Ethics and integrity

Setting high standards

Our reputation for integrity is one of our most important assets. We hold ourselves to standards that not only meet those required by the laws and regulations that apply to us, but also to our principles, which are rooted in exceeding our clients’ expectations. 

Business conduct and ethics

Our Code of Business Conduct and Ethics sets out basic principles to guide employee conduct. The code is supported by employee conduct policies and programs and reinforced through employee training.

We have zero tolerance in relation to illegal or unethical conduct and this is articulated in our relevant policies, including policies on conflicts of interest, gifts and entertainment, money laundering and counter terrorism, fraud, sanctions, outside activities, political contributions, and bribery and corruption. Any employee who violates the requirements of the Code of Business Conduct and Ethics, or many of our other policies, is subject to disciplinary action.

BlackRock expects the same high standards of those who represent us and we conduct appropriate due diligence on our business partners according to the risks they present, including corruption risk.

BlackRock’s Guidelines for Anti-bribery and Corruption Compliance

BlackRock, Inc, its subsidiaries, affiliates and joint ventures (collectively, “BlackRock” or the Firm”) and its employees commit to conduct its business activities in the highest ethical and professional manner. BlackRock’s reputation for integrity is one of its most important assets, and compliance with anti-bribery and corruption laws is fundamental to business conduct. BlackRock has zero tolerance for bribery and corruption: all improper payments in dealings with public officials or private individuals are strictly prohibited, as is offering or giving anything of value for a corrupt purpose.

Our Global Anti-Bribery and Corruption Policy (the “Policy”) requires all BlackRock directors, officers, employees, agents, advisors, consultants, partners and representatives to conduct their activities in full compliance with all applicable anti-corruption laws, including without limitation, the United States Foreign Corrupt Practices Act, the UK Bribery Act of 2010 and any other anti-corruption laws in effect in countries where the firm operates. BlackRock prohibits any transaction, including facilitation payments, which could constitute a bribe or a corrupt payment to or from a public official or body, or a private entity or individual. In addition to the Policy, BlackRock has implemented the following to manage associated risks as well as meet regulatory principles:

• Global Gifts and Entertainment Policy
• Global Sponsored Visitor Policy
• Global Third-Party Risk Management Policy
• Private Advisory Consultants Policy
• Direct Private Transaction Origination and Oversight Policy
• Sourcing and Vendor Management Policy
• Global Fraud Policy

BlackRock employees are subject to mandatory training on the Anti-Bribery and Corruption Policy and the applicable regulations at least annually. Employees are tested on their knowledge of the Policy and must obtain a minimum score to receive a successful completion. Additionally, employees are subject to nonmandatory, tailored trainings, which include hypothetical scenarios, to raise awareness of specific risks associated with certain businesses and jurisdictional nuances.

The Policy and training are core to BlackRock’s Global Anti-Bribery and Corruption Program (the “Program”), which is maintained and regularly assessed by Compliance through an Enterprise-wide Anti-Bribery and Corruption Risk Assessment that covers all businesses and regions and uses a risk-based testing model to evaluate control effectiveness. The results drive enhancements, including by putting in place governance and oversight in relation to higher risk transactions or relationships, that mitigate BlackRock’s exposure – and our clients’ exposure – to corruption risk. In addition, the program is subject to periodic assessment by the Firm’s auditors .

Employees are encouraged to utilize the BlackRock Business Integrity Hotline or the BlackRock Integrity Reporting Website to report suspicions or actual violations of the Policy. All reports of potential violations of policies are investigated and reported to relevant risk and governance committees which are led by the firm’s leadership. The Firm’s proxy statement sets out more about the role of our Board of Directors in the oversight of risk management.

For more information on BlackRock’s Business Ethics, visit: Code of Business Conduct and Ethics

Additional Resources

BlackRock's Anti-Money Laundering and Sanctions Program Attestation Letter

Wolfsberg Group Financial Crime Compliance Questionnaire