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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.
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:
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
EFG Hermes is a premiere financial services corporation that offers diverse investment banking
including securities brokerage, investment banking, asset management and private equity.
As responsible investment is part of EFG Hermes’ corporate strategy, EFG Hermes is committed to integrating Environmental, Social and Governance principles into its investment approach and practice, wherever applicable.
EFG Hermes sees engagement with investee companies as a key aspect of ESG integration as it enables the proactive
management of ESG factors. It is through supportive and constructive dialogue with the management of investee
companies that EFG Hermes can exercise its stewardship responsibilities and encourage organisational change where
warranted. We continually seek to exercise the highest standards of stewardship across all our investment activity
and as such we draw on internationally accepted best practice principles, including of the revised UK Stewardship
Code (2020), to guide our approach.
EFG Hermes believes that our investment professionals are in the best position to evaluate the potential impact that ESG issues or the outcome of a given proposal will have on long-term shareholder value. As such, responsibility for our engagement activities rests with our investment professionals, and they are fully integrated into our investment processes. Thus, our engagements focus on issues that could have a material financial impact with priority given to the largest holdings of a particular strategy and/or investments facing a material ESG concern, as determined by investment professionals and the outcomes of the respective ESG Scorecard.
In regard to voting practices, EFG Hermes will exercise its ownership rights by voting at company meetings. The voting decision is made with the objective to reduce material ESG risks while protecting the best interest of investors. When voting is sub-contracted, then the respective business line shall encourage the sub-contractor to adopt voting practices that help reduce ESG risks.
Training on sustainability, including ESG factors, should be provided to all EFG Hermes staff, across all business
lines and supporting functions on an annual basis.
Additional advanced training, with a focus on ESG integration, should be provided to select investment professionals.
In line with the UNPRI requirements for reporting and the Egyptian Exchange (EGX) model guidance for reporting on ESG performance, EFG Hermes aims to be transparent about its ESG activities and will make publicly available the following information:
As part of EFG Hermes’ commitment to the successful integration of this ESG Policy, an ESG governance framework has been developed. The ESG Policy’s governance framework is summarised below.
|ESG policy governance||Relevant department||Governance responsibilities|
|ESG Policy approver||Board of Directors||
|ESG Policy owner||CSR department||
|ESG Policy implementation||Executive Committee||
An overview on the sustainability frameworks that can be adopted to improve sustainability performance is provided below. This list is only indicative and not comprehensive. It shall be updated regularly by the CSR department.
|BREEAM||Building Research Establishment Environmental Assessment Methodology|
|BS 8903||Guide for sustainable supply chain and procurement|
|Carbon Disclosure Project||A voluntary based organisation and mechanism to help organisations report on their carbon emissions and develop mitigation strategies|
|Equator Principles||A risk management framework for financial institutions to assist in the assessment of environmental and social risks of project financing|
|Global Sustainability Assessment System (GSAS)||Green building certification system developed by the Gulf Cooperative Council|
|GRI Standards||GRI is an international independent organisation that helps businesses, governments and other organizations understand and communicate the impact of business on critical sustainability issues such as climate change, human rights, corruption and many others|
|Integrated Reporting||A concept for institutional reporting that combines financial with non-financial (i.e. environmental, social and governance) disclosures|
|LEED||Leadership in Energy & Environmental Design|
|Sustainable Development Goals||UN-sponsored set of 17 aspirational sustainable development goals developed to provide guidance to UN members, the private sector and non-governmental organisations|
|SSEI||Peer-to-peer learning platform to explore how exchanges, in collaboration with investors, regulators, companies can improve corporate transparency and performance on ESG investment|
|UNGC||United Nations initiative to encourage businesses to adopt universal sustainability principles in the areas of human rights, labour, the environment and anti-corruption|
|UNPRI||UN-backed framework for investors to assist in the implementation of responsible investment criteria in investment decision making|
An overview on the management systems that can be adopted to improve sustainability performance is provided below. This list is only indicative and not comprehensive. It shall be updated regularly by the CSR department.
|ISO 9001||Quality Management System ISO|
|ISO 14001||Environmental Management Systems|
|ISO 50001||Energy Management ISO|
|OHSAS||Occupational Health and Safety Management Systems|
EFG Hermes‘ Exclusion criteria seek to screen investments on three levels:
ESG factors and issues may vary significantly between different companies, industry sectors, and geographical regions. The following non-exhaustive list provides some examples of potential ESG issues that EFG Hermes may consider, where material and relevant to the companies assessed for potential investment.
|Climate change policy and strategy||Community relations and support||Accounting and disclosure|
|Ecosystems, biodiversity, and habitat protection||Customer satisfaction||Auditor independence|
|Environmental impact and related risks||Employee training and development||Board structure and independence|
|Energy consumption and efficiency||Employee compensation and benefits||Business ethics and integrity|
|Greenhouse gas emissions||Health, safety and wellbeing||Compensation and remuneration policies|
|Pollution to air, land and/or water||Human rights||Data protection and privacy|
|Pollution to air, land and/or water||Labour standards and practice||Management protocols|
|Waste management and recycling||Product/services responsibility and innovation||Government relations|
|Water management||Staff recruitment and retention||Risk management|
|Supply chain management||Shareholder rights|
|Transparency and accountability||Transparency and accountability|
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.
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.
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.
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:
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.
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:
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.
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.
Climate change is perhaps the most significant threat facing our planet today. It poses severe threats to food security, coastal and rural communities, and economies as a whole. Nowhere is this more apparent than in Egypt, where the Nile Delta—the country’s fertile breadbasket—is facing water scarcity, increased soil salinity and rising sea levels. Economic sectors across the country, from agriculture and fishing to tourism and manufacturing, are all being forced to adjust to dwindling resources and harsh new realities. Not to mention the toll on human health and wellbeing.
In 2016, world leaders came together to ratify the Paris Agreement, a pact sponsored by the United Nations to unite countries in the fight against climate change. A call to action was issued for governments, business leaders, investors and communities to forge new partnerships to curb greenhouse gas emissions and limit global warming.
EFG Hermes believes it is vital for leading financial institutions to make a firm commitment to the sustainable development goals and to the support of climate change mitigation efforts. Investors around the globe are increasingly aware that environmental risk has become a major factor affecting the future of their investments. As the foremost provider of financial solutions for retail, high-net-worth and institutional clients across MENA and Frontier Emerging Markets (FEM), EFG Hermes recognizes its influence and role in minimizing portfolio exposure to environmental risk while also identifying opportunities that actively contribute to reducing emissions and shifting to a low-carbon global economy.
Since 2011, EFG Hermes has been on a resolute journey to integrate sustainability into all aspects of its operation and corporate culture. From joining the United Nations Global Compact (UNGC) to becoming a signatory to the United Nations Principles for Responsible Investment, we have made it a priority to take purposeful and deliberate steps to continuously strengthen our commitment to sustainability in tandem with corporate growth. The time has now come to turn our attention more fully to climate change issues. The following highlights our key areas of engagement:
EFG Hermes is committed to expanding its environment, social and governance (ESG) policy, adopted in 2017, to more specifically address climate change considerations.
EFG Hermes is committed to expanding its responsible investments, particularly in the area of clean and renewable energy, while at the same time continuing to offer attractive returns for shareholders and investors. Concomitantly, we are introducing training modules to improve the ability of our investment professionals to recognize climate risk and identify sustainable market opportunities. We are also committed to helping our clients limit their exposure to environmental risk utilizing our award-winning research capabilities and our in-depth knowledge of on-the-ground conditions in environmentally vulnerable FEMs.
EFG Hermes is committed to continuing to minimize our carbon footprint across our premises worldwide and to expanding our initiatives to conserve energy, minimize waste and increase the efficiency of our supply chain.
EFG Hermes is committed to encouraging and promoting the acceptance and implementation of climate change measures within the investment industry by engaging with peers, government agencies and the wider community through several forums. On an internal level, EFG Hermes continues to engage with employees to prioritize climate change considerations.
EFG Hermes, through its philanthropic arm, the EFG Hermes Foundation for Social Development, is committed to incorporating climate change mitigation measures in its integrated development initiatives in rural Egypt and elsewhere.
EFG Hermes realizes that a commitment to climate change mitigation brings with it profound challenges and responsibilities, but we cannot afford to be complacent. We have responsibilities towards our shareholders, towards the communities where we do business, and, most of all, towards future generations. There is still much to do, but we look forward to meeting each challenge head-on
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.
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:
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.
EFG Hermes ensures all salaries fulfil any legal minimum wage requirement in all the countries we operate in.
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.
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.
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.