 Foreword This Citadel APAC Employee Handbook is supplemented by separate Addenda for your Home Location (as defined below).
References below to the Handbook mean the Handbook and the Addenda which apply to you. This Handbook supersedes all previous employee handbooks, policies, practices and procedures applicable to Citadel employees whose normal place of work is in APAC. In addition, this Handbook supplements Citadel’s compliance policies, manuals, procedures and bulletins, which are available on our Legal and Compliance web or intranet page, as appropriate. You should also refer to the Intranet’s “Employee Resources” and “My Benefits” tabs for additional policies and benefits information. It is important that you adhere to all of Citadel’s policies and procedures, whether included in the Handbook or elsewhere. You may be required to affirm and accept the information contained in the Handbook on a yearly basis, and by affirming the Handbook, you will be deemed to have accepted the terms and conditions of employment set out in it (as amended from time to time). We expressly reserve the right to modify the Handbook or amend or terminate any policies, procedures or employee benefit programs, whether or not described in the Handbook, at any time, or to require and/or increase employee contributions toward such benefit programs. We will provide you with the appropriate training regarding these policies. If you have any questions regarding the Handbook, please contact Human Resources. Table of Contents
A. Introduction and Welcome
Welcome to Citadel! Citadel is a place where extraordinary people come together as a team in the pursuit of excellence. We have a proven history of collaborating to solve complex problems that many think unsolvable and breaking down barriers that others deem insurmountable. Our extraordinary colleagues are the key to our success. We take pride in our cohesive and cooperative work environment; an environment that offers exciting and rewarding experiences and produces superior results because of the efforts of the people involved.
Purpose of this Handbook
This Handbook is your guide to your employment at Citadel and is intended to highlight important policies, procedures and programs. You should read this Handbook and familiarise yourself with its contents. Updates to the Handbook will be published periodically. Please refer to the Intranet for the most recent version.
If you have any questions regarding any of Citadel’s policies, procedures or programs, please ask your manager or Human Resources for assistance. Note that additional policy information and forms can be found on the Intranet. Handbook Structure
This Handbook is divided into a number of sections:
Section A contains this introduction. Section B contains additional terms and conditions of employment which supplement those set out in your Offer Letter, Employment Terms, and other relevant documents. The terms set out in Section B are contractually binding. Section C contains our policies which apply to you. These do not form part of your contract of employment and are not contractually binding (unless deemed by the laws of your Home Location to be contractually binding) but they are important and you are expected to comply with them. Failure to do so may result in disciplinary action up to and including dismissal. Addenda – you should refer to the relevant Addendum for the Citadel location where you normally work. This contains additional policies and information applicable only to employees working in that country or location. Governing Law and Interpretation
This Handbook is governed by and construed in accordance with the laws of the location in which you normally work. In this Handbook we refer to this as your “Home Location”. The Handbook is also subject to the provisions set out in the Citadel Dispute Resolution Procedure.
In this Handbook: “Citadel” means the Citadel entity which employs you and any other Citadel Group entities in your Home Location (or assignment/seconded location where applicable); and “Citadel Group” has the meaning given in the definitions section of your Dispute Resolution Procedure. References to “we”, “us” and “our” are to Citadel. B. Supplementary Terms and Conditions of Employment
This Section B of the Handbook, together with the following documents, comprise your contractual terms and conditions of employment (i.e. your contract of employment):
1. Offer Letter and/or any separate International Assignment Letter/Secondment Letter (as appropriate);
2. Employment Terms;
3. Non-Disclosure, Non-Compete, Supplemental Non-Compete (as applicable) and Non-Solicitation Agreements;
4. Dispute Resolution Procedures in place from time to time;
5. Employee Incentive Plans; and
6. Affirmations.
The terms and conditions set out in the above documents take precedence if there is any inconsistency or conflict between them and Section B of the Handbook (as supplemented by the corresponding section of your Home Location Addendum).
If you are assigned/seconded to work for Citadel in APAC from another member of the Citadel Group outside of APAC, your contractual terms of employment (and benefits) will continue to be governed by your Offer Letter and/or contract of employment (except in relation to work schedules and holidays which will be governed by local custom in your host location instead), together with any separate international assignment letter or secondment letter (as applicable). You will be expected to adhere to the policies in Section C of this Handbook and the relevant host location Addendum for the duration of your assignment/secondment.
Except where the contrary is stated, all consents and authorisations which you are required to obtain from us shall be given by your manager or the Chief Operating Officer, or by such other person as they may nominate from time to time.
With the exception of any member of the Citadel Group, a person who is not a party to any of the documents listed above, has no rights to enforce the terms of those documents or Section B of this Handbook (as supplemented by the corresponding section of your Home Location Addendum).
We reserve the right to make reasonable changes to any of the terms and conditions in this Section B and the Addenda.
Your Appointment and Working Hours
Right to Work and Background Checks
Your employment with us is conditional on you being legally entitled to work in your Home Location at all times during your employment. It is also conditional upon us receiving satisfactory results of full background, reference and other checks, where applicable.
In particular, to the extent permitted by law, the commencement and continuation of your employment is conditional upon satisfactory results of a standard pre-employment drug screen in compliance with local laws. However, we reserve the right to waive the requirement to undergo a pre-employment drug screen.
Before you start employment with us and, if requested, at any time during your employment, you must provide us with acceptable evidence of your right to work in your Home Location. You will allow Human Resources to inspect your original passport/identity card or other documentary evidence of your right to work in your Home Location and take a copy for our records.
If you require a work visa or other legal permission to work in your Home Location, your employment with us is and will continue to be conditional upon such visa or permission being granted and remaining in force and you must:
Subject to applicable laws, your employment with us will terminate automatically and without notice if you cease to be lawfully entitled to work in your Home Location.
Restrictions and Regulatory Approval
Your employment is also conditional upon you:
Subject to applicable laws, your employment with us may be terminated without notice if you are unable to comply with these requirements.
Commencement and Continuous Service
The commencement date of your employment will be as stated in your Offer Letter or notified separately to you in writing. Your period of continuous employment will begin on the commencement date unless otherwise stated. Your employment will continue indefinitely until terminated in accordance with your Employment Terms or this Handbook.
Probationary Period
Upon commencement of your employment, you will be subject to a probationary period to review your suitability for the job. The duration of this probationary period is set out in your Offer Letter and in the Home Location Addendum. Unsatisfactory performance or conduct could result in a decision to terminate your employment in writing at any time during or at the end of your probationary period. We reserve the right to extend your probationary period at our sole discretion.
Your employment may be terminated during the probationary period in accordance with local law. Please refer to the Home Location Addendum for further information.
On satisfactory completion of your probationary period (or any extension), and subject to the termination provisions in relation to Right to Work and Regulatory Approval in this Handbook, your notice period will be as set out in your Employment Terms. Unless you are notified otherwise in writing, you will be deemed to have successfully completed your probation at the end of your probationary period.
Job Title, Duties and Training
Your job title is as set out in your Offer Letter. Your role will include any duties that we may assign to you consistent with your job title (including any regulatory duties applicable to your role) and any other duties that we reasonably ask you to undertake from time to time. We reserve the right to make certain changes to your title, duties or reporting line (and any written job description) at any time. In addition, you may be assigned/seconded to, or asked to perform duties for, other members of the Citadel Group.
You must attend any compulsory training given. Please refer to Section C of this Handbook and the Intranet for further information on training programs that we offer.
Normal Place to Work
Your normal place of work is set out in your Home Location Addendum. You may be required to undertake business travel within your Home Location and to other jurisdictions including to the offices of any member of the Citadel Group, clients and business associates, for the proper performance of your duties. You may also be required to travel to other Citadel Group offices in other jurisdictions for training which, on commencing employment, may be for an extended period of several months.
Your Work Schedule
Citadel’s typical work week is Monday to Friday. Your manager will determine your normal working schedule and may authorise variations from this schedule. While your schedule will typically reflect our normal office hours for your Home Location, you may be required to work additional hours. Citadel may modify your normal schedule from time to time to meet varying business conditions. Schedules for part-time employees will be as agreed with the relevant manager(s). Please refer to your Home Location Addendum for further details on your work schedule.
Attendance and Punctuality
Your regular attendance and punctuality are vital to operations and performance, and are your responsibility. If you are unable to work because of injury or illness or will be late for any reason, you must notify your manager in accordance with the applicable sickness or other notification requirements. In the absence of mitigating circumstances, you are expected to notify your manager of your absence or lateness prior to the start of your scheduled workday. Failure to do so will result in an unauthorised absence. Excessive unauthorised absences or lateness may result in disciplinary action, up to and including termination of employment.
Outside Interests and Whole Time and Attention
As an employee of Citadel, you are expected to devote your full business time and attention to the performance of your duties at Citadel. Accordingly, you may not:
Prior to commencing any Outside Business Activity, employees must obtain approval via the Outside Business Activity Disclosure Form which is available on the Compliance Intranet page. Your manager may request that you terminate or modify the terms of any outside work at any time, in order to allow you to devote your business energies to Citadel business. Refusal to comply with such a request may result in disciplinary action, up to and including termination of employment.
Personal Solicitations
To maintain a professional and respectful work environment and to avoid potential offence or disruption, you should not distribute literature or printed materials of any kind, sell merchandise, solicit financial contributions or otherwise promote causes to your colleagues without prior approval from Legal & Compliance. Your attention is also drawn to our Political Contributions Policy which is available on the Intranet.
Salary and Expenses
Salary and Benefits
Salary
Your basic salary is as set out in your Employment Terms. This will be paid monthly after deduction of any applicable tax and social security contributions and any other statutory or contractually agreed deductions (to the extent permitted by law), or deductions required by law, in equal instalments in arrears in accordance with our procedures from time to time in force. Currently payment is made on or around the 25th day of each month and credited to the bank account nominated by you.
Your salary will be reviewed from time to time. Any changes are solely at our discretion and will be notified to you in writing. Any increase in salary should not give rise to any expectation of further increases in subsequent years. Except where prohibited by the laws of your Home Location, all such communications should be kept private and confidential and should not be discussed with other employees. Any queries relating to salary payments should be raised with the Payroll Team without delay.
Benefits
During your employment with us, you will be eligible to participate in a number of benefit schemes, subject in each case to you meeting (and continuing to meet) any terms, requirements and conditions imposed by the vendor or insurer from time to time. Details of the current scheme(s) and scheme documents are available on the Intranet, or alternatively from Human Resources.
We may amend, replace or discontinue any of these benefits or change the benefit providers at our discretion at any time. If a vendor or insurer refuses cover or fails to provide a benefit then we shall be under no obligation to take any further steps to provide it and you will have no right of action against us in respect of such a refusal or failure.
Expenses and Deductions
We shall reimburse you for all expenses reasonably and necessarily incurred by you in the proper performance of your duties in accordance with the Travel and Expense Policy as amended from time to time, and available on the Intranet.
Any payments (including reimbursement of overpayments) due from you to us or any member of the Citadel Group may be deducted from your salary, bonus, unvested or vested CEIF or other deferred compensation plans, incentive awards and/or from any other money that we owe to you, to the extent permitted by law. To the extent Citadel is required to pay tax, social security contributions, any levy and/or associated costs in any jurisdiction other than your Home Location, it may deduct these from any sums owed to you on the same basis. All employees must review this policy and commit to maintaining a work environment free from harassment, discrimination, and retaliation. In addition, all employees must complete harassment prevention training on an annual basis.
Bonus Awards
Bonus/Incentive Awards
Citadel retains the option, in its sole discretion, to pay bonuses to employees on a periodic basis, in recognition of your achievements. Decisions as to whether to award a bonus, the amount of such bonus, and who receives a bonus are entirely at our discretion and you will be notified in writing whether you will receive a bonus. Eligibility for incentive awards, deferred awards, equity awards and other bonuses or special payments is also conditioned on the employee meeting all terms, conditions and/or obligations of the applicable award documents (including any partnership agreements, program documents, and award letters), as amended from time to time.
You will not be eligible to receive a bonus/incentive award if your employment has been terminated (by you or us) or if you are under a notice of termination (whether given by you or us) at the time such bonus/incentive award is paid. The decision whether to award you a bonus/incentive award and/or the payment of any bonus/incentive award that has been awarded may be deferred at our discretion in the event that you are under investigation for a potential disciplinary offence or disciplinary proceedings are pending or proceeding against you. If disciplinary allegations are upheld against you between the date of the award of any bonus/incentive award and payment of bonus/incentive award, the award may be reconsidered and may be reduced (or cancelled entirely) at our discretion.
Annual Leave and Sickness
Annual Leave
Entitlement
Unless otherwise specified in your Home Location Addendum, our annual leave year is the calendar year. In addition to public holidays in your Home Location you are entitled to the specified number of paid annual leave days per year as set out in your Home Location Addendum (your “Annual Leave Entitlement”) to be taken at times convenient to us. Your Annual Leave Entitlement is inclusive of any statutory annual leave entitlement. If we require you to work over a public holiday you may be entitled to alternative time-off and any additional payments in accordance with the law in your Home Location.
Procedures
We will not unreasonably refuse requests to take annual leave, although approval is granted in our sole discretion. Please ensure that you make every effort to give your manager reasonable notice of any proposed annual leave that is requested. You may not take annual leave without the prior approval of your manager. Where you hold a regulated position, it is especially important that annual leave absences are booked and planned well in advance to ensure appropriate temporary cover of any regulatory responsibilities.
Carry over of any accrued but unused Annual Leave Entitlement is set out in the Home Location Addendum.
Please refer to your Home Location Addendum for further details on procedures for taking annual leave.
Termination of Employment
On the termination of your employment we will, where required by the laws of your Home Location, pay you in lieu of any accrued but untaken Annual Leave Entitlement. Any such payment in lieu will be based on the accrual rate specified in your Home Location Addendum. Subject to applicable laws, we reserve the right to require you take any outstanding Annual Leave Entitlement during your notice period (including during any period of garden leave) to the extent permitted by law.
Sickness
Notification and Sick Pay
We recognise that employees may need to take time off from work as a result of sickness or injury. You must comply with the notification requirements set out in your Home Location Addendum in respect of any absence and in order to receive any statutory or company sick pay that you may be entitled to. Failure to do so may also be a disciplinary offence. Subject to local law, we reserve the right to only pay statutory sick pay where you take sick leave whilst under investigation or where disciplinary proceedings have commenced against you.
Medical Examinations
We reserve the right to require you to be examined at any time by an independent doctor or medical practitioner of our choice and at our expense, and you agree to give consent to the disclosure of any medical report prepared by such person to us. Subject to local law, we reserve the right to only pay statutory sick pay and other statutorily required benefits to you if you unreasonably refuse to comply with any such requests, if you are deemed fit to return to work or if you fail to follow medical advice concerning treatment, medication or rehabilitation without good reason.
Please refer to your Home Location Addendum for further details on procedures for taking sick leave. Rules and Codes of Practice
Ensuring Ethical Responsibility
We expect all of our employees to act with the highest standards of integrity. You should at all times be guided by the fundamental principles of trust, honesty, objectivity, fairness and respect for yourself and others. Our reputation for high regulatory and professional standards is vitally important. Every employee has a direct personal responsibility to:
Due to the nature of Citadel’s activities, our practices and procedures are highly regulated. Specific standards and guidelines for ethical conduct are explained in the Code of Conduct or Code of Ethics (as applicable to you) and any applicable Compliance Manual, and other policy statements or manuals that you may receive from time to time. If you are unsure what is expected of you or if a matter is particularly complex or sensitive, you should discuss the matter with your manager, Human Resources, the Chief Compliance Officer or the Chief Operating Officer.
Cooperation with Investigations
From time to time, and in our sole discretion, we may authorise or conduct an investigation into possible misconduct, rule or regulatory breaches or otherwise seek to gather information for compliance purposes. You are expected to fully co-operate with any request to participate in such an investigation. Investigations may be conducted in person, via telephone, or over platforms such as Zoom, and you may be required to turn on the webcam. Failure to cooperate so may result in disciplinary action.
Protecting Confidential Information
As our employee, you will have continuous access to proprietary information, confidential business information and trade secrets regarding our affairs, and our current and former employees and investors (and those of any member of the Citadel Group). You are responsible for maintaining this information in strict confidence. You may be required to accept and sign the following additional documents as a condition of your employment. Where applicable, they will be provided to you with your offer documentation:
You must familiarise yourself with these documents.
You are also responsible for complying with Citadel’s Confidential Information and Material Non-public Information Policy and other policies related to confidential information such as Citadel’s Information Barrier Policy and IT Systems Use Policy which can be found on the Intranet.
Any improper use, transfer or disclosure of Confidential Information (which is defined in your Dispute Resolution Agreement), whether for business or personal purposes, may result in disciplinary action, up to and including summary dismissal, and you may also be subject to civil and criminal penalties.
Generally, all information obtained and work product produced – including, but not limited to, Confidential Information, documents (whether printed, electronic, white-boarded, or other), data, source code, executable binaries, notes, and diagrams – during your employment with Citadel, are Citadel property. You may not remove documents or work product from Citadel’s premises without authorisation. You are responsible for taking necessary care to adequately secure our Confidential Information against inadvertent disclosure. This includes, but is not limited to, sealing files, locking cabinets, desk drawers and briefcases, avoiding sensitive conversations on mobile phones and in public areas (particularly enclosed areas such as elevators and airplanes), never sending Confidential Information to your personal email or data-storage account, and ensuring that data stored on computer hardware, such as laptops, cannot be viewed by others in your surroundings and is password protected or encrypted where appropriate. You must ensure you do not store Citadel documents or work product in unapproved locations, or store using unapproved tools, including source code management systems, or document management or workflow systems. In addition, you must carefully safeguard Confidential Information provided to you by third parties by virtue of your employment with Citadel. Personal photographic and/or other imaging devices, including phone cameras, are not to be used in Citadel offices at any time.
If you leave Citadel, you may not in any way misappropriate, store, use, disclose, or transmit Confidential Information obtained while working here.
Nothing in this Section will prevent you from reporting misconduct in accordance with the Reporting Misconduct section in this Handbook and your Home Location Addendum or from:
Citadel is firmly committed to cooperating with regulatory inquiries and examinations. You should abide by our policies and agreements in relation to communications with regulatory authorities, including but not limited to the Code of Ethics or Code of Conduct (as applicable to you).
Avoiding Conflicts of Interest
We respect the right of employees to invest in private enterprise and to engage in appropriate personal activities. However, you are responsible for avoiding any conflict between your personal interests or activities, and our interests and those of the Citadel Group. As a general rule, this means that you must not acquire a personal interest in securities or properties or permit yourself to come under any personal obligation that might tend to cause you to use your position with us for private gain or to obtain benefits or favours either for yourself or anyone you know, or will influence your conduct on our behalf. Conflicts can arise with suppliers, investors and other organisations or people seeking to do business with us and any member of the Citadel Group, and can involve investments, outside employment or personal relationships.
If you encounter a situation in which you or an immediate family member, including your spouse, minor children and other adults living in your household, might have an actual or potential conflict of interest, you must immediately discuss the situation with your manager, the Chief Compliance Officer or the Chief Operating Officer. This allows appropriate personnel within the organisation to make an informed, independent decision regarding a potential conflict. We will determine in our sole discretion whether a conflict exists and what action, if any, should be taken. Failure to follow these steps or breaches of the conflict rules as set out above may result in disciplinary action.
Disclosing Potential Conflicts
We have established certain disclosure requirements designed to help you comply with these professional standards of responsibility and thereby prevent conflicts of interest. These policies attempt to cover common situations but are not exhaustive. You must exercise sound judgement consistent with these policies at all times in the performance of your duties. If you are unsure as to the conduct required from you or have any questions either regarding your own activities or those of your co-workers, you must seek guidance from the Chief Compliance Officer or the Chief Operating Officer.
Financial Interests
You must disclose any financial interests that you or any member of your immediate family holds in a present or potential investor, vendor or competitor of ours (or any member of the Citadel Group). Immediate family includes your spouse, minor children and any adult living in your household. Such financial interests, which include individual brokerage accounts, must be identified on the Personal Account Information Form or Private Placement Disclosure and Pre-Approval Form as appropriate. If you do have such a financial interest, you must not represent us or be involved in any transaction with such present or potential investor, vendor or competitor of ours (or any member of the Citadel Group). This sub-section does not apply to ownership of less than 1% percent of the equity or debt of a publicly held corporation.
As further explained in the Code of Conduct or Code of Ethics (as applicable to you) and any applicable Compliance Manual, and the Policies and Procedures regarding Confidential Information, Material Non-public Information, Information Barriers, and Personal Investment (the “Policies”), any trading in Covered Accounts as defined in the Personal Investment Policy, such as trading on your personal account, and any trading your immediate family wishes to make on their personal accounts must be approved in advance. Approval must be sought for personal account trading by using the relevant platform at the Personal Investment Center located under “Legal & Compliance” on the Intranet. Failure to comply may result in disciplinary action, up to and including dismissal, as well as other legal implications and penalties.
Personal Data
Processing of personal data and Citadel’s policies
In a similar way to many businesses, we hold and process a wide range of information, some of which relates to individuals – known as “personal data”. In relation to the protection and processing of employee personal data in your Home Location, please refer to the relevant section of your Home Location Addendum. To help us comply with data protection regulations, we have also adopted policies including the Information Security Policy and IT Systems Use Policy. Copies of these policies may also be found on the Intranet. You must read these and comply with them in carrying out your work. If you are unclear how the policies apply or, more generally, what you need to do to comply with the law on data protection, you should speak to Human Resources or contact Legal & Compliance via email at AsiaLegalCompliance@citadel.com
In the event of a data breach, you must notify your line manager and Legal & Compliance at AsiaLegalCompliance@citadel.com immediately. Failure to provide notice of a breach or to provide information as set out above will be treated seriously and disciplinary action may be taken. Please refer to your Home Location Addendum for further information about data breaches.
We monitor our premises and the use of our communication facilities for the purpose of monitoring compliance with our policies – in particular our data, IT and Compliance policies - and where non-compliance is suspected, investigating in a more targeted way. There are CCTV cameras in operation within and outside our offices, which are used for the following purposes:
We reserve the right to amend any notice, policy and procedure documents relating or referred to above from time to time.
Leaving Citadel
Notice of Termination of Employment
We reserve the right to enforce your full notice period. However, in some situations, we may consent to waiving all or part of your notice period at our discretion.
Where legally permissible in your Home Location, we reserve the right (but shall not be obliged) to terminate your employment with immediate effect and pay your salary only (but not any other benefits, bonuses or other pay, unless required by law) in lieu of all or any of your notice period. This applies whether notice has been given by you or us and this right may be exercised at any time. Any payment in lieu of notice will be subject to any applicable tax or other deductions required by law. Any payment in lieu of notice shall be made within one month or by such earlier date as required by law of us notifying you in writing that we intend to exercise this right.
We also reserve the right to require you not to perform any duties and/or not to attend our premises and not to contact any of our (or any member of the Citadel Group’s) clients, counterparties, brokers or employees once notice of termination of employment has been given. This is known as garden leave. During any period of garden leave you will continue to receive your salary and benefits (or a payment in lieu of the value of such benefits, where applicable) and you will be required to take any accrued outstanding Annual Leave Entitlement, to the extent permitted by law. You will not be eligible to receive a bonus or an Incentive Award. For the avoidance of doubt, you shall not work for anyone other than us during garden leave and you shall continue to comply with your express and implied duties under your terms of employment (except those from which you are explicitly released by Citadel). In particular, your obligations of good faith, fidelity and confidentiality continue to apply (including but not limited to, your obligations under the Non-Disclosure, Non-Compete, Supplemental Non-Compete (as applicable), Non-Solicitation Agreements and the Dispute Resolution Procedure).
Prior to your last day of employment, including before and during your notice period, you may not disclose your resignation internally or externally (other than to your immediate family, legal or tax advisors, or a future employer on a confidential basis in connection with the acceptance of an offer of employment) except with your manager’s prior written approval. Doing so would be a breach of your Non-Disclosure Agreement and Citadel’s Confidential Information and Material Non-public Information Policy. The ability of Citadel to maintain the confidentiality of employee resignations before and during the notice period is necessary to protect Citadel’s business interests and ensure a smooth transition.
Please refer to your Home Location Addendum for further details on notice of termination of employment.
Summary Termination
Notwithstanding any other provision of this Handbook and subject to local law, we shall (without prejudice to our other rights and remedies) be entitled to terminate your employment without notice and without pay in lieu of notice in appropriate circumstances including those listed in the Disciplinary Rules in this Handbook, your Home Location Addendum, or if you become incapacitated, bankrupt or if you make any arrangement or composition with or for the benefit of your creditors generally.
Please refer to your Home Location Addendum for further details on summary termination.
Service of Notice
Any notice required to be given under this Handbook or your Employment Terms should be in writing, addressed for the attention of your manager or Human Resources, and shall be deemed served if it is personally delivered or sent by registered post to the last known address of the other party, or sent by email. Any notice posted shall be deemed served upon the second calendar day following that on which it was posted. Any notice sent by email shall be deemed served on the business day after it was sent.
Return of Citadel Property
Upon termination of your employment, or at any other time if so required by us, you shall immediately return to us via your manager or Human Resources any property, including any files, reports, analyses, charts, records, materials, drawings, laptops, computer hardware or software, entry passes, keys, mobile telephones and other electrical devices, credit cards, etc., any copies of the same, and any intellectual property belonging or relating to us or any member of the Citadel Group which you created or received during the course of your employment with us and which are in your possession or under your control. Any confidential information or intellectual property belonging to us or any member of the Citadel Group which is on a personal computer, personal electronic device or personal storage device of any kind must be forwarded to us and then irretrievably deleted upon the termination of your employment. You also agree to sign an affirmation (where requested) that all such property has been returned/deleted.
C. Non-Contractual Policies and Procedures
Introduction This Section C of the Handbook (as supplemented or amended by any relevant Addenda), sets out our non-contractual* policies and procedures which apply to you. We reserve the right to amend, withdraw or replace any policies in this Section C and the Addenda at any time.
Citadel expects every employee to use common sense and good judgement, to perform their job in a careful, conscientious and satisfactory manner, to comply with all policies and procedures, and to conduct themselves professionally in a way that will foster good relationships with the employee’s managers, co-workers, investors, vendors and other persons with whom Citadel does business. The policies and procedures in this Section C are important and you are expected to comply with them. Failure to do so may result in disciplinary action up to and including dismissal. While this Handbook lists some of the ways in which Citadel expects its employees to act, it is not exhaustive.
* Section C sets out policies and procedures that do not form part of your contract of employment and are not contractually binding (unless deemed by the laws of your Home Location to be contractually binding). However, these policies and procedures are important and you are expected to comply with them.
Employment Policies Citadel maintains personnel records for each employee in a personnel file. These files contain documentation regarding most aspects of your employment, including, but not limited to, performance evaluations, compensation letters, disciplinary warnings and other notices. Citadel seeks to maintain up-to-date, accurate and complete personnel files at all times. It is your responsibility to manage updated telephone number(s), home address, emergency contact information or legal or preferred name in the relevant HR system. It is your responsibility to maintain and update changes in number of dependents, or beneficiary designations in the respective employee benefit system. You have the right to review your personnel file and payroll records consistent with applicable law in your Home Location. If you wish to review your personnel file, please submit a written request to Human Resources. Further information about your right to access your personnel file is set out in your Home Location Addendum.
We respect the privacy of employees and will control access to individual files. Personnel records are maintained as confidential data, and are shared only with those persons with a need to know.
Employment References
We provide multiple resources for employees to obtain employment and/or income verification letters. Please refer to the Employee Resources section on the Intranet for more information on available options.
Employment of Relatives
Relatives of employees are eligible to work for Citadel if they meet our hiring standards. To avoid conflicts of interest and the perceived appearance of bias or favouritism, relatives may not work with one another in a manager/subordinate relationship, in the same managerial line, or in positions involving the review or auditing of each other’s work.
For purposes of this policy, a relative is any person who is related by blood or marriage/civil partnership, or whose relationship with the employee is similar to that of persons who are related by blood or marriage/civil partnership. This policy applies to all employees without regard to the gender or sexual orientation of the individuals involved.
Personal Relationships in the Workplace
Citadel prohibits relationships between a manager and a member of the manager’s staff (an employee who reports directly or indirectly to that person) and between employees who are in positions involving the review or audit of each other’s work, as permitted by law. Citadel also prohibits relationships where there may be a real or perceived conflict of interest, as determined in Citadel’s sole and absolute discretion. If such relationships exist, the parties need to be aware that Citadel, at its sole discretion, may effect modifications, including, but not limited to, implementation of enhanced controls in respect of one or both roles, one or both employees may be moved to a different department, or other action may be necessary, up to and including, in accordance with applicable law, separation from employment.
If any employee enters into (or is already in) a relationship, the parties must notify their Department Head and Human Resources. If there is any ambiguity or doubt as to whether a particular relationship creates a real or perceived conflict of interest, employees are expected to seek clarification with Human Resources. At all times, you are expected to respect the confidentiality obligations that you and other employees owe to Citadel. You may not disclose sensitive information to any employees that do not have a business need to know, and should not ask or probe for sensitive information that other employees are not permitted to disclose to you.
Illegal, Unethical or Unsafe Activities
If at any time you have any question or comment relative to any activity of Citadel managers or employees, please seek out Human Resources or the General Counsel as soon as possible to report this concern. You will never be reprimanded or dismissed for reporting this information in good faith/if you have reasonable grounds to suspect misconduct, and all communications will be held confidential to the extent possible. However, if after investigating a complaint of unlawful discrimination/harassment, or any complaint including, but not limited to, a complaint of a violation of any of Citadel’s policies, Citadel determines that the complaint was not made in good faith/there were no reasonable grounds to suspect misconduct, or that an employee has knowingly provided false information regarding the complaint, disciplinary action may be taken against the individual who filed the complaint or who gave false information, up to and including dismissal.
Workplace Policies Working with Respect
Equal Opportunity
Citadel is an equal opportunity employer and we oppose all forms of discrimination. Employee achievement at Citadel is measured by merit and accomplishment, including decisions regarding hiring, promotion and compensation. As an organisation, Citadel is committed to these ideals as they relate to employment, promotions, compensation, benefits, disciplinary actions, training opportunities and all other terms and conditions of employment.
Employees with Disabilities
Citadel prohibits unlawful discrimination against qualified individuals with disabilities and endeavours to provide reasonable accommodation for those individuals. If you feel you need an accommodation to perform your job, you should discuss the request with the HR Benefits team, complete the necessary accommodation request paperwork, and provide supporting documentation, as appropriate. Upon receipt of the accommodation request, and supporting documentation, Citadel will work with you in seeking a reasonable accommodation that enables you to perform the essential functions of your job.
Diversity and Inclusion Policy
A diverse team and an inclusive culture are foundational to Citadel’s mission of being the world’s most successful investment team and market maker. For three decades, Citadel has flourished by attracting extraordinary individuals of all backgrounds, upholding meritocracy and winning with integrity.
This policy sets out the elements of Citadel’s core values and strategies as they pertain to promoting a work environment that is diverse and inclusive.
Citadel believes a diverse team of individuals is a powerful source of strength. A broad array of viewpoints and experiences drives faster innovation and superior execution, creating a meaningful source of competitive advantage. We believe diversity of background, experience, beliefs and thought drives unique and greater outcomes. Citadel’s commitment to attracting and developing a diverse talent base reflects its culture of meritocracy.
Policy Against Discrimination, Harassment, Victimization and Retaliation
Citadel is committed to maintaining a work environment that fosters appropriate conduct and respect for individuals, and therefore strictly prohibits all forms of unlawful discrimination, harassment, victimisation and retaliation. This policy also prohibits offensive conduct which does not give rise to a violation of law. Accordingly, Citadel has adopted this policy in order to create a work environment free from discrimination, harassment, victimisation and retaliation of any kind, including sexual harassment and harassment based upon race, religion, religious creed, colour, sex (including pregnancy, childbirth, breastfeeding, and related medical conditions), gender, gender identity, national origin, ancestry, age, disability, military or veteran status, sexual orientation, caregiver status, familial status, marital status, medical conditions, genetic information or any other classification protected by law. In addition to sexual harassment, Citadel wishes to emphasise that all forms of discrimination, harassment, victimisation and retaliation are unacceptable. Accordingly, Citadel will not tolerate discrimination, harassment, victimisation or retaliation by or of any employee, non-employee, intern, vendor or workplace visitor, including co-workers, third parties (e.g., independent contractors, clients, members of the general public, etc.), managers, supervisors, and others with whom the employee comes into contact.
All employees must review this policy and commit to maintaining a work environment free from discrimination, harassment, victimisation and retaliation. In addition, all employees must complete training on prevention of discrimination, harassment, victimisation and retaliation on an annual basis.
Any employee violating this policy shall be subject to remedial and/or disciplinary action, up to and including dismissal.
Our zero-tolerance approach to discrimination in all forms, includes the bullying or harassment of any individual whether on grounds protected by law or otherwise. This applies not only in the workplace but outside work where there is a work connection – for example at a social or Citadel sponsored event, or whilst individuals are travelling for business. Bullying and harassment can occur in-person or remotely including through calls, texts, instant messaging, emails, and social media usage (whether using work or personal devices and irrespective of whether it takes place in or out of work hours). Such behaviour is normally considered gross misconduct and is likely to result in dismissal; in serious cases, it may be a criminal offence. It is also no excuse to say you were unaware your words or actions would cause offence.
Bullying and harassment includes conduct that creates an intimidating, degrading, or offensive environment. It might include (but is not limited to):
Whilst we take all forms of harassment very seriously, for illustrative purposes we have listed below some examples of what might constitute harassment related to sex or of a sexual nature:
Sexual harassment includes harassment on the basis of sex, sexual orientation, self-identified or perceived sex, gender, and/or the status of being transgender. The list above is not exhaustive and is also illustrative of the types of conduct which might constitute harassment based on other grounds.
Citadel recognises that people and their perceptions and sensibilities are different and can change. Comments, jokes or personal advances that you may perceive as innocent or funny may be offensive to a co-worker. You should know that even innocent intentions do not excuse actions that are unwanted or that may be reasonably perceived as threatening or offensive. Therefore, Citadel encourages you to avoid misunderstandings by acting professionally, treating others with respect, and avoiding conduct that others could misinterpret as inappropriate conduct.
Your responsibilities
You must demonstrate respect for your colleagues and act appropriately and respectfully at all times. All employees have a personal responsibility to comply with this policy, do their best to ensure that it is adhered to in their day-to-day work and ensure discrimination, harassment, victimisation or retaliation in any form does not occur. Managers are responsible for ensuring that this policy is applied in their area of responsibility.
What to do if you have a complaint
We all have an interest in maintaining a safe and comfortable workplace that is free from discrimination, harassment, victimisation and retaliation. If you believe that you are being subjected to harassment, victimisation, discrimination or retaliation, or if you have reason to believe that someone else is being subjected to harassment, victimisation, discrimination or retaliation, you should immediately report the offending incident(s) or conduct to your manager, Human Resources, your Business COO, a member of Legal & Compliance, or any other member of Firm management with whom you are comfortable. The contact information for these individuals can be found on the Intranet.
Any manager receiving a complaint of discrimination, harassment, victimisation or retaliation must report the incident promptly to Human Resources. A manager’s failure to report such conduct may result in disciplinary action, up to and including dismissal. Managers may also be subject to disciplinary action if they engage in, or in any other way condone discriminatory, harassing, victimising or retaliatory conduct.
No individual is required to report a complaint of harassment, victimisation, discrimination or retaliation to an immediate supervisor or other person responsible for the conduct being complained about.
All complaints of conduct inconsistent with this policy will be investigated promptly and effectively. In doing so, Citadel will attempt to preserve confidentiality to the maximum extent as possible, to the extent that the needs of the situation permit. Accordingly, absolute confidentiality cannot be guaranteed. While the investigation process may vary from case to case, upon receipt of a complaint, Citadel will conduct a review of the allegations and may take any interim actions as deemed appropriate. Investigations will be fair, thorough, impartial, conducted by qualified personnel, and documented and tracked for reasonable progress and timely closure. As applicable, Citadel will review relevant documents, such as electronic communications and phone records, as well as interview necessary and relevant parties involved, including witnesses. Citadel will reach reasonable conclusions based on the evidence collected and reviewed. Where applicable, Citadel will take appropriate corrective action based on such conclusions, consistent with applicable laws and the goals of this policy. If it is found that a disciplinary offence has occurred, disciplinary action will be taken under the Disciplinary Rules.
Prohibition Against Retaliation
We prohibit any form of retaliation or victimisation against any employee who, in good faith/had reasonable grounds to suspect misconduct, reports a complaint under this policy or assists in an investigation and shall treat such retaliation or victimisation as a disciplinary offence.
Training
We conduct regular workplace training on discrimination, harassment and respect.
Please see your Home Location Addendum for any additional requirements that may apply in your location or country.
Health and Safety Policy
We are committed to providing a safe work environment for our employees and other visitors to our facilities. We seek to provide and maintain safe working conditions, equipment and systems of work for all our employees, and to provide such information, training and supervision as they need for this purpose. To help accomplish this, you are expected to work diligently to maintain safe working conditions and to adhere to practices and procedures designed to prevent injuries and illness. Your responsibilities in this regard include:
We reserve the right to request that you leave the premises if, in our judgement, your injury or illness poses a direct threat to the health and safety of others in the workplace, in accordance with applicable law.
Further details of this policy and the employees responsible for health and safety issues will be provided to you from time to time by the Workplace Team.
Drugs and Alcohol
Employees who work while under the influence of alcohol or illegal drugs pose a danger to themselves, their colleagues, Citadel and the general public. Accordingly, you are strictly prohibited from using, possessing, distributing, selling, purchasing, manufacturing or being under the influence of illegal drugs or prescription only drugs that have not been prescribed for your current use at any time while you are employed by Citadel. In addition to potential legal consequences, violations of this policy may lead to disciplinary action, up to and including termination of employment.
Employees must also be mindful of alcohol consumption at company sponsored events. We expect every member of our team to act with integrity and exercise sound judgement. Accordingly, no Citadel sponsored events will serve alcohol past 11pm local time.
This policy does not apply to the lawful use of prescription drugs under the supervision of a licensed health care professional within the limits of a valid prescription, or the possession or consumption of reasonable quantities of alcohol in the workplace when sanctioned by Citadel management.
As permitted by law in your Home Location, Citadel reserves the right to require you to undergo appropriate tests designed to detect the presence of alcohol, illegal drugs or other controlled substances when in Citadel’s sole discretion there is a reasonable basis to do so. Your refusal to submit to a requested test under this policy may result in disciplinary action, up to and including termination of employment.
Office Facilities and Environment
Noticeboards, Property and Facilities Noticeboards in communal office spaces and kitchens are predominantly intended to be for Human Resources to post useful information; they should not be used to post materials of any kind that are inconsistent with our Personal Solicitations policy. Office equipment, stationery and other office supplies and facilities are our property and are not for your personal use, unless approved in advance by your manager. Unless expressly authorised, services provided by our vendors should not be used by employees for personal use.
Smoke-Free Environment
To maintain a safe and comfortable working environment, and in accordance with local legislation, smoking (including electronic cigarettes) is prohibited in all our office premises without exception.
Personal Appearance
Our office dress code is business casual. However, you should wear appropriate attire having regard to any client or other appointments, and present professionally at all times.
You are also expected to keep your work environment clean and tidy. To this end, please make an effort to organise and clear all materials from work surfaces prior to leaving at the end of each day. Confidential or sensitive materials should be securely stored at the end of the day and computers switched off.
Personal Property
Property You should take care of your property to prevent theft and you are responsible for the safety of your own personal property on our premises. We cannot accept responsibility for any loss or damage caused in this regard. If you choose to keep personal property at work, be advised that it may be accessed at any time by Citadel personnel. Notification of articles lost or found on the premises should be made to the Workplace Team or Security. You should refrain from having personal mail sent to you at our premises. We cannot accept liability for the loss of such mail.
Inspections
In the interests of the safety and security of our staff and property, we reserve the right, subject to applicable law, to inspect any personal bags, briefcases, clothing, possessions or storage areas within our offices where this is considered to be reasonably necessary. Such inspections will only take place with the authorisation of the Chief Operating Officer or a member of the Human Resources team and will be conducted with a witness.
Workplace Violence
You are strictly prohibited from any act or threat of violence against any person, including employees, customers, clients, vendors, service providers or other visitors, in or about our facilities or while you are engaged in our business. You are further prohibited from such conduct against any of your colleagues at any time, to avoid tension and conflict inside the workplace. You may not bring weapons of any type onto our premises at any time, regardless of whether they are in your personal possession or whether they are properly licensed. If you violate this rule, this will be treated as an act of gross misconduct which is likely to result in the immediate termination of your employment as well as possible legal prosecution. We will take appropriate action where such conduct does occur, including notifying law enforcement officials. As our employee, you should warn appropriate personnel, for example your manager or the Chief Operating Officer, if you observe or are made aware of any inappropriate behaviour relating to violence in the workplace. Your report will be held in confidence to the extent possible and you should not suffer any detrimental treatment by us for making a report in good faith/if you had reasonable grounds to suspect misconduct under this policy. Policy for Use of Citadel’s IT Systems
You must comply with the provisions of our IT Systems Use Policy on the Intranet when accessing or using our IT systems or equipment including our network, computers, laptops, mobile phones and other electronic devices. For further information, please refer to the policy.
Performance Evaluations
Citadel endeavors to conduct an annual written performance evaluation of each employee’s performance. This process is administered by Human Resources. Your manager should schedule a meeting to discuss your evaluation within the timeframe established by Human Resources; however, if you find that such a meeting has not been scheduled during this timeframe, you should bring it to the attention of Human Resources. This will help ensure that evaluations are provided in a timely manner.
To ensure that you perform your job to the best of your abilities and in accordance with our expectations, Citadel will endeavor to provide you with appropriate suggestions for improvement on an ongoing and informal basis. You may also receive periodic written evaluations of your performance from your manager on an as needed basis. All written performance evaluations will be based on your manager’s view of your overall performance in relation to your job responsibilities, achievement of goals and expectations and will also take into account your manager’s view of your conduct, demeanor and attendance. Professional Standards, Conduct and Ethics Reporting Misconduct
We conduct our business in accordance with all applicable laws and regulatory requirements within your Home Location and all countries in which we do business. It is important you fulfil your own responsibilities consistently with this intention at all times. Failure to do so may lead to disciplinary action and other legal and regulatory consequences.
You are required to promptly report any actual or suspected violation of applicable law, regulatory requirements, or the Firm’s policies. Please refer to the Code of Ethics or Code of Conduct (as applicable to you) for further details on reporting misconduct. Where relevant, your Home Location Addendum or other local compliance policies may contain additional details concerning the reporting of misconduct. We prohibit any form of retaliation, harassment or adverse employment consequence against any employee who, in good faith/had reasonable grounds to suspect misconduct, reports a violation or raises a concern, or assists in an investigation. If you have a concern relating to your own employment or working conditions, this may be more appropriately raised under the Grievance & Workplace Concerns Procedure (see below). Media Enquiries, Social Media, and Presenting in Public
As Citadel grows, the Firm attracts increasing levels of attention from the public, including media, industry groups, and online forums. Every employee should be conscious of how we represent our organisation to the public. When in doubt, consult with your manager or Corporate Communications. Below are policies for the most common situations.
Media Enquiries
All media enquiries about Citadel should be referred to Corporate Communications. Employees may only speak to the press on Citadel’s behalf with proper authorization from Corporate Communications. If you believe you’ve said something to a reporter unknowingly or mistakenly, or you need guidance on a press query you’ve received that is not related to Citadel, contact Corporate Communications.
Social Media
Social media consists of blogs, online social networks and other similar public communication venues. Participation in online forums is permitted in a purely personal capacity. However, employees are not authorised to act as a representative or spokesperson for Citadel, or to disclose information that pertains to Citadel’s business or confidential information, and must comply with Citadel’s Social Media Policy, which is available on the Intranet. Unauthorised disclosure will constitute a violation of your Non-Disclosure Agreement.
If you choose to participate in forums on the Internet, you are personally responsible and liable for what is communicated. Employees are expected to exercise common sense and caution. You must take care to ensure nothing you post is attributable to us or could reasonably be expected to damage our reputation. You should never post comments on social media that are discriminatory, harassing, offensive or defamatory to us, fellow employees or managers, investors, counterparties or clients. If you come across online content related to us that is incorrect or potentially damaging to our reputation, please forward it to Corporate Communications for appropriate action. Please refer to our Social Media Policy on the Intranet for more information. Public Speaking
From time to time our employees are invited to speak on topics pertaining to our industry. These programs are often valuable to our business and to our reputation as a market leader. Because these programs require a considerable time commitment from our employees, it is important to manage this investment wisely. We pursue opportunities that are relevant, reach audiences who are important to us and provide value to the organisation. If you have been requested to speak on our behalf and feel the opportunity is worthwhile, contact Corporate Communications prior to agreeing to the speaking engagement and complete the Public Speaking Request form on the Intranet.
Presenting Appropriately
As a member of our organisation, you are viewed by others as a representative of our business. Be sensitive to how you and we may be perceived by others through your words and actions. When in public – including business trips, industry events and Company functions – exercise good judgement and common sense.
Disciplinary Rules
Any employee who is found to have committed the following acts of misconduct may be subject to disciplinary action, including termination of employment. The following list of misconduct is not intended to be exhaustive and any other conduct identified by Citadel, in its sole discretion, to be similar misconduct or conduct that interferes with its operations or is generally offensive to co-workers, customers, clients, vendors, services providers or other visitors may also result in disciplinary action, including termination of employment.
Citadel may issue you with a warning and/or take further disciplinary action if the conduct persists. Citadel may, in accordance with local laws, terminate your employment summarily without notice or without pay in lieu of notice if it regards the misconduct as gross misconduct. Gross Misconduct
Gross misconduct is conduct which particularly warrants severe disciplinary action up to and including immediate dismissal without any notice or payment in lieu of notice. The following are non-exhaustive examples of gross misconduct:
Grievance & Workplace Concerns Procedure
This procedure is designed to help us resolve any workplace concerns raised by employees. If you are dissatisfied with any aspect of your employment, it is often best to try and resolve the matter informally by discussing it with your manager or with Human Resources. If you have a concern that cannot be resolved informally, you should set out in writing the alleged concern and send the written complaint to Human Resources. We will then invite you to attend a meeting to discuss the matter where you will have an opportunity to explain your views. After the meeting, we will inform you of our decision. Please see your Home Location Addendum for any additional requirements that may apply in your country or location.
Use of recording devices in meetings
You, and anyone accompanying you, must not make any recordings (whether on your own device or on our device) of any meeting or conversation without the express consent of the person or people being recorded. This consent must be obtained in advance of making any recording. Covert recording is strictly prohibited.
Employee Welfare and Benefits Education and Training Programs
Citadel recognizes the important role you have in creating and maintaining our learning organization.
Our Learning and Development Team provides professional development opportunities that enhance the performance of our individuals and teams, including various onsite training, online training and self-study resources, offsite continuing education and training, and individual and team coaching. For full details regarding our education and training programs, including eligibility requirements, program restrictions, and the application/reimbursement process, please visit the Intranet. Employee Referral Program
Citadel strives to create a workplace in which we can all take pride and encourages employees to refer candidates for employment consideration. If an individual referred by you is hired by Citadel, you may be eligible to receive an employee referral bonus. Further information is available on the Intranet. If you have any questions regarding this Policy, please contact the Recruiting team.
Family Leave and Other Time Off
We recognise that many employees will have family responsibilities and other obligations in addition to the responsibilities they have to us. We are therefore pleased to support employees in achieving a healthy work/life balance. For some, this will include taking leave as a result of becoming a parent. Others may require time off to perform public duties or care for a dependant. We provide a number of options with regard to leave from work, many of which exceed legal requirements. Please refer to your Home Location Addendum for more information or contact Human Resources.
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