HSBC UK Bank plc’s action plan
Published 25 July 2024
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This publication is available at https://www.gov.uk/government/publications/directions-issued-to-hsbc-about-breaches-of-the-retail-banking-order/cad7245c-b860-4c06-ac8c-5c97b5b2e6e6
Clause 4: Appointment of an Independent Body and Initial Assurance Engagement
| Item | Action | Target completion date |
|---|---|---|
| 1 | Nominate an Independent Body for approval by the CMA | Within two calendar months of Directions being issued |
| 2 | Appoint Independent Body | Within 10 working days of receiving the CMA’s written approval of HSBC’s nomination |
Clause 5: Initial Assurance Engagement
| Item | Action | Target completion date |
|---|---|---|
| 3 | Commencement of the Initial Assurance Engagement following agreement of scope with the Independent Body and the CMA | No later than one calendar month of the Independent Body having been appointed by HSBC |
Clause 6: Outcomes of the Initial Assurance Engagement
| Item | Action | Target completion date |
|---|---|---|
| 4 | Issuance of Report by the Independent Body to the CMA after HSBC has been provided a reasonable opportunity to review and comment on the Report | Subject to agreement with the CMA |
Clause 7: Implementation of improvements, oversight and correction by the Independent Body
| Item | Action | Target completion date |
|---|---|---|
| 5 | Take Recommended Steps in the Report | In accordance with the Recommended Timescale in the Report issued by the Independent Body |
Clause 10: Annual reminders and statement of policy to Staff
| Item | Action | Target completion date |
|---|---|---|
| 6 | Provide annually to each Relevant Staff a specific and direct written reminder relating to Article 12 | Within 12 calendar months of the Directions being issued, and annually (for example: within 12 calendar months of the previous deployment) thereafter. |
| 7 | Provide annually to each Relevant Staff a specific and direct written reminder relating to Part 8 | Within 12 calendar months of the Directions being issued, and annually (for example: within 12 calendar months of the previous deployment) thereafter |
| 8 | Provide to the CMA the text of the written reminder relating to Article 12 | Within 10 working days of its provision to all Relevant Staff |
| 9 | Provide to the CMA the text of the written reminder relating to Part 8 | Within 10 working days of its provision to all Relevant Staff |
Clause 11: Annual staff training
| Item | Action | Target completion date |
|---|---|---|
| 10 | Ensure Relevant Staff receive training relating to Article 12 at least once annually | Within 12 calendar months of the Directions being issued, and annually (for example: within 12 calendar months of the previous deployment) thereafter. |
| 11 | Ensure Relevant Staff receive training relating to Part 8 at least once annually | Within 12 calendar months of the Directions being issued, and annually (for example: within 12 calendar months of the previous deployment) thereafter. |
This Action Plan may be subject to such change as requested by or agreed with the CMA from time to time.