Financial Crimes
Ryan Specialty is committed to compliance with applicable laws and regulations, and prohibits bribery and corruption in any form.
Examples of applicable laws and regulatory agencies include (but are not limited to) the U.S. Foreign Corrupt Practices Act, the U.K. Bribery Act of 2010, the United Nations Convention against Corruption and the Organization for Economic Co-Operation and Development.
Ryan Specialty prohibits Employees and Trading Partners from engaging in corrupt conduct. This prohibition is applicable to all transactions and activities, including all government and private business transactions. Employees and Trading Partners are prohibited from directly or indirectly offering, promising, giving or authorizing anyone to give money or anything of value to a government official for the purpose of obtaining a business advantage.
Foreign Corrupt Practices Act
The Foreign Corrupt Practices Act (“FCPA”) addresses illegal or sensitive payments or gifts to individuals or organizations in countries outside the U.S. and applies to all Employees. The FCPA prohibits directly or indirectly, offering to pay, making a payment, promising to pay, or authorizing the transfer of funds to any foreign official, foreign political party, or candidate for foreign political office in order to induce or influence that person to use their authority or influence to assist its business.
U.K. Bribery Act
The U.K. Bribery Act of 2010 prohibits companies that have a presence in the U.K., including Ryan Specialty companies based in the U.K., from failing to prevent activities that constitute bribery. The U.K. Bribery Act prohibits a wide range of activities, such as the payment or receipt of commercial bribes between private individuals and corporations as well as facilitation payments.
Unfair Inducements
Ryan Specialty prohibits Employees from entering into any contracts or from giving any business to those who may have offered an inducement, and likewise, Employees are prohibited from offering inducements to others, especially when that inducement could be considered to be a bribe. You must avoid engaging in any activities that could create the perception of an inducement or bribe.
International Sanctions
Sanctions encompass a broad range of enforcement options that do not involve the use of armed force. Sanctions range from comprehensive economic and trade sanctions to more targeted measures such as arms embargoes, travel bans, and financial or commodity restrictions. Ryan Specialty prohibits any Employees from entering into any business or contract that could be in breach of sanctions applicable to that business, contract or contracting party.
Anti-Bribery and Corruption
Ryan Specialty strictly prohibits bribery and corruption in any form, and requires you to abide by all applicable laws, treaties, and regulations that forbid bribery – both in the private and public sectors. Ryan Specialty is committed to maintaining a business environment that is free of bribery and corruption in all forms. You must avoid engaging in any activities that could create the perception of impropriety.
Insider Trading
In the course of doing business, you may have access to inside information or become aware of inside information regarding Ryan Specialty or other companies, including our clients. You must not buy or sell the securities of any company, including Ryan Specialty, while you are aware of inside information about the company.
Inside information is any non-publicly available information that would reasonably be expected to affect the price of a security or that would influence an investor’s decision to buy, sell or hold a security. Examples of inside information include financial results; financial forecasts; possible mergers, acquisitions or dispositions; knowledge of important product developments; and changes in senior management.
You may not use any inside information you receive in the course of your employment at Ryan Specialty to buy or sell securities of any company, including Ryan Specialty or our clients. This is known as “insider trading.” In addition, you may not disclose any inside information to anyone who might use it to make an investment decision, or make buying or selling recommendations to anyone based on inside information. This is known as “tipping.” Insider trading and tipping are illegal, and may result in civil and criminal penalties.
Directors, executive officers, employees and colleagues are subject to additional trading restrictions, and have been notified of these restrictions by the Legal Department. Questions regarding transactions in Ryan Specialty stock should be directed to the General Counsel.
Anti-Money Laundering
Money laundering is the process used to transform funds generated from illegal activities into legitimate financial institutions or businesses to conceal the initial source of the funds. In order to avoid any potential involvement with money laundering, it is of paramount importance that Employees maintain vigilance regarding Clients and Trading Partners. Employees should make reasonable efforts to prevent money laundering by determining the true identity of all clients and Trading Partners.
Fraud and Abuse
Ryan Specialty expects Employees to be vigilant in the prevention of fraud and abuse of funds, assets, and resources. Minor administrative or managerial irregularities on the surface can at times be indicators of fraud and abuse. Any deception to deprive Ryan Specialty, its Clients or Trading Partners of something of value is expressly prohibited.