H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
EMPLOYMENT HANDBOOK
OF
SILICON VALLEY BANK
Complying with the rules and principles set out in this Employment Handbook is a
condition of employment or service to Silicon Valley Bank (SVB). We ask that you read
this document carefully, considering the spirit, as well as the letter of the policies laid out
here. Since even the mere appearance of unethical behavior may be damaging to you and
to SVB, we strongly encourage you to interpret this code in the broadest possible sense
and apply it in everything you do. The „employee‟ in this Employment Handbook refers
to the employee dispatched by FESCO to service for the Representative Office of Silicon
Valley Bank. No employment relationship is established between the employee and the
Representative Office of Silicon Valley Bank according to relevant Chinese laws and
regulations.
I acknowledge that I have received a copy of this Employment Handbook:
___________________
Name:
Date:
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
VALUES AND STANDARDS
DRIVEN
We hire motivated and talented people who strive to do their best. But drive is not a
measure of hours worked. Instead, drive is about urgent actions that bring results to the
fast-changing market we serve. It's about understanding the evolution of our clients‟
financial needs. And it‟s about taking ownership over our efforts to help entrepreneurs
succeed.
ENTERPRISING
Our employees are creative, intelligent, energetic and take the initiative. We are
constantly striving to innovate the business of banking. We are always willing to embrace
change as an avenue for long-term growth. And we always endeavour to identify unique
solutions that can better help our clients.
DEDICATED
We act without reservation to support, to assist, to aid, and to team with our co-workers
and clients. We empathize with the challenges they face in difficult times and celebrate
alongside them when they reach their goals.
ETHICAL
We continue to be an organization where personal and professional ethics always
supersede short-term business gains. A decision based on ethics — and guided by
conscience — will uphold the integrity of the Office and will always have the support of
senior management.
In addition to these core values, we seek to provide a high level of service that
distinguishes SVB in the marketplace. We value professionalism and emphasize its
importance in communication, responsiveness, approach and appearance.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
1. PERSONAL DETAILS
Any changes to your personal details (particularly changes in name, marital status,
address and telephone number or bank details) should be notified to both the Client
Services Manager and the Human Resources Business Partner as soon as possible. The
registered office address of the Representative Office of Silicon Valley Bank (“Office”)
is Room 410C, No. 234, Songhu Road, Shanghai 200433, PRC. All correspondence and
notices that may be given by you in connection with your service for the Office should be
sent to the registered office address by registered post. However, a notice or other
document may be given to you by FESCO, a Human Resources representative of the
Office or any other person authorised by them handing the document to you personally.
You may also deliver documents to the Office personally by handing it to the Client
Services Manager or to your immediate supervisor. It will always be the responsibility of
the person delivering the document to obtain a written receipt. All information in your
personnel record will be treated in the strictest of confidence. However, you acknowledge
and agree that the Office is entitled to transfer your personal details and any information
in connection with your labour contract or other employment documents to any
associated company of Silicon Valley Bank or any outside human resources service
company where necessary. Any information communicated with the outside human
resources service company (if any) by you should be copied to the Office.
2. COMMENCEMENT OF EMPLOYMENT AND PROBATION PERIOD
The date that you started servicing for the Office is that as recorded in your dispatching
agreement between FESCO and the Office (“Dispatching Agreement”), unless
otherwise changed with the agreement of yourself, FESCO and the Office, and may not
be the same date that you signed your Employment Agreement with FESCO
(“Employment Agreement”).
Subject to the terms of your Employment Agreement and the Dispatching Agreement,
during your probation period, your employment and/or service may be terminated by
such length of prior notice in writing by you, FESCO or the Office as agreed under your
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Employment Agreement and given at any time during or at the end of this period. If your
continued employment and/or service is confirmed within or after the probation period,
then any terms referred to in your Employment Agreement and/or Dispatching
Agreement which are dependent upon confirmation of your employment and/or service
will come into effect and not before.
3. JOB TITLE AND DESCRIPTION
Your job title is set out in your Employment Agreement or such documents of
appointment provided by the Office and your normal duties are detailed in the job
description attached to the same. However, in addition you may be required to undertake
other reasonable duties from time to time appropriate to your level within the Office, but
you will not be assigned duties which you cannot reasonably be expected to perform.
The Office's reporting requirements are that you report to those of your supervisors as
management may instruct you from time to time.
4. NORMAL HOURS OF WORK AND OVERTIME
Your normal hours of work may be set out in your Employment Agreement or such hours
of work information sheet provided by the Office. You may also be required to work
such additional hours as may be necessary for the proper performance of your duties, and
you will be expected to comply with all reasonable requests and instructions.
The Office reserves the right to amend your starting and finishing times (either
temporarily or permanently) where required in the interests of efficiency or the needs of
the business after due consultation.
Prior approval from your Office supervisor is required for all overtime work and the Part
A of the Overtime Approval and Claim Form (Appendix 7) should be completed and
countersigned by the Office supervisor, and after the overtime work being performed, the
Office supervisor should be asked to sign at the Part B of the Overtime Approval and
Claim Form confirming the claim. The signed Overtime Approval and Claim Form shall
then be submitted to the designated Human Resources colleague for further processing.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
You should submit your Overtime Approval and Claim Form(s) in a timely manner, and
in any event not ten (10) working days after the overtime work.
5. PAY
Your basic pay is set out in your Employment Agreement and this will be paid monthly
on or before the last working day of each month. Payment of overtime (if payable) will
be made on the normal pay day for the month following that in which the overtime was
worked. On every pay-day you will receive a pay slip showing gross pay, deductions
(statutory, agreed or otherwise) and the net sum paid. Your pay will be reviewed at the
time or times as provided in your Employment Agreement. Any change as a result of
that review will be notified at the beginning of the calendar month following the review.
All regular, full-time employees are eligible to participate in incentive compensation
programs. Details of these programs, including eligibility criteria and pay cycles, will be
provided to you.
6. HOLIDAYS AND HOLIDAY PAY
The Office believes that holidays are vital for the morale of all employees.
Regular employees begin accruing holiday leave credits on their date of hire, at a rate
determined by length of service, salary grade, and work schedule. Credits accrue during
active service period (e.g., credits do not accrue during leaves of absence). Temporary
and Intern employees who have not been in continuous service term with the Office for
one year or more do not accrue holiday credits.
No holiday may be taken during the probation period without express prior written
permission. The Office will honour holiday that you have booked before the start of your
service provided that the dates were agreed at your interview.
If you are a regular employee taking holiday leave, you must give sufficient prior notice
of proposed holiday dates and these must be agreed with the person you report to and
recorded. Agreement to your proposed holiday dates will not be unreasonably withheld
but consent will remain in the absolute discretion of the Office. Reasonable efforts will
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
be made to accommodate your personal requirements but you are advised to consult with
your immediate supervisor before making any reservations and you should not assume
that dates are acceptable until notified as there may be clashes. Sufficient staff to
continue an efficient service must be present in each department at all times. Holiday
dates requested when less than the required notice is given may be allowed or disallowed
in the absolute discretion of your immediate supervisor. Your length of service may also
be a factor if a number of employees prefer the same dates. A request for holiday should
be made by using the Office‟s holiday form.
Holiday pay is paid at your normal rate of salary.
For the purpose of all provisions covering holiday, one day's pay shall be .38% of your
basic annual pay although holiday taken will be calculated to the nearest half day. Staff
taking a half-day's leave will work 4 hours on the day concerned.
You can accrue holiday credits up to a maximum of one and a half times your annual
allotment. When maximum accrual is reached, no further accrual will occur until some
accumulated vacation is used.
The Office encourages employees to schedule and use accrued holiday credits in the year
in which they accrue. Holiday balances continue to carry forward at the end of each
calendar year, up to the maximum accrual mentioned above, and cannot be “exchanged”
for cash during employment.
Maternity leave
You are entitled to take leave for such periods as stipulated under the relevant laws, rules,
and regulations on maternity leave. The Office will continue to pay you during your
period of maternity leave in accordance with the maternity leave pay at the appropriate
statutory rate.
Other Unpaid Leave and Holiday
Other unpaid leave and holiday may be granted, depending on business staffing needs
and related considerations, for extenuating circumstances.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Public Holidays
You are entitled to all public and statutory holidays applicable in the People‟s Republic
of China (“PRC”) from time to time in addition to your basic holiday entitlement and will
be paid for each public holiday.
7. SICKNESS AND ABSENCE AND SICKNESS/ABSENCE PAY
If you are absent from work for any reason and your absence has not previously been
authorised by the person you report to or another management representative, then you
(or someone on your behalf if your sickness prevents you doing it yourself) must inform
the Office within one hour of the beginning of your normal working hours of every day
of absence which is a weekday (not being a public holiday). Failure to notify the Office
of absence and the reason for it, or absence from work for three or more days without
proper and reasonable reason, will normally result in loss of pay for the period of
absence, and may be treated as an act of gross misconduct justifying dismissal without
notice when repeatedly practised.
Any unauthorised absence must be properly explained and an absence record sheet
completed on your return to work (setting out dates and reasons for absence including
dates of sickness on non-working days) and this must be signed by your immediate
supervisor or another management representative in charge of the matter. If absence is
likely to be of uncertain duration, you must keep the Office regularly informed on at least
a daily basis, unless you have a medical certificate from your Doctor for a longer period.
For any absence for sickness or injury, you will be required to provide an original
medical statement signed by a doctor expressing the reason for your absence from work.
Medical certificates must be provided to the Office on the day you return to work, but if
sickness or injury will prevent you from returning to work for over one week, you must
provide the relevant medical certificate on the day immediately following the expiry of
such week, and then on a weekly basis, if your sickness or injury continues. If you are
absent for three working days or more without making contact with the Office, it will be
considered as a serious breach of the rules or policies of the Office and your service
relationship with the Office may be terminated without notice. Alternatively, the Office
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
has the right to take or accept such conduct on your part as having resigned from the
Office without prior notice to the Office.
Medical certificates will be maintained in the Office's personnel records and any failure
without good cause to comply with these arrangements will be considered as a serious
breach of the rules or policies of the Office and your service relationship with the Office
may be terminated without notice.
If you are absent from work (due to sickness or any other reason) and you comply with
the above, the Office may pay you either sick leave pay in accordance with the Office‟s
rules or policy in making sick leave pay (“Sick Leave Pay Policy”) or sick leave pay at
the appropriate rate of statutory sick pay ("SSP") (subject to your qualifying for SSP)
according to the relevant laws, rules and regulations (as amended from time to time).
Sick leave pay will be treated like pay being subject to PRC individual income tax.
Please note that the Office shall have the right to pay sick leave pay according to the
relevant laws, rules and regulations. Any payment under the Office‟s Sick Leave Pay
Policy shall be deemed to include any SSP to which you are entitled.
In the case of other unauthorised absence, the Office may decide to pay you such sums as
are in its absolute discretion. The Office will take into account the following factors in
deciding whether any absence pay is payable:-
1. length and reason for the absence
2. your absence record
3. your performance generally
4. any other relevant points which the Office in its absolute discretion
takes into account including any representations made by you on
your return from such absence, although the Office reserves the
right to have such absence charged against your annual holiday
entitlement.
All periods of absence are recorded in your personnel records.
The Office reserves the right to have you examined at one or more medical examinations
at any time by an independent Doctor or Consultant at its expense and to cease payment
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
of any discretionary sick pay paid under the Office‟s Sick Leave Policy if it is advised by
the Doctor or Consultant that you are fit to return to work. You will be shown a copy of
the report prepared by such independent Doctor or Consultant and given the opportunity
to comment on it. It is agreed that you will co-operate in full with any such reasonable
request to be examined by such Doctor or Consultant and you will be expected to sign a
statement to authorise that your Doctor‟s records (and any other relevant medical records)
be made available to the independent Doctor or Consultant. However, absolute
confidentiality as to your medical condition will be respected and maintained and the
only person to have sight of such records will be the independent Doctor or Consultant
and the only person(s) to have sight of the report will be you and the Head of the Office
or the Human Resources Business Partner, but should there be dispute leading to
arbitration or litigation, the report and any medical evidence may be produced in such
arbitration or litigation. In particular, the Office will be concerned to establish the likely
extent and frequency of any future sickness absence and the general prognosis. Refusal
by you to comply with this requirement may result in disciplinary action. The Office
reserves the right to request your written permission to discuss your medical condition
with your Doctor.
If you are absent for work (due to sickness, injury or any other reason) excluding annual
and public holidays, for over the stipulated period under PRC Labor Law or other
relevant laws, rules or regulations, such conduct will be considered as a serious breach of
rules or policies of the Office and your service relationship with the Office may be
terminated without notice. Alternatively, the Office has the right to take or accept such
conduct on your part as having resigned from the Office without prior notice to the
Office.
If you are absent because of any injury or accident caused by someone else (for example,
in a road traffic accident), you will be required to repay any sickness/other absence
payments made to you and the Office will seek to recover the equivalent compensation
for loss of earnings from the third party. However, such repayments will only be sought
when the actual compensation is received from the third party.
8. TERMINATION
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Subject to the rules governing notice during or upon the expiry of your probation period,
and on the confirmation of your continued service relationship, the period of notice to be
given in writing by FESCO, the Office or by you to terminate your employment and/or
service for the Office is set out in your Employment Agreement and/or the Dispatching
Agreement.
If you commit a serious breach of the rules or policies of the Office, or a violation of any
applicable laws and regulations (no matter whether any penalty has been imposed), or
you are temporarily incapable to perform your duties for more than 30 days due to the
situations including but not limited to detention by the Police or any other competent
authorities, the Office may terminate your service relationship with the Office without
notice pursuant to the relevant law, rules and regulations.
The Office reserves the right to pay monies in lieu of notice and any payment made in
lieu of notice will be subject to individual income tax deducted at source but nothing in
this paragraph shall prevent the Office from terminating your service for the Office
without notice or pay in lieu of notice in the appropriate circumstances.
Your final monies properly payable to you (to be paid by cheque) and arising out of the
termination of your service for the Office will be sent to you within the month in which
your service for the Office ended (whether terminated by you or the Office) or soon
thereafter if your service for the Office ends after the 20th
of a month, or within such
period as provided under the relevant law, rules and regulations, subject to and always
provided if the Office shall have a claim against you arising out of your breach of the
Employment Agreement and/or the Dispatching Agreement or your duties to the Office,
the Office may retain such final monies pending determination of the matter.
Should you leave without notice or during your notice period without the permission of
the Office, the Office reserves the right to deduct a day's pay for each day not worked
during the notice period. This may include deductions of pay and/or accrued holiday pay
and/or any other monies contractually due to you. (In any case, where the Office agrees
in writing to waive the need for you to work your notice, this will not apply).
The Office reserves the right to require you to remain away from work during a notice
period (whether you or the Office gave notice and irrespective of the length of any
notice).
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Where the Office requires you to remain away from work during a notice period (whether
you or the Office gave notice and irrespective of the length of any notice), you must
comply with any conditions laid down by the Office (including the performance of such
duties as the Office may require in its entire discretion) and whilst on full pay (with all
contractual benefits), and during such time you will not be permitted to work for anyone
else or on your own behalf without the Office's prior written permission. During this
period the Office will require you not to communicate with suppliers, customers or other
employees and in no circumstances should you enter into any contract or arrangement
which would bind the Office. You will be personally liable for such arrangements. The
Office reserves the right to inform other employees and third parties that you have
resigned or given notice in its absolute discretion.
On the last day of your service for the Office , or at such time during your service for the
Office as the Office shall determine, you must return to the Office, all correspondence,
drawings, documents, papers and any copies which you may have taken in whatever form
as well as any other property belonging to the Office which may be in your possession or
under your control. The Office reserves the right to charge for any equipment which has
been lost or not returned.
9. COPYRIGHTED MATERIALS
You cannot copy or distribute copyrighted material (e.g., software, computer files,
documentation, articles, graphics) unless you have confirmed that the Office has the right
to copy or distribute the material. Failure to observe a copyright may result in legal
action by the copyright owner. When in doubt about whether you may copy copyrighted
material, consult the Office‟s Legal Department. Violation of this provision will be
considered as a serious breach of the rules or policies of the Office and your service for
the Office may be terminated without notice.
10. CONDUCT & PERFORMANCE EXPECTATIONS
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
The Office will provide the necessary information, training and tools for employees to
perform their job duties.
Although each situation is unique, should improvement in job performance be needed,
guidance and counselling are generally provided. These may take a variety of different
forms, such as verbal or written counselling.
The Office expects all employees to behave in a respectful and professional manner at all
times. The Office expects employees to follow this Handbook and to demonstrate the
Values and Standards embodied in this Handbook and sound and ethical business
standards. Although not an exclusive list, job expectations include:
Avoid any actions which are dishonest or fraudulent or which jeopardize the
security of the Office operations, its employees or clients, including
falsification, misrepresentation, alteration, or destruction of any the Office
records or property, providing false or misleading information on an
employment application form or on any other Office records.
Comply with the Office‟s cash balancing or cash control standards.
Perform your job duties, as requested, according to the established performance
standards and guidelines. Maintain all licenses required for your job. Provide
support for colleagues‟ goals and work.
Avoid any actions of refusal or failure to abide by or obey instructions.
Avoid behaviours that are disruptive or that antagonize or harass clients,
vendors or other employees, or that reflect negatively on the Office.
Employees who are related to one another or are in close personal relationships
with one another are not to be in direct (or chain of command) reporting
relationships. This will avoid any conflict, as well as possible security and
morale issues. Disclose to your immediate supervisor or manager if you have
any potential conflicts of interest.
Engage in proper, appropriate and authorized use of Office property,
equipment, or premises (or that of others), including copying, photographing,
reproducing or utilizing Office documents, Office property or property of
others.
Carry out the Office‟s guidelines regarding proprietary and/or confidential
Office, client and employee information.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Compliance of all applicable laws and regulations.
Conduct yourself in a professional manner at all times.
Failure to meet with any of the above expectations will be considered as a serious breach
of the rules or policies of the Office and your service for the Office may be terminated
without notice.
11. WORK ENVIRONMENT
In order for us to maintain a positive work environment for all of our employees, you are
required not to engage in or permit any fellow employee to engage in, any sexual, racial
or other harassment or other unlawful discrimination against any person (whether or not a
fellow employee) in the course of your service with us. You should strictly observe the
Silicon Valley Bank Harassment-Free Workplace Policy attached hereto as Appendix 1.
Violation of this provision will be considered as a serious breach of rules or policy of the
Office and your service for the Office may be terminated without notice.
12. HEALTH & SAFETY
We will take all reasonable steps to ensure your health, safety and welfare whilst at work.
You must familiarise yourself with the Safety Policies and Guidelines attached hereto as
Appendix 2.
The Office will make reasonable accommodations for employees with life-threatening
illnesses. It will also take necessary steps to ensure that the health and safety of
employees, clients, and business contacts are not endangered by any employee‟s illness.
In most circumstances, employees may not refuse to work because they are afraid of
contracting a life-threatening illness from a co-worker. Under no circumstances will
discrimination or harassment of an employee with a life-threatening illness be tolerated.
Violation of this provision will be considered as a serious breach of rules or policies of
the Office and your service for the Office may be terminated without notice.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
All employees share the responsibility for maintaining a workplace free from violence or
the threat of violence. Any employee, who believes he or she is a victim of threatening
behaviour, harassment, or other violence or threat of violence, or is a witness to this
behaviour, must report it immediately to a supervisor, manager, or high levels of
management.
Employees should be aware that many episodes of violence arise from individuals who
are not employees and may even be family members of the employee. Please do your
part to monitor and maintain our mutual safety by complying with safety and security
policies.
The Office does not tolerate violence or the threat of violence in or out of the workplace.
Violation of this provision will be considered as a serious breach of rules or policy of the
Office and your service for the Office may be terminated without notice. The Office will
further take all necessary steps to ensure that violent or threatening behaviour does not
occur, which may involve mandatory referral to a mental health professional, discipline
or termination of the service for the Office and/or bring the matter to the attention of the
Public Security Bureau. Examples of unacceptable behaviour include: threatening to
harm another person in any way; striking or physically challenging another person;
engaging in dangerous, threatening or unwelcome horseplay; bringing any article that
could be construed as a weapon to work or any work-sponsored event; or engaging in any
activity that causes or may cause an unsafe work environment. Jokes about weapons,
violence or the threat of violence are also considered to be threatening.
Failure to observe safety rules including intentional misuse of equipment which is likely
to endanger another‟s health and safety may also lead to dismissal without notice.
13. COMPLAINT RESOLUTION
The Office encourages you to try to resolve concerns, problems or complaints as they
arise through direct discussion.
The Office‟s managers and executives practice an “open door” policy, and employees are
encouraged to raise suggestions and voice concerns on a regular and/or “as needed” basis.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Many situations of potential conflict can be resolved quickly by communicating directly
with the person whose behaviour you believe is inappropriate. If you feel comfortable
doing so, tell that person to stop and that the conduct makes you feel uncomfortable.
The Office will take prompt and appropriate steps to prevent harassment or other
inappropriate behaviour. This may include additional training or education, coaching,
counselling, disciplinary action, transfer, demotion or termination. The results of the
investigation will be communicated to the complainant, the alleged offender and, as
appropriate, to any others directly involved.
The Office will not tolerate any retaliation against anyone who has raised concerns,
reported harassment, participated in, or cooperates in any way with an investigation of
employee complaints.
Any employee who reasonably believes that he or she is aware of substantial misconduct
that ranges from questionable accounting practices to harassment of discrimination is
encouraged to file a report to either the Head of the Office or the Human Resources
Business Partner. You may also contact any member of the Steering Committee. Refer to
Appendix 6 for a list of Steering Committee members and their contact information. You
may also contact the Chairman of the Audit Committee, SVB Financial Group Board of
Directors. Refer to the SVB intranet for more information.
Additionally, you may make anonymous and confidential reports of unethical conduct by
logging onto www.ethicspoint.com from any computer with access to the Internet or by
calling their toll-free Hotline at 866-ETHICSP (866-384-4277). All reports are taken
seriously and are promptly investigated.
SVB “EthicsPoint” Hotline
Calls Within the U.S.
866-ETHICSP (866-384-4277)
Calls Outside the U.S.
Dial Country Access Code and 866-ETHICSP (001-866-384-4277)
Web site Submission: www.ethicspoint.com
Available 24 hours a day, 7 days a week
All CONTACTS ARE CONFIDENTIAL
SVB “EthicsPoint” Hotline
Calls Within the U.S.
866-ETHICSP (866-384-4277)
Calls Outside the U.S.
Dial Country Access Code and 866-ETHICSP (001-866-384-4277)
Web site Submission: www.ethicspoint.com
Available 24 hours a day, 7 days a week
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
14. CONFIDENTIALITY AND FIDELITY
You are required to comply with the Confidential Information and Invention Assignment
Agreement for Employees attached hereto as Appendix 3 and familiarize yourself with
the terms and requirements of the same. You should be sensitive to the risk of
inadvertent disclosure resulting from open doors, speaker phones, cellular phones, and
when transmitting confidential information by fax or other electronic media. You must
secure confidential information, whether in physical or electronic form, according to the
applicable procedures. Confidential information should not be taken to an employee‟s
home unless as necessary to conduct the Office business.
The Office appreciates that not all employees will remain with the Office forever and it is
not its intention to prevent employees from using in future employment their skills and
experience gained with the Office. Nevertheless the Office will take such measures as
are necessary to protect its confidential information and trade secrets.
Unauthorised disclosure of confidential information will be considered as a serious
breach of the rules or policies of the Office and your service for the Office may be
terminated without notice. Further, it may lead to civil proceedings to restrain you from
disclosing the information to a third party or making personal use of it without authority
from the Office or for damages if loss to the Office results from unauthorised disclosure.
All employees are required to conduct dealings with their colleagues, suppliers, external
organisations and the public at large with total honesty and integrity, and to maintain the
reputation and image of the Office at all times. Violation of this provision will be
considered as a serious breach of the rules or policy of the Office and your service for the
Office may be terminated without notice.
If you have a suspicion that a member of staff is divulging confidential information to
competitors, then you should inform either the Head of the Office or the Human
Resources Business Partner immediately.
15. CONFLICT OF INTEREST
Ethical Conduct
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
The Office‟s employees may encounter situations that require them to make an ethical
judgment and in such situations, the Office requires employees to conduct themselves in
a manner that is fair, reasonable, and honest. The Office requires employees to act within
the following boundaries:
Interests in Competitors, Suppliers and Customers. Subject to the provisions in this part,
in order to avoid real or perceived conflicts of interest, you may not obtain a financial
interest in a privately-held client, prospective client, company, competitor, or supplier in
the business niches that SVB serves, or a venture capital or private equity fund in the
business niches that SVB serves. During the term of your service relationship, you shall
not directly or indirectly obtain more than a 2% equity or other financial interest in a
publicly-traded company in the business niches that SVB serves or that is a competitor
(e.g. another bank) or supplier unless prior approval has been given by your manager and
the Head of Human Resources following the procedures below. If you are on a client‟s or
prospective client‟s account management team (including, but not limited to, relationship
managers, regional managers and credit officers) or if in the normal course of your job
duties you make decisions regarding a client or supplier such as procurement or account
management decisions you are considered a “Client Decision-maker” and shall not
directly or indirectly obtain a financial interest in such client, prospective client or
supplier unless prior approval has been given by your manager and the Head of Human
Resources following the procedures below. In addition, if you are a Client Decision-
maker and have a pre-existing investment in a company that becomes a client or supplier,
you must immediately inform your manager and the Head of Human Resources such
investment and provide the details thereof as required by your manager and the Head of
Human Resources and may need to either divest your interest in such company or cease
handling any business for SVB involving such company. Under some exceptional
circumstances, the foregoing types of investments may be permitted on a case-by-case
basis, but only with the advance written approval of your manager and the Head of
Human Resources. You are encouraged to address any questions or requests for
approval of an exception to this standard to the Head of Human Resources.
Related Employees. You must avoid initiating or approving personnel actions affecting
reward or discipline of employees or applicants where there is a family relationship or a
personal involvement.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Use of the Office Property. You may not use the Office property, facilities, or equipment
for personal gain. You may not operate a private business from Office grounds, on
Office time, or with Office materials.
Loan Applications. Loan applications submitted to lending officers by relatives or close
personal friends (or entities controlled by relatives or close personal friends) should be
submitted to other lending officers of equal or higher position for processing and
approval. This rule also applies to processing and approving overdrafts and waiver of
service fees.
Personal Investments. You may not make an investment as a result of an opportunity that
arises out of any employee‟s professional relationship with a client, prospective client or
venture capital fund.
Perception of Impropriety. You must avoid any actions that can be perceived as
improper or unfair in dealing with customers, suppliers or any other person.
Violation of any of the above provisions will be considered as a serious breach of the
rules or policies of the Office and your service for the Office may be terminated without
notice.
Business Courtesies
Giving or receiving common courtesies (such as business meals) usually associated with
accepted business practice is acceptable. However, in any such dealings, employees
should not request, accept, offer to give or give anything of value, the express or implied
purpose or result of which is to influence the bona fide business relationships between the
Office and such person or entity.
Gifts, Advantages & Entertainment
U.S. and PRC:
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Except to regulators, government officers or other public officers, where specific rules
apply, SVB recognizes that the giving and receiving of gifts and entertainment is an
important part of developing and maintaining business relationships. Employees are
encouraged at all times to ensure that their activities in this area align with the following
key principles:
Ensure that the intent or purpose behind the gift or entertainment activity is open and
honest, and aligns with SVB‟s Core Values and Standards. Anything that is designed
to improperly influence a business relationship or to bribe another not only
contravenes our Core Values but may also be illegal.
Adhere to the SVB Employee Expense Reimbursement Policy, which provides
specific guidelines on business development-related events, gift and entertainment
limits.
When representing SVB internationally, exercise appropriate local discretion. The
attached Appendix 5 provides additional information on local business practices and
customs in each of SVB‟s international locations. and strict compliance to the
provisions herein and in the Appendix is required (where there is a conflict between
the general rules herein and the specific local rules, you are advised either to comply
with the stricter rule, or seek clarification from your manager and the Head of Human
Resources). Violation of this provision will be considered as a serious breach of the
rules and policies of the Office and your service for the Office may be terminated
without notice.
Employees must seek guidance from their manager if, after reviewing the policies and
appendices referenced above, they are uncertain whether their activities are in
compliance.
Further, a gift given by you or an agent for you in connection with Office business must
not violate restrictions against bribes under PRC laws and regulations and the U.S.
Foreign Corrupt Practices Act.
Other Outside Positions
You may not serve as an officer, director, advisory director, honorary director, committee
member, or in any management position of an outside business organization without the
prior written approval of the Head of the Office and the Head of Human Resources. You
may not serve as an officer, director, advisory director, advisory director, honorary
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
director, committee member, or in any management position for an SVB client without
also obtaining the prior written approval of the CEO. Violation of this provision will be
considered as a serious breach of the rules or policies of the Office and your service for
the Office may be terminated without notice.
16. INSIDER TRADING
If you are in possession of “material nonpublic information” (or “inside information”)
about another company, you must not trade in or recommend the purchase or sale of the
stock or other securities of that company until the information has been made available to
the public. Inside information includes any material information, written or oral, that is
not generally available to the public. Not only are employees prohibited from buying or
selling securities based upon inside information, the law also imposes liability upon
anyone who discloses inside information to an outsider who uses that information to trade
in securities or passes the information along to someone else who does. Violation of this
provision will be considered as a serious breach of the rules or policies of the Office and
your service for the Office may be terminated without notice.
17. DISCIPLINARY OFFENCES
Without prejudice to any conduct mentioned elsewhere in this handbook that will subject
you to dismissal without notice,
(i) if you commit misconduct of a minor nature, you will receive an oral or written
warning from your supervisor or a higher level of management. You should
treat such warning seriously and refrain from committing any further
misconduct. Examples of minor misconduct include but is not limited to bad
time keeping, unreasonable or persistent absenteeism and other minor breach of
rules listed in this handbook;
(ii) if you commit misconduct of such nature that it fundamentally breaches the
contractual relationship between you and the Office or is a gross violation of
the rules, policy and/or principles set out in this handbook, you may receive a
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
written notice from your supervisor or a higher level of management asking
you to stop or rectify the breach. Alternatively, you may be dismissed without
notice. Other than such serious breaches as expressly stated in this
Employment Handbook, examples of gross misconduct include repeated
breaches of the rules and principles of this handbook, fraud, breach of
confidentiality, violent behaviour and being committed of a criminal offence;
(iii) you will also be subject to dismissal if you have shown incapability to perform
your job efficiently and competently. In cases of incapability, the Office may if
it chooses to, implement appropriate procedures, arrangements and/or training,
if necessary, with a view to encouraging you to improve to an acceptable level.
If you still prove to be incapable of performing your duties thereafter, you will
be dismissed after a notice has been served upon you.
18. BEHAVIOURAL RULES
Alcohol & Drugs
Alcoholic drink must not be brought into the Office's premises for consumption.
Drinking which affects your performance or behaviour at work may be a reason for
dismissal when it affects your capability or results in intolerable behaviour, intolerable
absence, lateness, etc. This also applies to the possession of and being under the
influence of drugs except where medically prescribed. The Office considers excessive
drinking to be gross misconduct justifying dismissal without notice.
The Office reserves the right to ask any employee to submit to a drug test where an
employee‟s conduct, behaviour or work performance gives reason to believe that an
employee is under the influence of drugs. Violation of this provision will be considered
as a serious breach of the rules or policies of the Office and your service for the Office
may be terminated without notice.
Betting & Gambling, etc.
You are not allowed at any time to engage in gambling of any nature on the Office's
premises, nor be involved in the distribution or traffic in betting slips.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Also, you are not allowed to sell tickets for events outside the business, organise raffle
tickets or undertake private trading on the Office's premises or car park.
Violation of the above provisions will be considered as a serious breach of the rules or
policies of the Office and your service for the Office may be terminated without notice.
Smoking
The Office maintains a smoke-free work environment and expects all employees to
strictly observe designated smoking areas outside the office building. Smoking in the
Office‟s premises will be a disciplinary offence and will thus be subject to disciplinary
action and persistent breaches of this provision will be considered as a serious breach of
the rules or policies of the Office and your service for the Office may be terminated
without notice.
Harassment
The Office believes in treating all employees and clients with sensitivity and respect,
consistent with our Core Values and Standards, regardless of physical or mental
disability, and consistent with our obligations under laws. The Silicon Valley Bank
Harassment-Free Workplace Policy should be observed from time to time, and failure to
comply with the same will be a disciplinary offence and will thus be subject to
disciplinary action that may lead to dismissal without notice.
19. MISCELLANEOUS
Performance Appraisals
These ensure the Office's objectives are achieved and assists in identifying training needs
and ensures your continuous development. Therefore, in relation to the performance of
your duties, and in order for us to discuss your future progress, you will be required to
participate in any appraisal scheme which we may have from time to time and for this
purpose participation means being involved in the scheme as appraiser, an appraisee, or
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
both. A copy of your appraisal will be kept in your personal file. Appraisals will be with
your immediate superior.
However, informal monitoring may continue throughout the year and you may be asked
to attend discussions with your immediate supervisor.
Professional Appearance
The Office endorses a “business casual” dress style in its work locations, on an “as
appropriate” basis. All employees, even those who do not have direct customer contact,
represent the Office in the community at large. Since it is important to project an image
of competence and efficiency upon which the Office‟s reputation has been built,
grooming and dress is to be neat and professional at all times. Formal or traditional
business attire is to be worn when appropriate to business circumstances.
Expenses
The Office will reimburse all expenses properly incurred by you in the proper
performance of your duties provided that on request you provide the Office with such
receipts or other evidence of actual payment of such expenses that the Office may
reasonably require. You should discuss anticipated expenses with your reporting
manager prior to incurring them.
Claims for reimbursement of expenses should be made on a calendar month basis as soon
as possible after the end of the month, but more frequent claims may be made if
reasonable and necessary. Advances may be obtained in respect of specific expenses to
be incurred with prior approval and they will be given only on the understanding that
they will be wholly accounted for by the submission of a business expense claim form
within 7 days of the receipt of the advance. Advances which are no longer required must
be returned immediately. The Office reserves the right to withhold from your salary
payments of any advances which have not been accounted for. Employees must take all
reasonable steps to minimise expenses.
Statement to Media
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
All media inquiries regarding the Office and its parent / subsidiary companies must be
referred to the Director of Public Relations. Only the CEO, the CFO and the Director of
Public Relations are authorized to make or approve public statements pertaining to the
Office or its operations. No employees, unless specifically designated, are authorized to
make statements to the media. Any employee wishing to write and/or publish an article,
paper, or other publication on behalf of the Office must first obtain approval from the
Head of the Office before publication. Violation of this provision will be considered as a
serious breach of the rules or policies of the Office and your service for the Office may
be terminated without notice.
Income Pay and National Insurance
Withholding tax on your remuneration and compulsory contributions to the statutory
insurance scheme will be deducted from salary payments in accordance with the relevant
law, rules and regulations.
Car Park
The Office is not bound to provide you with staff car parking facilities and does not
accept liability for damage or loss incurred whilst your vehicle is parked on the Office's
premises.
Any motor vehicle brought onto the Office‟s premises by an employee must be insured in
respect of third party risks.
Any unauthorised use of the Office‟s car park for up to 3 times will be considered as a
serious breach of rules or policy of the Office and may lead to dismissal without notice.
Lost Property
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Property lost or stolen should be reported to the Client Services Manager at once.
Property found in the Office's premises should be sent to the Client Services Manager
and items of value will in turn be passed to the Public Security Bureau.
Other Employment & Outside Activities
You must devote the whole of your time, attention and abilities during your hours of
work to your duties for the Office. You may not, under any circumstances, whether
directly or indirectly, undertake any other duties of any kind (whether for personal and/or
business purposes) during your hours of work for the Office. You must not in any
circumstances engage in any employment outside your hours of work with the Office.
Unless special permission is obtained, you must not undertake outside activities which
would involve your absence from work or result in reduced personal efficiency.
Violation of this provision will be considered as a serious breach of the rules or policies
of the Office and may lead to termination of your service for the Office without notice.
Personal Effects
Personal effects should at no time be left unattended and the Office does not accept
responsibility for their damage or disappearance.
Private Telephone Calls, Correspondence and use of the Office's Facilities
The Office relies a good deal on telephone communications and it is important that the
system is kept free for the conduct of business. Non-essential private telephone calls are
therefore discouraged, but necessary and brief private telephone calls at your expense are
permitted from the office telephones. The Office‟s e-mail policy is set out below. This
concession must be exercised in such a way that there is no more than a minor disruption
of your work if and when making a private telephone call. However, we reserve the right
to withdraw this facility if reasonably believing that it is working unsatisfactorily, or is
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
being abused. Similarly, you are requested not to make private use of the Office's
photocopier, fax or postal (including franking) facilities.
Private correspondence must not be sent to the Office's address, nor should
correspondence relating to work be sent to a private address. The Office accepts no
liability for any private letters which may arrive at the Office's premises and can give no
guarantee that they will not be opened. The Office's stationery must not be used for
personal correspondence. No orders for goods or services other than those required and
authorised by the Office for its business may be placed in the Office's name. Overall,
you must not use the Office's time, resources or materials for private purposes, and must
avoid any conduct which may be prejudicial to the efficiency or reputation of the Office.
Failure to observe these rules will be a disciplinary offence and will thus be subject to
disciplinary action that may lead to dismissal without notice.
Mobile Telephones
Use of personal mobile telephones should be minimised in the workplace unless the use
is work related. Personal mobile telephones are permitted to be used in an emergency.
Computer system
Employees should not make any unauthorised modification to any software, hardware or
other component of the Office‟s computer system.
Employees should not install any software or hardware without such software or
hardware and its relevant licences or terms and conditions of use being inspected and
approved by a representative of senior management with overall responsibility for IT.
Failure to observe these rules will result in disciplinary action being taken against you,
and that may lead to dismissal without notice.
Employees must do their utmost to protect the security of the computer system and guard
against virus attack.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Employees have no expectation of privacy in, and SVB may monitor at any time without
notice, all communications conducted on or through SVB computers, equipment, systems
or network.
You are required to comply with the End User Services Policies and Procedures attached
hereto as Appendix 4. Failure to comply with the same will be a disciplinary offence and
will thus be subject to disciplinary action that may lead to dismissal without notice.
SVB Electronic Communications and Messaging Systems
The Office‟s computer systems contain messaging facilities which are intended to
promote effective communication within the organisation on matters relating to business.
Personal messages may be sent but these should respect the primary purpose of the
messaging systems. This means the messaging systems should not be used for a purpose
detrimental to your job responsibilities, for spreading gossip, or for personal gain or in
breach of any of the Office‟s standard employment policies on issues, such as sexual
harassment.
Messages sent on the messaging systems are to be written in accordance with the
standards of any other form of written communication and the content and language used
in the message must be consistent with best Office practice. Messages should be concise
and directed to those individuals with a need to know. General messages to a wide group
should only be used where necessary.
Confidential information should not be sent externally by any form of messaging without
express authority and unless the messages can be lawfully encrypted.
Messages sent over the Office‟s systems can give rise to legal action against the Office.
Claims of defamation, breach of confidentiality or contract could arise from a misuse of
the system. It is therefore vital for messages to be treated like any other form of
correspondence and where necessary hard copies to be retained. You are also reminded
that messages are disclosable in any legal action commenced against the Office relevant
to the issues set out in the messages.
The Office reserves the right to retrieve the contents of messages for the purpose of
monitoring whether the use of the messaging system is legitimate, to find lost messages
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
or to retrieve messages lost due to computer failure, to assist in the investigation of
wrongful acts, or to comply with any legal obligation.
If you are given access to the messaging systems you are responsible for the security of
your SVB equipment and you must not allow the SVB equipment to be used by an
unauthorised person.
You should therefore keep your personal passwords confidential and change it regularly.
When leaving your SVB equipment unattended or on leaving the office you should
ensure you log off the system to prevent unauthorised users using your equipment in your
absence.
Should you receive an electronic message which has been wrongly delivered to you, you
should notify the sender of the message for redirecting the message to that person.
Further in the event the message contains confidential information, you must not disclose
or use that confidential information. Should you receive an electronic message which
contravenes this policy, the message should be brought to the attention to your immediate
supervisor.
Failure to observe these rules will result in disciplinary action being taken against you,
and that may lead to dismissal without notice.
Internet
The Office recognises that the Internet is a valuable commercial tool.
Employees are requested to make considerate use of the Internet and to refrain from using
the Internet for personal purposes.
The transmission and distribution of indecent and offensive images, programmes and
documents is a serious disciplinary matter.
The Office will routinely monitor Internet activity.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Punctuality
In order to ensure a high standard of efficiency and service, punctuality is very important.
If you are late you must advise the Office of the reason, in advance wherever possible,
and you will be expected to make up the time that day. Persistent lateness will be subject
to disciplinary action that may lead to dismissal without notice. You should also not
leave before your finishing time without your immediate supervisor‟s express consent.
Bad Weather
You are expected to make every reasonable effort to get to work during bad weather.
Whistle-blowing policy
All organisations face the risk of things going wrong or of unknowingly harbouring
malpractice. The Office believes it has a duty to identify such situations and to react
accordingly.
By encouraging a culture of openness, the Office wants to encourage you to raise issues
which are of concern to you at work.
If there is anything which you think the Office should know about, please use the
following procedure:
1.) If you are concerned about any form of malpractice, you should normally first
raise the issue with your immediate supervisor.
2.) However, if you feel unable to tell your immediate supervisor, please raise the
issue with the Head of the Office.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
3.) If you have raised concerns and you are still concerned, or the matter is so serious
that you feel you cannot discuss it with either of the two persons mentioned
above, you should raise the matter with your Human Resources Business Partner,
any member of the Steering Committee or the Chairman of the Audit Committee,
SVB Financial Group Board of Directors. You may also make an anonymous and
confidential report by logging onto www.ethicspoint.com from any computer with
access to the Internet or by calling their toll-free Hotline at 866-ETHICSP (001-
866-384-4277).
After you have raised your concern, the Office will decide how to respond in a
responsible and appropriate manner under this policy.
In so far as is possible, the Office will endeavour to keep you informed of any decisions,
enquiries and investigations which have been carried out. Please note that the Office may
not be able to inform you of matters which would infringe the duty of confidentiality
which is owed to others.
Staff should of course on the other hand not engage in any fraudulent activity or any
activity in connection with his employment that may constitute a crime, e.g. defrauding
tax authorities or commercial bribery. The Office‟s management is not responsible for
individual criminal acts. No staff is allowed to remove the Office‟s chop from the
Office‟s premises or use it without the authorisation of an Officer or use any name card
that is not provided by the Office. Any failure to comply with such obligations will lead
to dismissal without notice and a possible claim for indemnity by the Office.
References
The Office does not give open references but will respond to specific requests from third
parties who should be asked to contact the Office direct. The Office reserves the right
not to provide a reference but any reference that is given will take into account the whole
of your service. Your employment is subject to the receipt of satisfactory references.
Rules
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Various rules exist for the smooth, effective and safe operation of business and the
welfare and interest of those who work for us. If you are subject to any particular rules
then, once you have been informed, you will be expected to comply with them.
However, from time to time we may exercise our right to change existing rules or to
introduce new ones with which you as an employee will be required to observe.
Information about particular rules will normally be provided in circular to staff on notice
boards, or otherwise brought to the attention of those required to observe them. A breach
of any such rule may render you liable to disciplinary action. However, rules should be
seen as essential in generating a convivial working environment, preferring to develop
the Office on the basis of mutual respect and co-operation.
The SVB Employment Handbook is available in English and Chinese. Where there
are any inconsistencies between the two versions, the English version shall prevail.
Neither this handbook nor the plans or benefits described in this handbook creates an
agreement for employment, nor a guarantee of employment, between Silicon Valley
Bank and any employee. The Employment Agreement between FESCO and the
employee will prevail where there is conflict between the Employment Agreement and
this handbook regarding any plans or benefits contained therein. Silicon Valley Bank
reserves the right to amend or discontinue any program at any time with or without
notice and as in its sole judgment may be necessary. However, any amendments made
to the rules and principles are not binding upon the employee unless they are expressly
made known to the employees. Should any provision of this document be declared
illegal or unenforceable by any court of competent jurisdiction and cannot be modified
to be enforceable, such provision shall immediately become null and void, leaving the
remainder of this document in full force and effect.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Appendix 1
Silicon Valley Bank Harassment-Free Workplace Policy
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Appendix 2
Safety Policies and Guidelines
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Appendix 3
Confidential Information and Invention Assignment Agreement for Employees
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Appendix 4
End User Services Guidelines Manual
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Appendix 5
Gift & Entertainment Guidelines – China
General Overview
Chinese law prohibits gift giving that amounts to commercial or criminal bribery.
Gifts, cash, advantages or entertainment for the purposes of bribery are
prohibited.
Recommended Business Gifts & Practices
A gift to a “company" should be given to the most senior person, as they
represent the company. Gifts given to people at the same level should be of
similar value.
Recommend gifts displaying the SVB logo; location-related gifts (e.g. coffee
table book about California); good Cognac or other fine liqueur; fine pen (not
red ink).
Gifts should always be wrapped, ideally in red paper.
Reference the book “Kiss, Bow or Shake Hands” for more context on
international business practices and norms. You can find a copy at your local
bookstore.
Inappropriate Business Gifts & Practices
Watches; sharp-edged items (e.g. scissors, knives); black or white wrapping
paper; handkerchiefs.
Anything containing the number 4 (Number 4 is considered unlucky).
Giving a valuable gift to one person versus giving something to the whole
group is considered inappropriate.
Gift & Entertainment Guidelines – India
General Overview
Gifts, cash or entertainment for the purposes of bribery are prohibited by Indian
law.
Recommended Business Gifts & Practices
Ties, pens, clocks; gifts representing your country (e.g. Swiss chocolate, French
perfume); gifts with the SVBFG logo.
If visiting someone's home, bring chocolates, Indian sweets or flowers. If your host
drinks, Scotch whisky is a favorite.
Wrap gifts in red, green or yellow, as these are all considered lucky colors.
Reference the book “Kiss, Bow or Shake Hands” for more context on international
business practices and norms. You can find a copy at your local bookstore.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Inappropriate Business Gifts & Practices
Serving alcohol or pork to a Muslim; serving beef or giving a leather item to a
Hindu.
Refusing an offer of coffee or tea, especially in someone's home.
Black or white wrapping paper is considered unlucky.
India is a large, diverse country. Customs vary by region, so ask one of our employees in India or another local contact for advice.
Gift & Entertainment Guidelines – Israel
General Overview
Gifts, cash or entertainment for the purposes of bribery are prohibited by Israeli
law. There is a strict distinction between gifts within the private sector and gifts to
members of the public sector.
Recommended Business Gifts & Practices
Dinner, tickets to sporting events; gifts (flowers, wine chocolates) on major
holidays (Jewish New Year, Passover).
Invitations to newly opened international offices; invitations to events with
famous musicians/actors.
Reference the book, “Kiss, Bow or Shake Hands” for more context on
international business practices and norms. You can find a copy at your local
bookstore.
Inappropriate Business Gifts & Practices
Non-kosher food.
Scheduling events/activities on religious/national holidays (e.g. Yom Kippur,
National Memorial Day).
Gift & Entertainment Guidelines – United Kingdom
General Overview
There are various restrictions under both U.K. common law (non-statutory) and
statutory law surrounding the giving of corporate gifts or entertainment. Gifts,
cash or entertainment for the purposes of bribery are prohibited.
Recommended Business Gifts & Practices
Giving gifts is not a normal part of British business culture. Some British
business colleagues may feel embarrassed to receive any gift at all. The only
exception would be at the conclusion of a deal when it might be appropriate to
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
give a unique commemorative item to mark the occasion. Such items might be
gold, silver, or porcelain, with a suitable inscription. Alternatively, other
small gifts such as a pen or a book, again suitably inscribed, would be
acceptable.
Drinks, meals, invitations or tickets to events (sports, theater, musical) are all
acceptable forms of gifts.
Business gifts are never exchanged at Christmas but it may be appropriate to
send a card, particularly as an expression of thanks to business associates but
also as a means of maintaining valuable contacts. In the unlikely event that
you yourself receive a gift, you should be sure to reciprocate.
Reference the book “Kiss, Bow or Shake Hands” for more context on
international business practices and norms. You can find a copy at your local
bookstore.
Inappropriate Business Gifts & Practices
The U.K. has similar norms to the U.S. in the giving of business gifts.
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Appendix 6
SVB Steering Committee Members Telephone Numbers
President & CEO, Silicon Valley Bank & SVB Financial Group Greg Becker
001-408- 654-7345
Head of Relationship Management
John China
001-650-233-4207
Chief Marketing Officer
Brian Dennehy
001-408-654-3022
General Counsel
Mary Dent
001-650-320-1119
Chief Financial Officer
Michael Descheneaux
001-408- 654-7437
Head of Human Resources
Chris Edmonds-Waters
001-415-764-4706
Chief Credit Officer
Dave Jones
001-408- 654-7778
Vice Chairman of Silicon Valley Bank
Head of Strategic Relationships
Harry Kellogg
001-650- 233-4229
Head of US Banking
Joan Parsons
001-650-320-1159
Chief Strategy & Risk Officer
Marc Verissimo
001-408- 654-5582
Chief Operations Officer
Bruce Wallace
001-408- 654-3412
SVB “EthicsPoint” Hotline
Calls Within the U.S.
866-ETHICSP (866-384-4277)
Calls Outside the U.S.
Dial U.S. Country Access Code and 866-ETHICSP
(001-866-384-4277)
Web site Submission: www.ethicspoint.com
Available 24 hours a day, 7 days a week
All CONTACTS ARE CONFIDENTIAL
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms
Rev. May 19, 2011
Appendix 7
Overtime Approval and Claim Form
Top Related