Cayman Islands Bankers’ Association Banking Code of Conduct

1. Introduction

This is an agreed Code of Conduct which sets standards of good banking practice in the Cayman Islands. It explains how member banks who commit to this Code are expected to serve and support their customers. Within this Code of Conduct, “you” means the customer, and “we”, “us” and “our” means the financial institution with which the customer deals.

2. Integrity and Professionalism

We will act with integrity and maintain the highest standards of professionalism in dealings with customers, regulators, and each other. We will ensure fair, honest, and transparent treatment of all customers, aligning with the Financial Conduct Authority’s Principle 6: “A firm must pay due regard to the interests of its customers and treat them fairly.”

3. Fair Treatment of Customers

We will:

• Ensure that products and services reasonably meet the needs of identified customer groups and are targeted accordingly.

• Provide customers with clear, timely, and comprehensible information so they can make informed decisions.

• Avoid unfair commercial practices such as misleading advertising or aggressive selling.

4. Transparency and Disclosure

We will provide full and transparent disclosure of fees, terms, and conditions. Any changes to the charges or terms associated with a product or service will be communicated in a timely and understandable manner.

We will:

• Use plain language in customer communications and avoid the use of terminology that may not be easily understood.

• Provide key product information documents where applicable.

• Disclose risks clearly, particularly for complex financial products.

• Ensure that products and services are fairly priced and information on pricing is fully disclosed to you in a timely manner and prior to any commitment being made for a product or service.

• Ensure that products and services are designed with client needs and banking requirements in mind.

• Provide you with access to account statements and activity on your accounts to enable you to appropriately monitor and manage your financial products and accounts.

• Provide a minimum of 30 days’ notice prior to implementing new or increased fees for products and services.

5. Financial Promotions and Marketing

We will:

• Ensure all marketing materials are clear, fair, and not misleading.

• Ensure promotions include risk warnings when applicable.

• Avoid pressure tactics and ensure promotions target suitable customer segments.

6. Vulnerable Customers

We will:

• Work to identify and support vulnerable customers, including those with physical or mental limitations, financial hardship, or limited financial literacy.

• Implement training and systems to ensure front-line staff can recognize and appropriately support vulnerable clients.

• Provide special assistance and support to senior citizens when needed.

7. Data Protection and Privacy

We will ensure customer data is collected, processed, and stored in accordance with the Data Protection Act of the Cayman Islands and GDPR equivalent standards, including data minimization and rights to access, correction, and deletion.

8. Conflict of Interest

• We will avoid situations where conflicts of interest could harm customers and disclose any material conflicts clearly and promptly.

• We will ensure that incentive structures for staff do not undermine the duty to act in the best interests of customers.

9. Financial Education and Inclusion

We will:

• Promote financial literacy among customers through education campaigns and financial support for charitable causes which benefit the communities we serve.

• Offer basic banking services on fair terms to foster inclusion.

10. Consumer Lending

We will:

• Act as responsible lenders, taking into consideration client needs and circumstances as well as sound lending practices.

• Assess the client’s financial position to ensure products offered are affordable and sustainable, and will not cause financial hardship.

• Consider cases of financial difficulty sympathetically and positively. We will work with clients who have experienced financial difficulties resulting in loan delinquency, with an aim of remediating such delinquency through forbearance or restructuring where appropriate.

• Not commence legal proceedings on borrowers who have defaulted on a loan or mortgage until we have made every reasonable effort to agree an alternative arrangement or remediation plan.

• Publish changes to our Prime or Base lending rates prior to implementing such changes.

11. Changes to our Banking Centres

If we plan to close or relocate any of our banking service centres, we will inform you within a reasonable period of time prior to the closure or relocation. We will also tell you how we will continue to provide banking services to you.

12. Complaint Handling and Redress

We will:

• Establish accessible, transparent, and fair complaint-handling procedures.

• Ensure that complaints and grievances are resolved in a timely manner through an efficient complaint resolution mechanism, with clear communication to you throughout the resolution process.