Anti-Bribery & Corruption Policy

Anti-Bribery and Corruption Policy

Introduction

Nuevo Partners does not tolerate bribery, whether active or passive, or corrupt behavior of any kind, and expect the same from any third parties providing services for or to our company globally. Nuevo Partners operates in multiple jurisdictions with offices in Houston and London.  As such the Nuevo Partners Global Anti-Bribery and Corruption (ABC) Policy applies to all Nuevo Partners entities, subsidiaries or affiliates.

This policy is designed to fight bribery and corruption and to comply with the UK Bribery Act 2010, the US Foreign Corrupt Practices Act 1977, and other applicable legislation and regulations in all jurisdictions in which Nuevo Partners operates.

Definitions

Bribe

  • A bribe is an offer of “anything of value” to a person in exchange for that person to provide an undue business advantage or other advantage. The offer, payment or promise of anything of value does not have to be successful in order for it to be considered a bribe.

Inducement

  • An inducement is the offer of “anything of value” which persuades or incentivises someone to give another an unfair business advantage.  

Corruption

  • Corruption is the abuse of power or breach of duty for personal/commercial gain. To this end, bribery is a specific form of corruption, and such activity undermines social and economic development

FCA Requirements

The FCA requires Firms to establish and maintain effective systems and controls to mitigate financial crime risk which includes bribery and corruption. The FCA’s financial crime rules can be found in SYSC 3.2.6R and SYSC 6.1.1R.

NFA Requirements

The NFA requires that “Members and Associates shall observe high standards of commercial honor and just and equitable principles of trade in the conduct of their commodity futures business and swaps business.” (NFA Rule 2-4)

Nuevo Partners requires that all employees: 

  • Are prohibited from accepting, or offering a bribe in any form;
  • Must not accept or provide “anything of value” with the purpose of persuading or incentivizing an unfair business advantage;
  • Must disclose any potential Conflicts of Interest, both at time of hiring and as they may arise;
  • Must ensure risk-based due diligence is conducted on all third-party relationships, in line with the company’s Third-Party Service Provider Policy
  • Must seek to prevent Gifts and Entertainment being used as a subterfuge for bribery;
  • Must be aware of the inducement risk of Charitable Giving and seek permission from management before engaging in Charitable Giving as a representative of the firm;   
  • Must not make Facilitation Payments unless there is a perceived threat to life, limb or liberty. A Facilitation (or “grease”) Payment is an unofficial payment that secures or speeds up the performance of a routine or necessary action where an employee already has a legal or other entitlement to the action.
  • Must periodically complete compliance training covering Anti-Money Laundering and Anti-Bribery and Corruption;
  • Must report any suspicions of bribery and corruption to management and/or the appropriate regulatory authorities.

Reporting Responsibility

All Nuevo Partners employees have a personal and ethical responsibility to abide by the company’s Global Anti-Bribery and Corruption Policy and to report any suspicions of possible bribery and corruption to their location’s Branch Manager or the Managing Partner.  

A material breach of the Global Anti-Bribery and Corruption Policy may be reported to the appropriate legal and regulatory authorities. 

This policy applies to both Nuevo Partners LLP and Nuevo Partners UK LLP.