Our commitments

We aim to create an environment that is inclusive, diverse and that harnesses talent from all backgrounds. We are committed to operating in a fair and transparent manner, and we recognise our responsibilities to our clients, shareholders, employees and to the wider communities in which we work. The contents of this page highlight our responsibilities in key areas.

Anti-Money Laundering (AML) and Counter Terrorist Financing (CTF)

We are committed to:

  • Not being used by criminals to launder the proceeds of crime or by terrorists or sanctioned individuals and entities;
  • Protecting the integrity and stability of financial markets and national economies;
  • Complying with applicable legislation and regulations that work towards maintaining the integrity and stability of financial markets and national economies;
  • Helping combat terrorist financing;
  • Complying with economic and trade sanctions issued by relevant governments and organisations in every jurisdiction in which we operate and
  • Operating in line with the Wolfsberg Group’s Guidance on a Risk Based Approach for Money Laundering Risks.

To this end, the Group has implemented an AML control framework.

For more information please download the full document

Bribery and Corruption

We do not tolerate bribery, whether active or passive, or corrupt behaviour of any kind. We also expect the same from any third parties providing services for, or on behalf of, TP ICAP globally.

Our ABC Policy requires that employees:

  • Are prohibited from accepting, or offering a bribe in any form;
  • Must not accept or provide gifts or entertainment from suppliers during a tender process;
  • Must not solicit business by offering any form of bribe;
  • Must not offer employment, with the intention of receiving an improper business advantage;
  • Must not make facilitation payments; and
  • If suspicious that an act of bribery or corruption has been attempted or carried out, must report the matter immediately to Compliance, Legal or via the Whistle-blower hotline.

For more information please download the full document

Environment

The Company makes a commitment to:

  • Ensure compliance with all current environmental legislation
  • Seek to identify forthcoming environmental legislation to ensure timely compliance with such new legislation
  • Seek to improve its management of energy, emissions, use of resources and waste performance to prevent pollution and provide resources to support effective improvement opportunities
  • Monitor and report the Company’s annual energy usage and greenhouse gas emissions, as appropriate
  • Adopt sustainable procurement practices and work with customers and suppliers to improve energy performance throughout the Company’s supply chain
  • Review this statement and other relevant environmental documentation at regular intervals.

For more information please download the full document

Equality, Diversity and Discrimination

We are committed to promoting Equality and Diversity and encouraging a culture that actively values difference. It is recognised that employees from different backgrounds and experiences can bring valuable insights to the work environment and enhance the way we work. We aim to create a positive, cohesive and inclusive culture, where diversity is valued, respected and built upon.  The objective is to recruit and retain a diverse workforce that reflects the global markets in which we work.

We are committed to ensuring that it does not directly or indirectly discriminate against Employees, ex-Employees, or candidates on the basis of any Protected Characteristics actual, perceptive, or associative or through Personal Relationships. It will not tolerate any unlawful discrimination by its Employees. Nor will it tolerate any favouritism based on Personal Relationships (also known as Anti Nepotism).

We are also committed to ensuring that the backgrounds, beliefs and cultures of all our Employees are respected and to ensuring that the working environment is free from discrimination, harassment, bullying or any other conduct which causes an Employee’s suffering. The Group also is committed to encouraging diversity amongst its current workforce and candidates.

For more information please download the full document

Gender pay

We aim to create an environment that is inclusive and diverse, and harnesses talent from all backgrounds. We welcome the new regulations, and believe they have created an important discussion about diversity, both in business and wider society.

We are focused on addressing the challenge of diversity in our organisation which, like many financial services sector businesses, employs more men than women, particularly at senior levels and in higher-paid broking roles. 

For more information please download the full document

For more information please download the full document (2017 Data)

Human rights and freedom of association

We support fundamental principles of human rights across all our lines of business and in each region of the world in which we operate. TP ICAP’s respect for the protection and preservation of human rights is guided by the principles set forth in the United Nations Universal Declaration of Human Rights. In addition, we support the UN Guiding Principles on Business and Human Rights. This includes implementing our obligations.

We have a defined set of values that underpin everything we do. We are known in the market for our honesty, integrity and excellence in the provision of service to our clients. Above all else, we respect our clients and each other, without bias.

We comply with the applicable international and local legal requirements in the countries in which we operate.

For more information please download the full document

Modern Slavery and Human Trafficking Statement 2018

This statement sets out the steps we have taken in the last financial year to prevent modern slavery and human trafficking from taking place in our business and supply chain.

It is made pursuant to section 54(1) of the Modern Slavery Act 2015, for the financial year ending December 31 2018, as approved by the Board on 30 July 2019. Signed on the Board’s behalf by: Nicolas Breteau, Chief Executive Officer, TP ICAP plc and Robin Stewart, Chief Financial Officer, TP ICAP plc.

For more information please download the full document

Complaints Procedure

Purpose

This process provides information to Clients (“Clients” or “you” or “your”) of TP ICAP  (“TP ICAP” or “we” or “us” or “our”) who wish to register a complaint.

We value our relationship with our Clients and it’s important that we can help resolve any issues you may have. That’s why we are committed to supporting your experience in a way which is fair, clear and not misleading. Therefore we encourage you to let us know if you are not satisfied with any of the services or products that we provide. If you have a complaint about any of our services, please share your concerns right away so we can help you and resolve your complaint as quickly as possible.

Scope

This process applies to any Client of TP ICAP who is not satisfied with the service provided in our capacity as an FCA regulated institution. If an order has been sent to TP ICAP for execution via an affiliated TP ICAP entity, you should contact the relevant TP ICAP affiliate who will liaise with TP ICAP on your behalf.

For more information please download the full document

Procurement and Modern Slavery

With over 7000 companies from over 28 countries supplying us we take the sustainability of our supply chain and procurement exceptionally seriously. We apply a set of standards to our suppliers through our Supplier Code of Conduct. In order to do business with us, our suppliers must accept responsibility to be held accountable to our Supplier Code of Conduct. Any new supplier who is being on boarded must attest that they meet those standards. Where suppliers fail to meet our expectations, we work to remediate gaps

We also take our obligations under the Modern Slavery Act (UK) extremely seriously. Any new supplier needs to declare that they strictly adhere to this Act. In 2017 we conducted an initial analysis of our top 30 direct suppliers concluding that they are all located in the US and EMEA and are, on balance, viewed as low risk. Many of our suppliers have comprehensive policies related to modern slavery.

As a first step towards gaining a better understanding of our supply chain, we wrote to our top 30 suppliers, communicating our principles for modern slavery and asking for information about their policies and processes for tackling forced labour and human trafficking.

To raise awareness of the risks of modern slavery and human trafficking in our business and in our supply chains, we provided specific modern slavery training to all employees who work directly with our suppliers in 2017.

For more information please download the full document

Tax strategy

The Group is committed to complying with tax laws in a responsible manner and to having open and constructive relationships with tax authorities wherever we operate.

  • Ensuring the tax strategy is consistent with the Group’s overall strategy, its approach to risk, and the Group’s core values of Honesty, Integrity, Respect and Excellence;
  • Applying professional diligence and care in the management of all risks associated with tax matters, and ensuring appropriate governance and assurance procedures are in place;
  • Paying the right amount of tax required under the laws and regulations of the jurisdictions in which the Group operates; and
  • Fostering constructive, professional and transparent relationships with tax authorities.

For more information please download the full document

Whistleblowing

The Board is committed to maintaining the highest standards of honesty, openness and accountability and recognises that all those who work with or within the Group have an important role to play in achieving this goal.

We take protecting our colleagues, customers and business very seriously. However, like any major organisation, there are occasions where we face the risk of things going wrong, or we are unaware of malpractice taking place.

To ensure we are aware of any wrongdoing we provide a confidential and secure service that enables our colleagues, suppliers and their staff to raise concerns.

We have global coverage through our whistleblowing policies, which applies to all entities within the group.

The Board treats all malpractice and/or misconduct with the utmost importance, whether it is committed by senior managers, staff, suppliers or contractors.

For more information please download the full document

Women in Finance Commitment

At TP ICAP, we aim to create an environment that is inclusive, diverse and that harnesses talent from all backgrounds. ‘Include’ is the third pillar of our ‘A Voice For All’ corporate responsibility strategy and is about building the diverse and skilled workforce we need for the future. We are committed to improving levels of gender, ethnic and socio-economic diversity across the business and ensuring all our employees have a voice.  This is why we’ve signed the Women in Finance Charter.

The Women in Finance Charter reflects the government’s aspiration to see gender balance at all levels across financial services organisations. We agree a balanced workforce is good for business – it is good for our clients, our shareholders and – most importantly – our employees.

For more information please download the full document

    For more information on TP ICAP’s individual businesses, please visit:

  • Tullett prebon
  • ICAP
  • PVM