Introduction

Arrow Global Group (AGG) is committed to conducting all business and relationships with integrity and professionalism and in a fair and honest manner, whilst complying with regulation and legislation pertaining to its business. Our aim is to limit exposure to bribery by:

  • Setting out clear anti-bribery and corruption policies and standards for our colleagues and third-parties;
  • Set out our responsibilities and of those working for us, in observing and upholding our position on bribery and corruption, and providing clear channels of communication to report any suspicion of bribery;
  • Providing training, education and guidance for colleagues on how to recognise and deal with bribery and corruption issues;
  • Providing oversight to ensure compliance with anti-bribery laws, rules and regulations across all countries that AGG conducts business;
  • Taking firm and clear action against any individual(s) or third parties involved in bribery.

The key policy requirements are:

  • Colleagues must conduct all business and relationships with integrity and professionalism and in a fair and honest manner, whilst complying with regulation and legislation.
  • Accurate and timely management information (MI) must be provided to the Board and Senior Management via relevant committees.
  • All business areas are responsible for assessing and reporting bribery and corruption risk and executing controls where required.
  • Appropriate due diligence must be performed before entering into a relationship with a new third party.
  • Monitoring of higher risk third party relationships must take place regularly.
  • All offered and received gifts or hospitality must be approved, if appropriate, and logged in the Gifts and Hospitality Register.
  • The Group does not make, and will not accept, facilitation payments or "kickbacks" of any kind.
  • The Group does not make contributions to political parties.
  • The Group Chief Risk Officer (CRO) is responsible for considering concerns, investigating where appropriate and reporting to the appropriate committees and authorities.

Colleagues wishing to raise a concern around bribery or corruption at AGG can speak directly to the Financial Crime Senior Manager or Group CRO. The Group also has a Whistleblowing Policy which can be followed by colleagues for raising concerns.