Zempler Bank

The Board and management of Zempler Bank believe in fair competition and are committed to carrying out our business in a way that ensures compliance with competition law, as well as supporting initiatives that drive competition in the financial services industry.

This statement sets out this commitment and describes how we will make sure that it is met as we carry out our day to day business.

What do we mean by competition law compliance?

Competition law seeks to prevent conduct that distorts competition in the market by prohibiting anti-competitive agreements and abusive behaviour by companies in dominant positions. Competition law is designed to enable competition and to ensure that the competitive process is free and fair for the benefit of customers and suppliers.

Zempler Bank recognises the serious consequences of competition law breaches and commits to taking a zero-tolerance approach to behaviour that breaches competition law, including:

• Entering into agreements or understandings with competitors to fix prices.
• Entering into agreements with competitors to limit competition in a market (for example agreeing with competitors to allocate markets, territories, bidding opportunities or customers).
• Participating in any exchange with competitors of commercially sensitive information (e.g. any information that could give an insight into future strategy).

In addition, Zempler Bank will continue to focus on pro-competitive outcomes in its day to day activities. It will continue to deliver and support initiatives that help drive new markets, new sectors, greater payment access choice, and create an industry environment where banks and non-banks can equally compete on a level playing field, creating positive outcomes that drive more choice for all participants, in order to support UK consumers and businesses with better payment and banking products and solutions.

What compliance measures have we put in place?

Zempler Bank has put in place a comprehensive competition law compliance programme to ensure that all staff at Zempler Bank are aware of and adhere to their responsibilities under competition law. This comprises a competition policy and a programme of regular training activities to guard against rule breaches, educate employees about how these laws apply to the jobs they do and inform them of ways to report concerns about potential anti-competitive practices. This training is mandatory for all employees but is also carried out at multiple levels with more intensive training for Board, senior management and those working in roles in which competition issues are more likely to arise. Our competition policy is reviewed annually and contains guidelines and compliance procedures for all employees and the Board.

The Board supported and approved this statement. We review this policy annually.