At UOB, we adopt a strong stance against bribery and corruption, with our Code of Conduct specifying zero tolerance to bribery and corruption in all forms.
Both corporates and individuals can potentially be prosecuted for giving or receiving bribes. Commission of offences can occur even if our employees are not physically present in the US, UK or Australia. A summary of these laws is available to all employees on our intranet.
Under our Policy on Managing Legal Risks, business and support units are required to identify, assess, monitor and report legal risks, including corruption risks, which may arise in their respective scope of work and/or business. This policy applies Group-wide, and is reviewed annually and approved by the Operational Risk Management Committee (ORMC). Group Legal provides advisory support for compliance with anti-bribery and anti-corruption laws, as well as for the management of any identified risk.
With respect to customer relationships, we regularly review and communicate applicable anti-corruption policies and procedures, including ensuring the inclusion of specific terms and conditions and/or contractual provisions where required. We require our employees, contractors, vendors, third parties and other stakeholders to be aware of and to comply diligently with our anti-bribery and anti-corruption provisions. We review our training module on anti-bribery and anti-corruption annually to ensure that the content is aligned with our overall objectives.
Prohibiting insider trading
All employees are required to adhere to the UOB Group Staff Trading Policy, which prohibits insider trading. The policy is reviewed annually and approved by the ORMC.
UOB has in place a pre-trade clearance system that requires employees, who may reasonably be expected to have access to inside information, to make declarations and seek approval before dealing in securities or executing their trades on any stock exchanges. In addition, Group Compliance regularly reviews securities transactions to detect potential violations. Employees may be subject to disciplinary action for non-adherence to the policy.