Policies and Procedures

EFG Hermes requires that all leadership, employees, representatives, independent contractors and consultants comply with an institutionalized code of conduct to provide general guidance regarding conduct and ensure the observance of corporate governance best practices throughout the firm. The code lays out the responsibilities of each person with regards to confidentiality, disclosure, protection and use of information and transparency. It serves as the foundation of the firm-wide commitment to international standard corporate governance practices.

We strictly prohibit the buying or selling of securities while in possession of material non-public “inside information,” as well as the communication of that information to others. We define inside information as material, non-public information about securities, activities or financial conditions of a corporation, public entity or other issuer of securities. Material, non-public information concerning market developments may also be construed to be inside information.

Information should be considered "non-public" unless it is clearly public. Information is deemed public once it has been publicly announced or otherwise disseminated in a manner that makes the information available to investors generally.

If our employees are aware of inside information,
Staff is strictly prohibited from the buying or selling of securities while in possession of material non-public “inside information,” as well as the communication of that information to others. Inside information is defined as material, non-public information about securities, activities or financial conditions of a corporation, public entity or other issuer of securities. Material, non-public information concerning market developments may also be construed to be inside information.

Information should be considered "non-public" unless it is clearly public. Information is deemed public once it has been publicly announced or otherwise disseminated in a manner that makes the information available to investors generally.

If employees are aware of inside information,
• They may not buy or sell securities that may be affected by that information, either for their own account or any account over which they exercise control, alone or with others.
• They may not pass along any inside information expressly or by way of making a recommendation for the purchase or sale of such securities based upon inside information.
These prohibitions are applicable no matter how inside information is acquired. They are applicable to the securities of EFG Hermes as well as other companies.

The firm’s compliance policy allows senior management to maintain best practice control standards and to fulfill regulatory requirements. More importantly, compliance safeguards the company against undue risk, whether reputational or financial. Compliance policies, procedures and controls are continuously updated, reviewed and communicated to all departments, branches and subsidiaries. Employees undergo annual anti-money laundering, anti-fraud and risk-awareness training, and additional ad-hoc trainings are held for new hires.

EFG Hermes is committed to maintaining a work environment with the highest standards of transparency and accountability. An important aspect of transparency and accountability is having a mechanism that enables employees to voice any concerns in a confidential, safe and effective manner. Employees should be empowered to share any information they may discover that highlights potential fraud and any failure to comply with a law, regulatory requirement, internal rule, regulation or policy, or any workplace malpractice without fear of being reprimanded. This policy is intended to assist employees who believe they have discovered fraud or malpractice; it is not designed to allow employees to question financial or business decisions made by the company.

Appropriate management of information is essential for EFG Hermes to maintain the trust of our clients and shareholders, and world-class systems are in place to manage personal and corporate information that we store for our business operations. EFG Hermes adheres to the highest international standards for information disclosure and protection of sensitive information, and we voluntarily choose to comply with stringent standards above and beyond those required by regulators in all our countries of operation. Our institutionalized disclosure and documentation procedures are reinforced by our commitment to raising awareness about the importance of these issues at the firm through employee training and information campaigns.

The firm is committed to safe guarding confidential information against conflicts of interest arising from unstructured interactions between the firm’s divisions. Chinese Walls (sometimes referred to as "information sharing barriers") are in place to prevent the flow of inside information from "insider" areas to "public” areas of EFG Hermes. The Chinese Wall policy prohibits anyone in an insider area from communicating inside information to anyone in a public area. A set of regulations and procedures is followed to regulate breaches of the wall, which are approved by a control room. Employee trading blackouts are strictly enforced during the lead up to major corporate announcements to prevent the improper use of confidential information. Any request for wall-crossing must be approved by compliance. Furthermore, all sensitive or potentially sensitive developments are shared on a strictly need-to-know basis to limit any risk of the spread of insider information.

We believe that having sufficient information about our clients is the best way to minimize the Firm’s risk of being used for illicit activities. Having this information also protects us against fraud and enables us to recognize suspicious activity. Our Anti-Money Laundering Policy is based upon strict adherence to the following procedures:

• Verification of the identity of new clients
• Receipt and payment of funds directly to / from clients (not from third parties)
• Reporting suspicious transactions using a specific system
• Maintaining complete and accurate records educating and training all employees on the AML manual and regularly sharing updates

The firm’s stringent due diligence processes, which apply to individual and corporate clients alike, ensure that investments are made in keeping with each client’s specific profile and that accounts are protected by strict access regulations and documentation standards.

Due diligence processes are implemented across all business lines at EFG Hermes to ensure that its investment platforms are not used for illegal transactions. Potential clients are required to fill out a detailed questionnaire, and investor names are checked against international sanction lists like the Office of Foreign Asset Control and United Nations lists to protect the firm from entering into business with sanctioned individuals. Politically sensitive clients undergo a strict screening process, and their accounts are subjected to stringent requirements to ensure compliance with international best practices in all areas.

EFG Hermes has invested time and money into developing a disaster recovery and business continuity plan that will protect the Firm’s data and IT infrastructure from fires, natural disasters and other unforeseeable events. All our regional offices have business continuity policies and procedures for notification and recovery. The business continuity plan will enable full operation of all lines of business in the event of natural or manmade disasters including accidents, sabotage and burglaries. A special Crisis Management Team composed of senior management and a Business Risk Coordinator responsible for all internal communication are also in place to implement disaster recovery procedures in a smooth and efficient manner.

KSA Pillar III Disclosure 

For more information about EFG Hermes’ KSA Pillar III Disclosure, click here.

ESG Policy
Environmental, Social and Governance Policy Summary

The following is a summary of EFG Hermes’ ESG policy. The information contained here is intended for information purposes only and should not be relied on for completeness.

1. ESG Guidelines for Business Lines

1.1 Overview

As a leading responsible financial services corporation, EFG Hermes understands that ESG issues can affect investment performance and expose the Firm to potential investment risks. EFG Hermes believes it is important for its investment professionals to integrate ESG factors within their processes.

As a diversified financial institution with a range of services, the implementation of ESG considerations varies across EFG Hermes’ various business lines. Specific guidelines have been developed for the Private Equity, Asset Management, Investment Banking and Research business lines, due to the significant impact of ESG factors on their activities.

1.2 EFG Hermes’ ESG Guidelines

Private Equity

Private Equity must take ESG factors into account during all stages of the investment cycle, including the initial screening, due diligence, transaction structuring, investment agreement, monitoring and reporting stages.

All potential investments should be assigned an ESG risk rating after undergoing a risk assessment during the pre-investment screening phase. The ESG rating subsequently determines the level of ESG due diligence and whether external resources are required to support with the process. Projects with a high ESG risk rating require independent experts to develop focused impact assessments and mitigation recommendations. Funds should comply with the investment exclusion list outlined in EFG Hermes’ ESG Policy.

Asset Management

EFG Hermes believes that a proactive focus on ESG factors is one indication of a company’s commitment to best practices in corporate strategy and business model design. EFG Hermes Asset Management professionals must be proactive in integrating ESG into the due diligence component of the investment process. The analysis of ESG factors by Asset Management professionals is incorporated into the overall risk profile and valuation of prospective investments. Negative screening via the EFG Hermes Exclusion List is also be applied with respect to all potential investments.

Investment Banking

The investment banking team must take into account ESG considerations whenever an ESG issue might have a material impact on the financial performance of its transactions, namely M&A, equity capital markets and debt capital markets.

Research

The Research business line at EFG Hermes provides macroeconomic, equities and index research with a focus on MENA and frontier markets for clients. The Research team should offer an ESG overview to clients on material ESG risks and opportunities whenever this has an impact on the research analysis decision-making process or the company’s financial/stock performance.

1. Policy Statement

Wellbeing is one of the essential beliefs of EFG Hermes. Having this commitment in mind, the firm establishes this corporate health and safety policy. EFG Hermes believes that health and safety of our employees, visitors and customers is essential to our sustainable success. The Group’s commitment to the effective implementation of its Health and Safety Policy and related management systems will help the Group create a healthy and safe work environment.

2. Scope

The Health and Safety Policy must be observed across the entire EFG Hermes Group. This policy applies to Group offices and people who carry out work under the direction of the Group.

3. Purpose

The purpose of this policy is to ensure fulfillment of corporate and legal health and safety responsibilities by implementing and maintaining policies, procedures and practices to provide a healthy and safe environment for all employees, visitors and customers.

4. Commitments

The firm is committed to fulfilling all corporate and legal health and safety responsibilities by implementing and maintaining policies, procedures and practices that provide a healthy and safe environment for all employees, visitors and customers.

The Group will meet its commitment to health and safety by:

• Acknowledging legislative requirements and ensuring compliance as our minimum acceptable standard;
• Holding all levels of management accountable for the health, safety and wellbeing of people under their leadership;
• Promoting and encouraging a healthy and safe work environment;
• Conducting inspections to ensure that the working environment is healthy and safe;
• Ensuring that responsibilities for health and safety are effectively assigned and fulfilled at all levels of the group;
• Ensuring that decisions that affect health and safety are made transparently;
• Ensuring that adequate resources are provided to safeguard the health and safety of all employees, visitors and customers;
• Ensuring that all necessary information, instructions, training and supervision are provided to enable all employees, visitors and customers to work safely and carry out their duties and responsibilities in a way that aligns with the policy;
• Ensuring risk assessments are undertaken where appropriate;
• Ensuring that health and safety performance is regularly measured and monitored and that audits of health and safety are carried out at appropriate intervals;
• Managing accidents and incidents as well as seeking to mitigate risks to avoid reoccurrence;
• Ensuring adequate resources and expertise are provided for the implementation of this policy.

Commitment

EFG Hermes complies with the UN Guiding Principles on Business & Human Rights, acknowledges its corporate responsibility towards the principles articulated within the framework and ensures the principles are captured in all its policies and rules governing employees at EFG Hermes.

EFG Hermes is a signatory of the UN Principles for Responsible Investment, an active participant in the UN Global Compact and a Co‐Founder for the UN Global Compact Network Egypt.

Approach

The EFG Hermes Statement on Human and Labour Rights extends to all EFG Hermes employees in all locations.

EFG Hermes acknowledges the definition of human rights as rights inherent to all human beings, regardless of race, sex, nationality, ethnicity, language, religion, political beliefs, or any other status.

EFG Hermes complies with the laws and regulations of the countries it operates in. The firm is guided by international and local laws for human rights and labour standards ensuring compliance and adherence with these laws. Where the internal standards supersede what is mandated by law, we will always apply what provides enhancement to employees' rights and entitlements.

Commitments to Employees

EFG Hermes adopts policies and procedures that protect the basic human rights of employees, and hires individuals based on expertise and competence, ensuring equal opportunities, diversity of experience, background, and skills to ensure a diverse workforce. The firm is committed to providing working conditions that meet accepted health and safety standards, fair and equitable wages in line with job scope, generous health benefits, a workplace free of discrimination, harassment and fair disciplinary practices.

EFG Hermes does not tolerate human trafficking, modern slavery or child labour. The firm employs individuals recognized as adults by the law and on a purely voluntary basis.

EFG Hermes reviews and revises internal policies where and when relevant to ensure they are always sustainable and in tune with our employees' rights, and articulates these policies clearly in the Employee Handbook, which is accessible to all employees in all locations.

Commitments Expected from Customers, Clients and Vendors

EFG Hermes is committed to the highest standards of social responsibility, environmental protection and ethical conduct. In its efforts to become a sustainable company, EFG Hermes' Supplier Code of Conduct requires its suppliers to uphold the principles listed herein and with all applicable laws and regulations regarding labour and human rights, health and safety, environmental protection and ethical practices wherever they make products or perform services for EFG Hermes.

EFG Hermes believes all workers in our supply chain:

• deserve a fair and ethical workplace where the highest standard of human rights, dignity and respect are upheld.
• deserve a safe and healthy working environment where the highest standard of an employee’s wellbeing is upheld.
• expects its suppliers, in their capacity as active members in the community.
• to operate in accordance with environmentally responsible business practices.
• to always be ethical in every aspect of the business.

Commitments to Communities

EFG Hermes is committed to leveraging our financial expertise and capitalizing on our human talent to create sustainable value for our stakeholders and the communities we serve.

The EFG Hermes Foundation supports poverty alleviation, disease prevention and youth development. The Foundation focuses on achieving the maximum sustainable impact not only by investing our resources wisely, but also by proactively engaging the communities in each project. EFG Hermes Foundation collaborates with existing community leaders at early stages of project planning, fully involving them in decision‐making processes and assists people and institutions to overcome the financial, educational and health‐related challenges facing society.

Governance

EFG Hermes promotes ethical and behavioural standards among its employees. The EFG Hermes Code of Conduct clearly articulates the expected behaviour of employees. The Whistleblowing policy ensures employees can raise necessary business–related flags without fear of retribution. “Voice It” ensures employees have an avenue to voice concerns regarding anything that impacts them within the scope of the workplace, knowing that their suggestions, complaints and concerns will be dealt with confidentially, with respect, and in a timely manner.

EFG Hermes' commitments and policies apply to all employees in EFG Hermes's businesses and operations where we have management control and where permitted by national laws and regulations. In countries where local legislation conflicts with certain human rights, EFG Hermes strives to act in the spirit of these principles while respecting and adhering to local legislation.

EFG Hermes recognizes its responsibility to support the protection and advancement of human rights and to ensure that modern slavery and human trafficking and their associated outcomes, such as the laundering of illicit gains, do not take place within our sphere of influence. EFG Hermes has been a participant in the United Nations Global Compact (UNGC) since 2011 and became a signatory of the United Nations Principles for Responsible Investment (PRI) in 2018. EFG Hermes’ goal is to uphold the UNGC principles on human rights by engaging with stakeholders and committing to policies that minimize risk on human rights issues and improve living standards in the communities where it operates. Key areas of engagement are as follows.

Labour

EFG Hermes believes that protecting the rights of its employees is of paramount importance. In line with the UN Guiding Principles on Labour & Human Rights, EFG Hermes articulated two statements to complement its existing policies: A Statement on Human and Labour Rights affirming compliance with the laws and regulations of the countries we operate in and a Statement on Health and Safety which aims to fulfil all corporate and legal health and safety responsibilities and provide a healthy and safe environment for all employees, visitors and customers. Where our internal standards supersede what is mandated by law, we will always apply what enhances employee rights and entitlements. Where local laws may stand in the way of the application of our standards for human rights, we will ensure we comply with the laws while having conversations with the related organizations to find ways of ensuring adherence to our human rights standards.

Compliance and Risk Management

EFG Hermes believes that having sufficient information about our clients is the best way to minimize the Firm’s risk of being used for illicit activities such as the processing of funds gained from human trafficking or modern slavery. It also protects EFG Hermes against fraud and enables EFG Hermes to recognize suspicious activity. EFG Hermes anti-money laundering (AML) policy is based upon the strict adherence to the following procedures:

• The verification of the identity of new clients.
• The ongoing screening of clients against international sanctions lists and media sources.
• The receipt and payment of funds directly to / from the client (not from third parties).
• The reporting system of suspicious transactions.
• The maintenance of complete and accurate records.
• The ongoing training of all employees on the AML policies and procedures.

EFG Hermes’ thorough due diligence processes, which are applied to individual and corporate clients alike, ensure that no new businesses are undertaken prior to compliance scrutiny, verification and approval. Our due diligence processes are implemented across business lines at EFG Hermes to ensure that our investment platforms are not used for illegal transactions. Potential clients are required to fill out a detailed questionnaire, and investor names are checked against domestic and international sanctions lists like the Office of Foreign Assets Control (OFAC), European Union and United Nations lists to protect the Firm from entering into business with persona non grata individuals. Our due diligence documents are protected by strict access regulations and documentation standards.

EFG Hermes Anti-Fraud and Corruption Policy aims to educate EFG Hermes employees on fraud and corruption, set the framework for fraud prevention and anti-corruption actions, and define each employee’s role in fighting any potential fraud and corruption within EFG Hermes. This policy applies to all employees irrespective of their position with the Firm and should be read in conjunction with the EFG Hermes Code of Conduct. Compliance with this policy is mandatory and non-compliance may lead to disciplinary action including dismissal.

Minimum Wage

EFG Hermes ensures all salaries fulfil any legal minimum wage requirement in all the countries we operate in.

Training

EFG Hermes conducts five mandatory training courses for all employees on Anti-Money Laundering (AML), Anti-fraud, General Data Protection Regulation (GDPR), Cybersecurity, and Responsible Investment on an annual basis.

Supply Chain

EFG Hermes’ Supplier Code of Conduct requires its suppliers to uphold all applicable laws and regulations regarding labour and human rights, health and safety, environmental protection, and ethical practices wherever they make products or perform services for EFG Hermes. This Code goes beyond mere compliance with the law by drawing upon internationally recognized standards to advance social and environmental responsibility. Any violations of the code jeopardize the supplier’s business relationship with EFG Hermes.

EFG Hermes is also committed to mitigating the socio-economic factors that may trigger vulnerability to human trafficking or modern slavery. The International Labour Organization (ILO) identifies issues such as income shocks and poverty as the main economic factors that push individuals into forced labour. Other reasons contributing to risk and vulnerability include lack of education, illiteracy, gender and migration. EFG Hermes’ approach to tackling these root causes involves two lines of attack:

Corporate Social Responsibility

The EFG Hermes Foundation for Social Development is committed to implementing sustainable integrated development projects in rural areas to provide economic opportunities, education and decent living standards for those most vulnerable to forced labour.

Financial Inclusion

EFG Hermes is committed to serving underprivileged communities by offering comprehensive microfinance solutions to owners of very small businesses across Egypt who would otherwise have no access to growth capital or banking sector services and who might resort to abusive lending or indenture, both gateways to forced labour.

EFG Hermes will continue to combat modern slavery and human trafficking wherever appropriate within its sphere of influence and operation as part of its commitment to uphold human rights and to create a better world for future generations.