraging the improper performance of one’s functions or activities in both the public and private sector. In addition, any other way to provide improper advantages to Vontobel, its employees, customers or other third-parties, including government officials are prohibited.

Vontobel’s anti-bribery and anti-corruption measures include:

Commitment and communication: Vontobel’s senior management is committed to maintaining a culture of zero-tolerance with regard to bribery and corruption and intends that it is clearly communicated to all employees and all relevant third parties
Bribery and impermissible transactions: All forms of bribery, including facilitation payments and kickbacks, and other types of proscribed behaviour are prohibited, whether directly or indirectly through another person.
Gifts and invitations: Vontobel's employees must not accept, give or promise gifts and/or invitations that represent corruption. Any gifts must not give them, Vontobel, clients, or third parties an undue advantage or cause persons in any other way, either directly or indirectly, to carry out their role, task, or office improperly or to refrain from actions related to their role, task, or office. Vontobel has similar expectations of persons who perform services for or on behalf of Vontobel and other third parties with whom it works
Training: Vontobel delivers anti-bribery and corruption training for its employees, with a particular focus on employees who may operate in higher risk sectors or jurisdictions
Reporting: Vontobel encourages the reporting of any suspicions of bribery and corruption to ensure that appropriate procedures are in place, to investigate accordingly, and to implement any control enhancements necessary
Authorities, their representatives, or representatives of public-sector undertakings: Dealings with such persons are subject to heightened due diligence requirements and care
Charitable and political contributions: Vontobel does not improperly contribute to any political organization, candidate or initiative. Charitable and other donations must not be abused to support any form of corrupt behavior
Payments and financial controls: Vontobel's expenses and payments procedures and authorization processes require a clear understanding of why payments are made and to whom, ensuring that there is a clear business rationale. Vontobel has similar expectations of persons who perform services for or on behalf of Vontobel and other third parties with whom it works
Risk-based due diligence: Vontobel applies due diligence processes on persons who perform services for or on behalf of it, with further due diligence conducted on those deemed to be high risk
Risk assessments: Vontobel applies risk measures on all its businesses to identify, mitigate and control potential bribery and corruption risks