UK Governance

The Board of Dir­ect­ors of SG Kleinwort Hambros Bank Limited (“the Board” or “Kleinwort Hambros”) is re­spons­ible for the over­all stra­tegic dir­ec­tion and regularly as­sesses stra­tegic and fin­an­cial plans to  ensure the firm (“Kleinwort Hambros”) is com­pet­it­ively po­s­i­tioned. The Board has overall responsibility for leading and controlling the company and is accountable to its Stakeholders for financial and operational performance.

The Board and its sub committees’ responsibilities are defined in their Terms of Reference.  The Board has established a corporate governance structure which ensures the oversight and monitoring of services, activities, products and operations offered or provided remain within the risk tolerance as set out in the firm’s Risk Appetite Framework, which is approved by the Board.  The firm’s governance arrangements include oversight and assessment of: the adequacy and the implementation of the firm’s strategic objectives in the provision of investment services; the skills, knowledge and expertise of relevant personnel; the adequacy of all policies including those relating to the provision of services, communications and disclosure to clients;  Remuneration, to ensure all personnel engaged in the provision of services to our clients are assessed for good conduct and the responsible and fair treatment of our clients, aiming to avoid conflicts of interest wherever possible.

Please see the link below for further information on Remuneration at Kleinwort Hambros: https://www.kleinworthambros.com/en/important-information/remuneration-disclosure/

The Board of Directors assesses the arrangements in place to take appropriate steps, including through regular stress testing, to identify and address any deficiencies throughout the firm.

Conflicts of interest

The Board of Directors oversees and is accountable for the implementation of governance arrangements that ensure effective and prudent management of the firm, including the segregation of duties in Kleinwort Hambros and the prevention of conflicts of interest, in a manner that promotes the integrity of the market and the interests of our clients.

For further information and how conflicts of interest are identified, prevented or managed at Kleinwort Hambros, please see the below link:

https://www.kleinworthambros.com/en/important-information/conflicts-interest/

Skills and Expertise of the Board and Management Body 

The Board and all Senior management function holders, including within the management body (“ExCo”), are assessed as to their skills, knowledge and diversity and reputation prior to appointment,  as part of Nominations committee process, and on an ongoing basis, as part of an annual Board assessment and other in-house appraisals to ensure competency as well as fitness and propriety. Members of the Board receive on-going training which is tracked and reported to the Board.  All Senior Manager function holders are subject to training requirements and skills or knowledge gaps are assessed on an ongoing basis, as are those of all other members of the Board.  Non-Executive Directors are selected and assessed for their ability to ensure adequate challenge of the decisions of senior management and to effectively oversee and monitor management decision-making.  All directorships (whether internal or external) and external positions held by members of the Board are subject to assessment and approval by the Board which includes appraising time commitments as well as any potential conflicts of interest.