Statement of

Business Principles

and Code of Ethics

HSBC North America Holdings Inc.

For US Employees

August 2022

Table of contents

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Protecting Company Assets 14

Doing the Right Thing for Our Customers 19

Fair Competition 19

Support for Our Community 19

Dear Colleagues,

Throughout its history, HSBC has strived to connect our clients to the rest of the world, and provide

the best possible financial products, services and advice. We enable businesses to thrive and

economies to prosper, helping our clients to realize their financial ambitions with a global connectivity

employees valuing dierence, succeeding together, taking responsibility and getting it done—our four

values. Adhering to these values will help us achieve our purpose: Opening up a world of opportunity

for our clients. At its most literal, this is a statement about the power of our international network to

connect people, ideas and capital across borders. And it reminds us that our unique blend of services

and expertise can help us create opportunities for our customers that they can’t find anywhere else.

But again, how we do business is as important as the business we do. To help guide employees in

their work, we have collected here important statements regarding these values, and how we put

them into practice. The principles set forth in our Charter and this Code of Ethics reinforce our purpose

and our values as a company, and the behavior that we encourage in all employees through initiatives

like ‘At Our Best.’ These principles help define how we act as individuals and collectively as an

this Code should be viewed as the baseline of expected behavior at HSBC.

Taking ownership for doing the right thing means asking the right questions and speaking up if you

have concerns or are unsure of what to do. This document provides both guidance for when you

should speak up and contacts to help you do so. I am personally committed to ensuring that you have

a safe and supportive environment to report any possible violations of policy.

Thank you for taking the time to review this document carefully and for your ongoing commitment to

making HSBC the world’s leading international bank, and a place where we are all very proud to work.

Michael M Roberts

CEO, US and Americas

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We were born speaking dierent languages. We were founded on the strength of dierent experiences,

attributes and voices; they are integral to who we are and how we work. The greater our empathy and

diversity, the better we reflect the worlds of our customers and communities – and the better we can

serve them. We champion inclusivity. We listen. We remove barriers and we seek out views dierent

from our own.

What we do has a real impact on people’s lives, communities and the planet. We take this responsibility

seriously. We set ourselves high standards and are each accountable for our actions. We always use

good judgment. If something doesn’t feel right, we speak up and act. We build for tomorrow, today.

We succeed only by taking the long view, by focusing on the sustainable interests of our customers,

investors, and the planet we all share.

We create value for our customers and investors by always moving forward and making things happen.

We’re entrepreneurial: we try new things, we learn and improve, and we take smart risks. We’re dynamic:

we reject mediocrity. We move at pace. We’re decisive: we make clear choices and take bold actions.

And we keep our word: we always do what we promise.

network opens us up to many dierent cultures and perspectives, and valuing and respecting one

Our industry has a growing list of rules and regulations. Our aim is to meet both the spirit and the letter of

the law — to do what is right, not only what is legal. Our own policies often go further than the minimum

required by law. Some are very specific, telling us what we must do and when. Others focus on the

outcomes we should deliver. These policies outline principles to be applied, not just processes to be

followed. They require us to use our judgment.

HSBC’s business principles direct how our business strategy is executed. They set the standard for

how we make commercial decisions. They underpin the business conduct of all HSBC employees and,

of our actions, make prudent decisions

intensity, prioritize, simplify

transition to a net zero carbon economy. Support diversity and strengthen the bank’s responsibility

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market practice and to adhere to the values of

HSBC Group. We believe that a strong culture

of compliance is essential to our reputation,

sustainability and success. Our standards

of conduct apply not only in the workplace,

but also to all interactions with colleagues,

clients, regulators, vendors, contractors and

customers whether in the work environment;

at social or corporate events; or using electronic

communications, technology or social media

conduct, to act with honesty and integrity

towards our customers, suppliers, regulators, the

public and each other; protect the Group and act

in its best interest, by adhering to our Statement

of Business Principles and Code of Ethics. Every

employee must demonstrate their commitment

to our culture of compliance by adhering to the

letter and spirit of the law, and applicable policies

and procedures. If any irregularities do arise, they

will be escalated and resolved promptly, and

our Charter explains, most of the decisions we

make each day are straightforward, but some

are not. This Code of Ethics does not address all

circumstances that could arise. It is an additional

guidance to assist you, rather than a complete set

of rules and regulations for all situations. Should

there be any question as to the interpretation

of a particular principle or how best to handle

a situation, you should refer your question to

your supervisor or department head, Human

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financing, corruption, and any other form of

both US and other countries’ laws regarding

sanctions and other embargoes. We are

fully supportive of the US Department of the

Treasury’s Oce of Foreign Asset Control and

its eorts to combat illicit financial transactions.

We are all responsible for being aware of

relevant sanctions and embargoes imposed

by any country or the international community

which may impact your work at HSBC.

boycotts. The law on this issue is complex and

the penalties for violations are extensive, so

employees must report any activity related to

potential violations of anti-boycott laws to a

supervisor immediately.

HSBC has a zero tolerance approach toward

bribery and corruption and requires compliance

with anti-bribery and corruption laws in all

markets and jurisdictions in which it operates.

an internship, paid or unpaid, for a client’s family

member, etc. In addition, employees must ensure

that any third parties engaged by HSBC to act

on HSBC’s behalf comply with these principles.

HSBC also prohibits the making of facilitation

The improper or personal use of nonpublic

information concerning HSBC or its aliates,

customers or suppliers is a violation of HSBC’s

communicating such information to others. Laws,

regulations and HSBC policies also apply to and

restrict employees’ personal investments and

any investment over which they have influence

or provide advice. Employees are prohibited

from using, sharing or trading on nonpublic

information concerning HSBC or its aliates,

customers or suppliers. Employees with access

to this information must guard it carefully,

following HSBC’s guidelines for handling sensitive

disclosure of information would be “viewed by

the reasonable investor as having significantly

altered the ‘total mix’ of information made

available”; or, the disclosure of the information is

“reasonably certain to have a substantial eect

on the market price of the security” is considered

material information.

Lotteries, Raes,

Solicitation and Fundraising

HSBC employees must make every eort to

remains compliant with this law and understand

where risks can potentially occur.

Under this law, a lottery is defined as three or more

persons, advancing money or credit for a chance to

win a prize. The law prohibits national banks from

dealing in lottery tickets or participating in a lottery/

rae, which includes announcing, advertising or

promoting a lottery/ rae using any of our facilities

or systems. As a result, all U.S facilities may not

allow lottery/rae tickets to be sold on premises

causes and fundraising in all forms is restricted in

the US, and prohibited including on or with HSBC

properties and systems (posted fliers, laptops, team

meetings, etc.), instant messaging, or any other

device or application. No individual should share

fundraising appeals via email or other sources.

These fundraising restrictions also apply to

other individual. Even a well intentioned

fundraising appeal from a nonprofit is

restricted, so it’s a ‘best practice’ to

simply delete any appeal which you

may receive. See the US Fundraising,

Solicitation and Distribution Policy found

on the US Corporate Sustainability page

for more details.

Taxes

HSBC is fully committed to complying

Subject to certain regulatory exceptions,

employees are required to cooperate with

any legitimate and lawful government or

internal investigation. They must tell the

full, complete truth in such inquiries and

are expected to provide the maximum

level of cooperation by, among other

things, being available to those conducting

the investigation and by providing any

materials requested by those conducting

investigation, the Company will attempt to

protect the privacy of both the Complainant

and the Subject of the investigation.

HSBC prohibits retaliation against employees

who raise complaints or participate in

regarding whether an inquiry is legitimate

or lawful, they should contact their Legal or

Compliance teams.

Anti-Retaliation

HSBC relies on the cooperation and support of

individuals who have witnessed or experienced

possible incidents of alleged wrongdoing or

violation of Company policy to report these

Managers and decision makers are

reminded to hire, assess and reward

employees strictly on the merit of

non-public supervisory information from

connected persons. All candidates will

be required to disclose whether they are

connected persons.

Because HSBC respects each employee’s

private life, social conscience and personal

beliefs, managers may not require

employees to perform personal tasks nor

attempt to coerce employees into supporting

any particular public issue, social cause or

confidential information, as well as our

customer relationships and other business

interests is of foremost importance

to HSBC. With these goals in mind,

employees who are in Group Executive,

General Manager, Managing Director

and GCB 3 roles and GBM employees

at all Global Career Band levels are

subject to certain notice periods and non-

Part of each employee’s responsibilities is to

act in a way that contributes to the financial

success of HSBC, enhances its reputation

and fosters our customer relationships. This

requires every employee to look after their own

private financial interests in such a way that

they are not in conflict with, and do not derive

or advantage whether or not they obtained

this gain or advantage at HSBC’s expense or

at the expense of any entity of HSBC or its

customers. This would also apply to a family

member or friend of an employee.

In addition, personal transactions in HSBC

accounts can impact its business interests,

reputation and compliance with regulatory

obligations. Therefore, every employee must

be sure to comply with all applicable laws even

to conduct personal business transactions.

When an actual or potential conflict of interest

confronts an employee they must disclose

its existence promptly to their immediate

supervisor or Compliance ocer.

A relative (whether by blood, adoption, or by

or appearance of favoritism in the hiring,

management or promotion of relatives.

An employee who may have a conflict is

obligated to notify and seek approval in writing

from their direct manager if working with,

or anyone else that may create a conflict for

the employee. The manager is expected to

apply the principles and exceptions set forth

above, and should seek guidance from senior

management and a representative from

discrimination against applicants and

“position of authority” (however temporary

or informal) must disclose to their direct

supervisor and a Human Resources

professional the existence of any relationship

with a co-worker, contract worker,

consultant, or service provider, that has

progressed beyond a platonic friendship. This

disclosure will enable HSBC to determine

whether a conflict of interest exists and

endeavor to find a solution to eliminate the

between employees, employees should

consult the Global: US Anti-Bullying &

Harassment Code.

If an employee marries someone in their

department, depending on a number of factors,

such as the reporting relationships involved,

one of the employees may be involuntarily

transferred to another department.

developed by employees of HSBC while

employed by HSBC is the exclusive property of

HSBC and employees may not utilize any such

property for personal gain or the personal gain

of family, friends or others.

information concerning any of these entities,