1 To qualify for an HSBC Premier relationship, you need to open an HSBC Premier checking account and maintain balances of $75, in combined U.S. Dollar personal deposit accounts and investment* balances OR recurring direct deposits totaling at least $5, from a third party to an HSBC Premier checking account (s) per calendar month OR an HSBC U.S. residential mortgage loan with an HSBC Global Money Account is a prepaid, multi-currency account available on our the HSBC Mobile Banking App for customers who maintain an HSBC consumer deposit account. Data rate charges from your service provider may apply. HSBC Bank USA, N.A. is not responsible for these charges Rule on personal account dealing. COBS R 03/01/ RP. A firm that conducts designated investment business must establish, implement and maintain adequate arrangements aimed at preventing the following activities in the case of any relevant person who is involved in activities that may give rise to a conflict of interest, or who has
Nomura Asset Management U.K. Limited - Personal Dealing Policy
Exhibit p 5. Insider Dealing Notice. July This notice draws your attention to Part V of the Criminal Justice Act “the Act” and to the Personal Account Dealing Rules of Nomura Asset Management U.
Ltd NAM UK. It is important that you read this document carefully. If there is anything you do not understand, please contact the Compliance Department ‘Compliance’. Please note that by signing and returning to Compliance the ‘Acknowledgement and Undertaking’ pertaining to the Compliance Handbook, you agree to observe the Act and the personal account transaction requirements set out in this Notice. NAM UK attaches great importance to strict compliance with your undertaking.
Please note that it is legally binding and will form part personal account dealing policy hsbc forex your contract of employment. Any breach of the undertaking would constitute misconduct for the purposes of the disciplinary procedures as set out in the Nomura Employee Handbook and could lead to your dismissal without notice. Other personal account dealing policy hsbc forex sanctions for breach include:.
b INSIDER DEALING, personal account dealing policy hsbc forex. PART V OF THE CRIMINAL JUSTICE ACT NOTICE TO EMPLOYEES. Under the rules of the FSA, we are required to provide you with a brief summary of the Insider Dealing Regulations. The Insider Dealing provisions contained in Part V of the Criminal Justice Act [“the Act”] are complex, and if you would like fuller details or are in any doubt whether a particular transaction would be prohibited, you should consult Compliance.
The Act applies to all securities traded on a regulated market which currently includes all EU stock exchanges, LIFFE, OMLX and NASDAQand to warrants and derivatives including index options and futures relating to these securities personal account dealing policy hsbc forex if these warrants and derivatives are “over the counter” or otherwise not publicly traded.
In broad terms, and subject to the exemptions provided by the Act, the Act makes it a criminal offence, with a maximum penalty of 7 years imprisonment and an unlimited fine, for an individual who has non-public information to deal in price-affected securities including warrants or personal account dealing policy hsbc forex relating to them on a regulated market; or with or through a professional intermediary; or by acting himself as a professional intermediary.
Securities are “price-affected” if the inside information, if made public, would be likely to have a significant effect on the price of the securities. This applies to all companies’ securities affected by the information, whether directly or indirectly for example, competitors of a company about to bring out a new product. The Act applies whether you deal as part of your employment or on your own account. It also covers information which you obtain directly or indirectly from an insider, whether or not in the course of your employment, e.
by social contacts. If you are precluded from dealing, normally you are also prohibited from dealing on behalf of the firm or a client except perhaps on an unsolicited basis and from procuring or encouraging another person to deal in the price-affected securities whether or not the other person knows that they are price-affected and from passing the inside information to another person other than in the proper performance of your employment.
It is possible for a transaction which involves insider dealing to constitute an offence otherwise than under the insider dealing provisions of the Criminal Justice Act.
In particular, under section of the Financial Services and Markets Actthe FSA have created a Code of Market Conduct. This establishes a market abuse regime, one of the categories being ‘misuse of information’, which could apply to an insider dealing transaction. For further details of the regime, refer to the Compliance Manual, Chapter A] Securities Exchange Commission “SEC”.
NAM UK is registered with the SEC as an Investment Adviser and therefore has to pay due regard to certain rules and regulations imposed by the SEC. In particular, NAMUK are required to abide the Investment Advisors ActCode of Ethics Rule a 1 which requires investment advisers to Periodic reporting and review of all “access person’s” personal securities transactions and holdings to the adviser’s chief compliance officer.
This should be done no later than 10 calendar days after joining Nomura. The information supplied should be no more than 45 days old. please see Appendix 3. Thereafter quarterly transaction reporting to be provided within 30 calendar days of quarter end. please see Appendix 4. Annual declarations of holdings to be provided within 30 calendar days of the request by compliance, for which the information should be no more than 45 days old.
c PERSONAL ACCOUNT DEALING RULES. ii communicate any information or opinion to any other person if he knows, or has reason to believe, that that person or some other person will, in consequence, enter into such a transaction or counsel or procure any other person to do so either on behalf of the employee or any other person. Expatriate employees are reminded that in addition to these rules, the Personal Account Dealing Rules personal account dealing policy hsbc forex their local Nomura Company continue to apply to them and take precedence over these rules.
Similarly, personal account dealing policy hsbc forex, employees seconded to other Nomura companies remain bound by these PA Dealing Rules. Secondee from another company inside or outside of the Nomura Group. References to dealing by an employee include dealing for his own account or:.
i dealing in his capacity as a personal representative or executor or other analogous position of an estate or as a trustee of a trust in which estate or under which trust there is a significant interest held by the employee, or any associate of the employee, or any company or partnership controlled by him or an associate; or. These rules apply to all transactions in “investments” within the definition of the Financial Services and Markets Act These are, broadly, the following:.
This includes transactions undertaken through PEPs, IRAs, ISAs, SIPP’s, personal account dealing policy hsbc forex, cash management accounts or any type of investment vehicle falling within the scope of these rules. These rules apply to all employees, their spouses, co-habitee partners and children under No other family members or other relationships are subject to the rules.
Personal account dealing policy hsbc forex shall take all reasonable steps to ensure that any person connected to them as described above complies with these rules when, that person transacts investment business for his own account.
Such transactions are notified to Compliance. An employee with a spouse or co-habitee partner who is subject to the PA Dealing rules of another financial institution should notify Compliance so that arrangements can be made to avoid any conflicts between that institution’s rules and those of NAM UK. The PA Dealing Rules do not apply to an employee where any transaction is entered into on his behalf but without prior communication with him by a person in the exercise of:.
Any personal account dealing policy hsbc forex wishing to transact a personal account deal must obtain the prior approval of Compliance. It is a requirement that staff request their broker to send a duplicate copy of all contract notes directly to Compliance for control purposes. Gold cards and other investment facilities provided by other firms as part of multi-service banking packages also fall within the provisions of the foregoing paragraph and of Personal account dealing policy hsbc forex 5 below.
Except for those transactions referred to in Section 5. All consents given are. generally only valid for two working days from the time of approval by Compliance see Section 5. With effect from June NAM USA has been selected to replace Fidelity as the investment adviser to ‘The Japan Fund’, a US registered mutual fund. This means that the fund is now considered an “affiliated” fund under US regulations. The “Authorisation for Personal Dealing” form Appendix 1 should be completed in the usual way, authorised by the employee’s line manager and handed to NAM UK Compliance, personal account dealing policy hsbc forex.
NAM UK Compliance will contact NAM USA Compliance to obtain permission and only when permission has been granted from both compliance departments and the authorised form handed back to the employee, may the deal go ahead. The standard 48 hour permission window applies. Any transactions in the Japan Fund must be recorded on the employee’s quarterly transaction return please see Appendix 4and any holdings in the fund must be recorded on the employee’s annual declaration of holdings.
A] NO CONSENT REQUIRED. NB—investment trusts are not collective investment schemes. iii Long term insurance contracts within the meaning of the Insurance Companies Act This list may be expanded from time to time to include different classes of investment or specific investments, personal account dealing policy hsbc forex. For the purposes of these Personal Account Dealing Rules, your Head of Department is the person to whom you report.
If you are in doubt as to whether an individual is authorised to approve your personal account transactions or external dealing accounts, please check beforehand with Compliance, personal account dealing policy hsbc forex. In respect of his own personal investment transactions, a Head of Department should obtain the permission of an Executive Officer of NAM UK and Compliance Dept.
Managing Directors and above need only obtain the approval of Compliance. Generally, if the proposed deal is not conducted in the two day time period, then the approval will expire. If the deal is to be completed at a later date, the employee must complete a new “Authorisation for Personal Dealing” form, prior to dealing, or obtain a signed declaration on the original form from Compliance.
Initial Public Offering “IPO”. Where an employee subscribes to an IPO, approval is required prior to the subscription. The time period restriction is waived where the period between subscription and allocation is greater then two days. However, in all circumstances, the employee must furnish Compliance with the following:. subscription period, allocation date, initial price if known and first trading day if known. Where the proposed subscription was not effected, a note to this effect; and.
If the proposed subscription was not taken up in its entirety i. was downsized at allocation. Index Options. Subject to the prior approval of Compliance and the relevant Head of Department, employees may obtain a limited general permission to deal, during a three month period and up to an agreed monetary limit, in traded index options.
Informal Offer. Where an informal offer to deal is made, the time period may be waived. However, additional approval is required using the approval form if and when the offer is formalised, personal account dealing policy hsbc forex.
Other Exceptions. Compliance may increase the time period if the circumstances dictate this course of action to be appropriate. This decision will be taken on a case by case basis. After consent has been obtained for a transaction in accordance with Section 5it is your responsibility to arrange for its execution within two working days from the time of approval by Compliance subject to the exceptions contained in Section 5.
In respect of transactions through any external account, you must inform the firm concerned that you are an employee of NAM UK, which is regulated by the FSA, and that NAM UK has permitted the transaction. It is a condition of NAM UK’s permission for the maintenance of such accounts that the firms concerned send to Compliance directly, copies of contract notes relating to transactions over the accounts. Where the nature of the transaction is such that a contract note would not normally be issued e.
application for, and allotment of, securities pursuant to a public offerequivalent confirmatory documentation should be provided to Compliance where possible e. copies of renounceable letters of allotment. All trades must be settled in full within the settlement period.
DO NOT DO THIS in QuickBooks (When Adding Bank Transactions)
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For the purposes of these Personal Account Dealing Rules, your Head of Department is the person to whom you report. If you are in doubt as to whether an individual is authorised to approve your personal account transactions or external dealing accounts, please check beforehand with Compliance The Policy is designed to ensure you are aware of the restrictions on your personal account transactions and of the measures established by HSBC in connection with your personal transactions. The Policy is designed to: i. Prohibit insider dealing and/or market manipulation; blogger.com Size: KB Personal account transactions in Equity/ETF securities that fall under their areas of coverage will be permitted, pursuant to established pre-clearance policies and procedures. Note: The “Black Out Period” rule still applies to all covered transactions, as set forth under Section of the Code, and under the GPAD Policy and US Addendum
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