Anti Bribery and Corruption Policy Statement

SG Kleinwort Hambros Bank Limited and its subsidiaries (Kleinwort Hambros) is committed to ensuring that:

It implements policies and procedures to minimise  the risk that a bribe is made by an associated person on its behalf;

It implements policies and procedures to minimise the risk that it is used to facilitate the payment or receipt of a bribe or the proceeds of corruption;

It acts as a responsible member of the community in deterring, preventing and, where necessary, reporting Bribery and Corruption to the relevant authorities; and,

Its employees at all levels abide by the highest standards of moral and ethical behaviour.

Kleinwort Hambros will comply with both the spirit and specific provisions of all relevant Anti-Bribery and Corruption laws, regulations and rules.

Objectives of the Anti-Bribery and Corruption Strategy

The objectives of the Kleinwort Hambros Anti-Bribery and Corruption Strategy are as follows:

Kleinwort Hambros minimises the risk that an associated person pays or receives a bribe for or on its behalf;

Kleinwort Hambros minimises the risk that it is used to facilitate the payment or receipt of a bribe or the proceeds of corruption;

Kleinwort Hambros will take and enforce a zero tolerance attitude to Bribery and Corruption, whether committed by external third parties, any member of staff, its clients or any combination of these parties colluding together.

Kleinwort Hambros will protect the reputation and integrity of itself, its parent company in France, Societe Generale and of the financial markets within which it operates.

Kleinwort Hambros will constantly measure, monitor and report on Bribery and Corruption risk to enable Senior Management to better understand that risk and to enable them to maintain the appropriate policies and procedures required.

Kleinwort Hambros will proactively apply industry best practice with regards to Bribery and Corruption prevention and liaise as appropriate and where necessary with any industry bodies.

In the event that Kleinwort Hambros is exposed to Bribery and Corruption activity, it will ensure that investigations and actions are in accordance with the documented Kleinwort Hambros investigation process; including consideration of "self-reporting" incidents to the Serious Fraud Office.