Client data disclosure for transactions and services
Information on the disclosure of client-related information in connection with the execution of transactions and the provision of services
In connection with the execution of certain transactions and the provision of certain services, Schroder & Co Bank AG (the "Bank" or "we") may disclose certain information relating to our clients ("Clients" or "you"), to the relationship between the Clients and the Bank and/or to economic beneficiaries, representatives and other parties involved in the banking relationship (collectively "client-related information”) to third parties.
We would like to supplement the information set forth in the above-mentioned documents with this information sheet, which may be updated from time to time. You may find the current version of this information sheet on our website (https://www.schroders.com/en-ch/ch/wealth-management/client-data-disclosure-for-transactions-and-services-/). Please note that the purpose of this information sheet is not to amend or limit any of the contractual terms governing the relationship between the Client and the Bank; it is merely intended to provide supplementary information to the Client.
You can find further information in the information sheet published by the Swiss Bankers Association (SBA) ("Information from the SBA regarding the disclosure of client data and other information in international payment transactions and investments in foreign securities"), which is accessible here on the website of the SBA.
2. General Information on the disclosure of client-related Information
In connection with the execution of transactions and the provisions of services to the Client, the Bank may disclose client-related information to third parties in Switzerland and abroad. These third parties may include, e.g., correspondent banks, depositories, transfer agents, stock exchanges and other marketplaces, regulators, authorities or their representatives, system and infrastructure operators, and any other relevant or mandated third parties. Such disclosures may be required in order to execute the relevant transaction or provide the service (e.g., where such transaction or services rely on the use of a certain system or infrastructure, the operator of the relevant infrastructure may need access to information relating to the transaction or the service, which may include client-related information) or to comply with statutory or regulatory provisions in Switzerland and/or abroad or to comply with other applicable specifications, contracts or standards.
The Bank may disclose the client-related information before, during or after the execution of a transaction or provision of financial services. The disclosure may even be required after the banking relationship between you and the Bank has ended, e.g., if such disclosure is or becomes necessary under applicable statutory or regulatory provisions.
If you have several accounts or client relationships with different entities of the Schroders Group, the Bank may disclose information about you to other entities of the Schroders Group for the operation and management of the accounts or client relationships. In addition, being part of the internationally operating Schroders Group, the Bank may need to disclose client-related information to other entities of the Schroders Group, including for the purposes of risk management and consolidated supervision. We further draw your attention to section 17.1 of the General Terms and Conditions that explain further situations in which the Bank may disclose client-related information to other entities of the Schroders Group.
The disclosed client-related information may include the following:
- details about you or the economic beneficiaries, representatives and other parties involved in the banking relationship between you and the Bank, e.g. name, address, domicile, nationality, ID, passport number, contact details, KYC-related information, such as information on political or commercial affiliations, investigations or sanctions;
- details with respect to transactions or other services, e.g. origin of assets, other background information about transactions and services, client status, client history, the extent and duration of the client relationship with the Bank, other compliance-related information.
3. Limited protection of client-related information disclosed outside of Switzerland
You may instruct us to execute transactions or use services that have a foreign involvement. This may be the case, e.g., in case of international payment transactions or in case of transactions in foreign securities, financial instruments or rights or currencies, or if you authorize us to open an account with a foreign bank. The execution of transactions and use of services that have such foreign involvement may result in the disclosure of client-related information to third parties outside of Switzerland and the Bank may have no control about the use of client-related information by such third parties. In addition, we may disclose client-related information to recipients outside of Switzerland in the circumstances described in the General Terms and Conditions and in other applicable terms.
Once client-related information is disclosed to a third party outside of Switzerland, it may no longer be protected by Swiss law. Banks outside of Switzerland and other third parties are not bound by Swiss bank-client confidentiality. Local law applicable where the recipient of client-related information is located or where such information is processed may not offer the same level of protection as Swiss law and local authorities may obtain access to client-related information from the recipient of such information under applicable local law. In particular, foreign laws and official orders may require client-related information to be forwarded to foreign authorities, supervisory bodies or other third parties. Swiss law also allows the Bank to disclose certain client-related information directly to foreign authorities, supervisory bodies or other third parties under certain circumstances.
4. Country-Specific Disclosure Requirements
In addition to the general information provided above, for certain specific markets in connection with which you may wish to execute transactions or use services, we would like to draw your attention to the following country-specific information on disclosures of client-related information. Please note that this list may not be exhaustive and does not limit the information provided elsewhere in this document, the General Terms and Conditions or other applicable terms, and the Bank's Privacy Notice. Similar disclosure requirements may exist in other markets or jurisdictions where you may wish to execute transactions or use services.
With respect to the stock exchange dealing in Hong-Kong, the regulations regarding the disclosure of the identity of customers (Hong KongClient Identity Rule Policy) of the Securities and Futures Commission of Hong Kong ("SFC") apply. If you request transactions at the Hong-Kong stock exchange (in particular securities and futures), the Bank informs security dealers in Hong Kong, the SFC or another supervisory board of Hong Kong of your identity. In addition to the information about the Client's identity, however, it may also be necessary under certain circumstances to supply more detailed information about the identity of the individual persons or companies that initiated the transaction originally and/or as an intermediary and who bear the economic risk of the transaction.
For further information, please refer to the data sheet of the SFC, explaining the Hong Kong Client Identity Rule Policy, which is available here on the website of the SFC. You can obtain the data sheet of the SFC from your client adviser. Your client adviser is happy to discuss any questions you may have.
Securities traded in Norway are subject to Norwegian laws and regulations. For such transactions, the Bank has to open a sub-account in your name at the local Central Securities Depository ("CSD") in Norway. Further, the Bank is required to provide all information to its custodian bank(s) and/or broker(s) in Norway and to the local CSD that may be necessary now and in the future for maintaining and conducting the custody account, including, but not limited to, your name, address, tax ID and a copy of your passport. Under Norwegian laws, such information about you may be disclosed to authorities in Norway or other recipients.