Treating Customers Fairly
Union Investment Bank's policy is to ensure that the bank promotes and adheres to the concept of fairness when dealing with its customers or prospective customers. Accordingly we have adopted a TCF policy pursuant to FCA principle 6 ‘A firm must pay due regard to the interests of its customers and treat them fairly’.
The Bank has adopted the six consumer outcomes which the FCA requires;
Our customers can be confident that they are dealing with a firm where their fair treatment is central to our corporate culture;
Our products and services marketed and sold in the retail market are designed to meet the needs of our consumer groups and are targeted accordingly;
All customers are provided with clear information and are kept appropriately informed before, during and after the point of sale;
Where our customers receive advice, the advice is suitable and takes account of their circumstances;
Our customers are provided with products that perform as we have led them to expect and the associated service is of an acceptable standard and as they have been led to expect;
Our customers do not face unreasonable post-sale barriers imposed by us to change product, switch provider, submit a claim or make a complaint.
Union Investment Bank is covered by the Financial Services Compensation Scheme (FSCS)
The FSCS can pay compensation to depositors if a bank is unable to meet its financial obligations. Most depositors, including most individuals and small businesses are covered by the scheme. In respect of deposits, an eligible depositor is entitled to claim up to £85,000. For joint accounts each account holder is treated as having a claim in respect of their share so, for a joint account held by two eligible depositors the maximum amount that could be claimed would be £85,000 each making a total of £170,000. The £85,000 limit relates to the combined amount in all the eligible depositor’s accounts with the bank, including their share of any joint account and not to each separate account.
For further information about the scheme including the amounts covered and eligibility to claim please contact us on 020 7290 3060 or refer to the FSCS website www.FSCS.org.uk or Call: 0800 678 1100 or 0207 741 4100
Pursuant to the USA PATRIOT Act and final rules issued by the U.S. Department of the Treasury, a U.S. bank or a U.S. broker-dealer in securities (a "Covered Financial Institution") is required to obtain certain information from any "Foreign Bank" that maintains a correspondent account with it. As permitted by the final rules, Union Investment Bank agreed a Certification for use by any Financial Institution that believes it requires a Patriot Act Certification from a Union Investment Bank. CT Corporation System, of 111 Eight Avenue, 13th Floor, New York, NY 10011, USA has been appointed as our acceptors of Process Serving.
Other Governance Measures
The bank has an established internal audit function which undertakes its work in accordance with an annual plan which is approved by the Audit & Compliance Committee. The Head of Internal Audit reports directly and independently to the Chairman of the Audit & Compliance Committee who is an independent Non-Executive Director. In addition to the Board and Management Committee framework, Union Investment Bank has a range of Board-approved policies and accompanying delegations, guidelines, manuals and procedures which provide clarity and consistency to the bank’s operations and decision making process.
Corporate Statement — Bribery & Corruption
Union Investment Bank recognizes that bribery and corruption have an adverse effect on communities wherever they occur and, if endemic, can threaten laws, democratic processes and basic human freedoms, impoverishing states and distorting free trade and competition. Corruption is often associated with organized crime, money laundering and on occasions the financing of terrorism. In addition, the level and efficacy of investment and financing can be reduced, particularly within economically disadvantaged societies.
We define bribery as where a person requests, agrees to receive or accepts a “financial or other advantage” intending that, in consequence, a relevant function or activity should be “performed improperly” (whether by that person or another person). “Improper performance” means an act or omission in breach of an expectation of good faith, impartiality, or a position of trust.
Union Investment Bank is committed to applying high standards of honesty and integrity consistently across our global operations and in all our business dealings. Our Bribery Policy reflects the statutory requirements applicable to the UK, including the Bribery Act 2010 and also those derived from the UN and OECD conventions on corruption.
Union Investment Bank Bribery Policy applies to all its employees as well as agency workers, consultants and contractors, irrespective of their location, function, grade or standing.
We expect our business partners, suppliers and contractors to act with integrity and without thought or actions involving bribery and, where appropriate, we include clauses to this effect in relevant contracts.
Union Investment Bank's Bribery Policy requires employees:
Not to offer or make any bribe, unorthodox or unauthorised payment or inducement of any kind to anyone;
Not to solicit business by offering any bribe, unorthodox or unofficial payment to customers or potential customers;
Not to accept any kind of bribe, unorthodox or unusual payment or inducement that would not be authorised by ZBL in the ordinary course of business;
To refuse any bribe or unorthodox payment and to do so in a manner that is not open to misunderstanding or giving rise to false expectation; and to report any such offers;
Not to make facilitation payments (these are payments used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer of the facilitation payment has a legal or other entitlement);
To report any breaches of the policy, related principles or standards or of any associated legislation.
Our “Whistle Blowing” policy and guidance is available to any employee who encounters a breach or potential breach of policy. They can report concerns in confidence and without fear of reprisals via a dedicated email address. All reports raised are taken seriously and, where appropriate, investigated in more depth. No employee is discriminated against in any way as a result of reporting a concern in good faith.
Our policy on bribery is supported by governance procedures covering monitoring of adherence and record keeping. Any breach of policy by any employee will be considered as grounds for disciplinary action, which may include dismissal.