Anti-Bribery Statement

This Anti Bribery Statement is issued by Cayman National Trust Company (Isle of Man) Limited, Cayman National Bank (Isle of Man) Limited and/or its subsidiaries – collectively known as “Cayman National Isle of Man or CNIOM”.

CNIOM is committed to carrying out its business in an ethical and honest manner. CNIOM takes a zero tolerance approach to bribery and corruption and is committed to acting professionally, fairly and with integrity in all business dealings and relationships. A culture of compliance with the Anti-Bribery & Corruption legislation has been embedded in the business as evidenced through the documentation of appropriate policies and procedures and the training provided to all staff and agents.

To ensure CNIOM is able to comply with the above statement it is expected that all Clients, Counter-parties, and Agents, hereafter known as “Observers” adhere to similar standards. In general terms all Observers are prohibited from offering, promising, giving, soliciting, or receiving a financial advantage or other benefit directly or indirectly. Specifically, all Observers in undertaking any business relationship with CNIOM confirm they:

1. will comply with all laws applicable relating to bribery and/or corruption (“Anti-Corruption Laws”)
2. will not directly or indirectly offer, give, authorise, solicit, or accept the giving of money or anything else of value to or from any person, whether a government official or private party, to obtain an improper advantage for CNIOM or any third party
3. will not secure the improper performance¹ of that person’s function or misuse of that person’s position for CNIOM or any third parties’ advantage
4. will not directly or indirectly offer, give, or approve the giving of money or anything else of value to any government official in his or her personal capacity, to facilitate or expedite government action or approvals
5. will not do, or omit to do, any act that will cause a third party to be in breach of the Anti-Corruption Laws
6. will not directly or indirectly authorise, offer, or give to any third party or their employee any gift, gratuity, service, favour, or anything else of value to influence or reward that employee or contractor
7. will promptly report any request or demand for any undue financial or other advantage of any kind received directly or indirectly by any officers, employees, consultants, affiliates, suppliers, agents, and subcontractors operating on their behalf
8. have and maintain throughout the term of the relationship, its own policies and/or procedures to help ensure its compliance with the Anti-Corruption Laws
9. will if requested to provide reasonable assistance in performing any activity related to the business relationship required by any government agency in any relevant jurisdiction for the purpose of compliance with the Anti-Corruption Laws.

All Observers confirm that neither they nor any of its principals, owners, directors, employees, or officers (as applicable):

1. has been convicted of any offence involving bribery, corruption, fraud, or dishonesty
2. has been or is the subject of any investigation, inquiry, or enforcement proceedings by any governmental, administrative, or regulatory body regarding any offence or alleged offence under the Anti-Corruption Laws
3. has been, or is listed by any government agency as being, debarred, suspended, proposed for suspension or debarment, or otherwise ineligible for participation in government procurement programs or government contracts.

Bribery does not simply refer to cash transactions or facilitation payments². Bribes can also include anything of value which may have influence. Hospitality, gifts, travel, or tickets for an event may be regarded as bribes. The bribe may also be indirect, for the benefit of a family member, charity, or political party.

CNIOM reserves the right to terminate any relationship with any client if we know or have reasonable grounds to suspect that the relationship or activity is, in any way, connected with or facilitates bribery or fraud or otherwise breaches our Anti-bribery & Corruption policy.

¹  Improper performance – where an individual does not act in good faith, impartially or a position of trust in performing an act.

²  Facilitation payments – usually small payments made to facilitate or expedite routine government action by public officials which will result in a benefit for the payer         

 March 2024