We believe that protecting the integrity of the financial system is a core responsibility of banks. At Credit Suisse, we are committed to complying with all applicable financial crime laws and regulations in the jurisdictions in which we operate. We have established global policies and procedures in an effort to achieve more robust and consistent standards of compliance, including in relation to politically exposed persons (PEP), the prevention of money laundering and terrorist financing, bribery and corruption, as well as the adherence to applicable economic and trade sanctions laws. In an effort to avoid direct and indirect involvement in such practices, we are committed to only doing business with clients and third parties who meet and adhere to our standards. We have a wide range of policies, procedures and internal controls, with requirements such as the evaluation of third parties who conduct business for or on behalf of Credit Suisse and dedicated controls for our employees related to gifts and entertainment, employment opportunities, and charitable contributions. Credit Suisse maintains active participation in the Wolfsberg Group, a reflection of our continued commitment to understand the latest financial crime risks and controls, while also staying abreast of important regulatory and market developments. We expect threats related to the global financial system to grow and change, and we are actively developing and implementing risk management capabilities to combat financial crime. In addition, employees must ensure that transactions that may affect the reputation of Credit Suisse undergo our bank-wide standardized Reputational Risk Review Process. Employees are required to regularly complete mandatory online training courses on topics ranging from the prevention of money laundering, terrorist financing and corruption to compliance with economic sanctions.

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Credit Suisse manages improper employee behavior and employee breaches through global disciplinary and escalation processes across three lines of defense. Our disciplinary process provides a structure that is designed to confirm that the bank’s standards of professional conduct (including our C&E Standards and Code of Conduct), policies and procedures (including on the prevention of money laundering, terrorist financing and bribery and corruption), and external laws, rules, regulations, standards and principles are adhered to and enforced on an ongoing basis, subject to local differences. Our Conduct and Ethics Boards provide an independent review of disciplinary matters and, where necessary, participate in or challenge disciplinary recommendations that may impact employee compensation and promotion opportunities. Additionally, employees have a responsibility to report concerns of potential legal, regulatory or ethical misconduct in a timely manner – in the first instance to their line managers or to Compliance. Employees worldwide also have the option of calling our Integrity Hotline or using our secure web-based solution, where they can report such issues anonymously, where permitted by local law.