EMPLOYMENT HANDBOOK - Ethicspoint · H:\International HR\China\China Rep Office\Shanghai Rep Office...

$: EMPLOYMENT HANDBOOK - Ethicspoint · H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms Rev. May 19, 2011 EMPLOYMENT HANDBOOK OF SILICON VALLEY BANK Complying$
H:\International HR\China\China Rep Office\Shanghai Rep Office New Hire Forms

Rev. May 19, 2011

EMPLOYMENT HANDBOOK

OF

SILICON VALLEY BANK

Complying with the rules and principles set out in this Employment Handbook is a

condition of employment or service to Silicon Valley Bank (SVB). We ask that you read

this document carefully, considering the spirit, as well as the letter of the policies laid out

here. Since even the mere appearance of unethical behavior may be damaging to you and

to SVB, we strongly encourage you to interpret this code in the broadest possible sense

and apply it in everything you do. The „employee‟ in this Employment Handbook refers

to the employee dispatched by FESCO to service for the Representative Office of Silicon

Valley Bank. No employment relationship is established between the employee and the

Representative Office of Silicon Valley Bank according to relevant Chinese laws and

regulations.

I acknowledge that I have received a copy of this Employment Handbook:

___________________

Name:

Date:


Rev. May 19, 2011

VALUES AND STANDARDS

DRIVEN

We hire motivated and talented people who strive to do their best. But drive is not a

measure of hours worked. Instead, drive is about urgent actions that bring results to the

fast-changing market we serve. It's about understanding the evolution of our clients‟

financial needs. And it‟s about taking ownership over our efforts to help entrepreneurs

succeed.

ENTERPRISING

Our employees are creative, intelligent, energetic and take the initiative. We are

constantly striving to innovate the business of banking. We are always willing to embrace

change as an avenue for long-term growth. And we always endeavour to identify unique

solutions that can better help our clients.

DEDICATED

We act without reservation to support, to assist, to aid, and to team with our co-workers

and clients. We empathize with the challenges they face in difficult times and celebrate

alongside them when they reach their goals.

ETHICAL

We continue to be an organization where personal and professional ethics always

supersede short-term business gains. A decision based on ethics — and guided by

conscience — will uphold the integrity of the Office and will always have the support of

senior management.

In addition to these core values, we seek to provide a high level of service that

distinguishes SVB in the marketplace. We value professionalism and emphasize its

importance in communication, responsiveness, approach and appearance.


Rev. May 19, 2011

1. PERSONAL DETAILS

Any changes to your personal details (particularly changes in name, marital status,

address and telephone number or bank details) should be notified to both the Client

Services Manager and the Human Resources Business Partner as soon as possible. The

registered office address of the Representative Office of Silicon Valley Bank (“Office”)

is Room 410C, No. 234, Songhu Road, Shanghai 200433, PRC. All correspondence and

notices that may be given by you in connection with your service for the Office should be

sent to the registered office address by registered post. However, a notice or other

document may be given to you by FESCO, a Human Resources representative of the

Office or any other person authorised by them handing the document to you personally.

You may also deliver documents to the Office personally by handing it to the Client

Services Manager or to your immediate supervisor. It will always be the responsibility of

the person delivering the document to obtain a written receipt. All information in your

personnel record will be treated in the strictest of confidence. However, you acknowledge

and agree that the Office is entitled to transfer your personal details and any information

in connection with your labour contract or other employment documents to any

associated company of Silicon Valley Bank or any outside human resources service

company where necessary. Any information communicated with the outside human

resources service company (if any) by you should be copied to the Office.

2. COMMENCEMENT OF EMPLOYMENT AND PROBATION PERIOD

The date that you started servicing for the Office is that as recorded in your dispatching

agreement between FESCO and the Office (“Dispatching Agreement”), unless

otherwise changed with the agreement of yourself, FESCO and the Office, and may not

be the same date that you signed your Employment Agreement with FESCO

(“Employment Agreement”).

Subject to the terms of your Employment Agreement and the Dispatching Agreement,

during your probation period, your employment and/or service may be terminated by

such length of prior notice in writing by you, FESCO or the Office as agreed under your


Rev. May 19, 2011

Employment Agreement and given at any time during or at the end of this period. If your

continued employment and/or service is confirmed within or after the probation period,

then any terms referred to in your Employment Agreement and/or Dispatching

Agreement which are dependent upon confirmation of your employment and/or service

will come into effect and not before.

3. JOB TITLE AND DESCRIPTION

Your job title is set out in your Employment Agreement or such documents of

appointment provided by the Office and your normal duties are detailed in the job

description attached to the same. However, in addition you may be required to undertake

other reasonable duties from time to time appropriate to your level within the Office, but

you will not be assigned duties which you cannot reasonably be expected to perform.

The Office's reporting requirements are that you report to those of your supervisors as

management may instruct you from time to time.

4. NORMAL HOURS OF WORK AND OVERTIME

Your normal hours of work may be set out in your Employment Agreement or such hours

of work information sheet provided by the Office. You may also be required to work

such additional hours as may be necessary for the proper performance of your duties, and

you will be expected to comply with all reasonable requests and instructions.

The Office reserves the right to amend your starting and finishing times (either

temporarily or permanently) where required in the interests of efficiency or the needs of

the business after due consultation.

Prior approval from your Office supervisor is required for all overtime work and the Part

A of the Overtime Approval and Claim Form (Appendix 7) should be completed and

countersigned by the Office supervisor, and after the overtime work being performed, the

Office supervisor should be asked to sign at the Part B of the Overtime Approval and

Claim Form confirming the claim. The signed Overtime Approval and Claim Form shall

then be submitted to the designated Human Resources colleague for further processing.


Rev. May 19, 2011

You should submit your Overtime Approval and Claim Form(s) in a timely manner, and

in any event not ten (10) working days after the overtime work.

5. PAY

Your basic pay is set out in your Employment Agreement and this will be paid monthly

on or before the last working day of each month. Payment of overtime (if payable) will

be made on the normal pay day for the month following that in which the overtime was

worked. On every pay-day you will receive a pay slip showing gross pay, deductions

(statutory, agreed or otherwise) and the net sum paid. Your pay will be reviewed at the

time or times as provided in your Employment Agreement. Any change as a result of

that review will be notified at the beginning of the calendar month following the review.

All regular, full-time employees are eligible to participate in incentive compensation

programs. Details of these programs, including eligibility criteria and pay cycles, will be

provided to you.

6. HOLIDAYS AND HOLIDAY PAY

The Office believes that holidays are vital for the morale of all employees.

Regular employees begin accruing holiday leave credits on their date of hire, at a rate

determined by length of service, salary grade, and work schedule. Credits accrue during

active service period (e.g., credits do not accrue during leaves of absence). Temporary

and Intern employees who have not been in continuous service term with the Office for

one year or more do not accrue holiday credits.

No holiday may be taken during the probation period without express prior written

permission. The Office will honour holiday that you have booked before the start of your

service provided that the dates were agreed at your interview.

If you are a regular employee taking holiday leave, you must give sufficient prior notice

of proposed holiday dates and these must be agreed with the person you report to and

recorded. Agreement to your proposed holiday dates will not be unreasonably withheld

but consent will remain in the absolute discretion of the Office. Reasonable efforts will


Rev. May 19, 2011

be made to accommodate your personal requirements but you are advised to consult with

your immediate supervisor before making any reservations and you should not assume

that dates are acceptable until notified as there may be clashes. Sufficient staff to

continue an efficient service must be present in each department at all times. Holiday

dates requested when less than the required notice is given may be allowed or disallowed

in the absolute discretion of your immediate supervisor. Your length of service may also

be a factor if a number of employees prefer the same dates. A request for holiday should

be made by using the Office‟s holiday form.

Holiday pay is paid at your normal rate of salary.

For the purpose of all provisions covering holiday, one day's pay shall be .38% of your

basic annual pay although holiday taken will be calculated to the nearest half day. Staff

taking a half-day's leave will work 4 hours on the day concerned.

You can accrue holiday credits up to a maximum of one and a half times your annual

allotment. When maximum accrual is reached, no further accrual will occur until some

accumulated vacation is used.

The Office encourages employees to schedule and use accrued holiday credits in the year

in which they accrue. Holiday balances continue to carry forward at the end of each

calendar year, up to the maximum accrual mentioned above, and cannot be “exchanged”

for cash during employment.

Maternity leave

You are entitled to take leave for such periods as stipulated under the relevant laws, rules,

and regulations on maternity leave. The Office will continue to pay you during your

period of maternity leave in accordance with the maternity leave pay at the appropriate

statutory rate.

Other Unpaid Leave and Holiday

Other unpaid leave and holiday may be granted, depending on business staffing needs

and related considerations, for extenuating circumstances.


Rev. May 19, 2011

Public Holidays

You are entitled to all public and statutory holidays applicable in the People‟s Republic

of China (“PRC”) from time to time in addition to your basic holiday entitlement and will

be paid for each public holiday.

7. SICKNESS AND ABSENCE AND SICKNESS/ABSENCE PAY

If you are absent from work for any reason and your absence has not previously been

authorised by the person you report to or another management representative, then you

(or someone on your behalf if your sickness prevents you doing it yourself) must inform

the Office within one hour of the beginning of your normal working hours of every day

of absence which is a weekday (not being a public holiday). Failure to notify the Office

of absence and the reason for it, or absence from work for three or more days without

proper and reasonable reason, will normally result in loss of pay for the period of

absence, and may be treated as an act of gross misconduct justifying dismissal without

notice when repeatedly practised.

Any unauthorised absence must be properly explained and an absence record sheet

completed on your return to work (setting out dates and reasons for absence including

dates of sickness on non-working days) and this must be signed by your immediate

supervisor or another management representative in charge of the matter. If absence is

likely to be of uncertain duration, you must keep the Office regularly informed on at least

a daily basis, unless you have a medical certificate from your Doctor for a longer period.

For any absence for sickness or injury, you will be required to provide an original

medical statement signed by a doctor expressing the reason for your absence from work.

Medical certificates must be provided to the Office on the day you return to work, but if

sickness or injury will prevent you from returning to work for over one week, you must

provide the relevant medical certificate on the day immediately following the expiry of

such week, and then on a weekly basis, if your sickness or injury continues. If you are

absent for three working days or more without making contact with the Office, it will be

considered as a serious breach of the rules or policies of the Office and your service

relationship with the Office may be terminated without notice. Alternatively, the Office


Rev. May 19, 2011

has the right to take or accept such conduct on your part as having resigned from the

Office without prior notice to the Office.

Medical certificates will be maintained in the Office's personnel records and any failure

without good cause to comply with these arrangements will be considered as a serious

breach of the rules or policies of the Office and your service relationship with the Office

may be terminated without notice.

If you are absent from work (due to sickness or any other reason) and you comply with

the above, the Office may pay you either sick leave pay in accordance with the Office‟s

rules or policy in making sick leave pay (“Sick Leave Pay Policy”) or sick leave pay at

the appropriate rate of statutory sick pay ("SSP") (subject to your qualifying for SSP)

according to the relevant laws, rules and regulations (as amended from time to time).

Sick leave pay will be treated like pay being subject to PRC individual income tax.

Please note that the Office shall have the right to pay sick leave pay according to the

relevant laws, rules and regulations. Any payment under the Office‟s Sick Leave Pay

Policy shall be deemed to include any SSP to which you are entitled.

In the case of other unauthorised absence, the Office may decide to pay you such sums as

are in its absolute discretion. The Office will take into account the following factors in

deciding whether any absence pay is payable:-

1. length and reason for the absence

2. your absence record

3. your performance generally

4. any other relevant points which the Office in its absolute discretion

takes into account including any representations made by you on

your return from such absence, although the Office reserves the

right to have such absence charged against your annual holiday

entitlement.

All periods of absence are recorded in your personnel records.

The Office reserves the right to have you examined at one or more medical examinations

at any time by an independent Doctor or Consultant at its expense and to cease payment


Rev. May 19, 2011

of any discretionary sick pay paid under the Office‟s Sick Leave Policy if it is advised by

the Doctor or Consultant that you are fit to return to work. You will be shown a copy of

the report prepared by such independent Doctor or Consultant and given the opportunity

to comment on it. It is agreed that you will co-operate in full with any such reasonable

request to be examined by such Doctor or Consultant and you will be expected to sign a

statement to authorise that your Doctor‟s records (and any other relevant medical records)

be made available to the independent Doctor or Consultant. However, absolute

confidentiality as to your medical condition will be respected and maintained and the

only person to have sight of such records will be the independent Doctor or Consultant

and the only person(s) to have sight of the report will be you and the Head of the Office

or the Human Resources Business Partner, but should there be dispute leading to

arbitration or litigation, the report and any medical evidence may be produced in such

arbitration or litigation. In particular, the Office will be concerned to establish the likely

extent and frequency of any future sickness absence and the general prognosis. Refusal

by you to comply with this requirement may result in disciplinary action. The Office

reserves the right to request your written permission to discuss your medical condition

with your Doctor.

If you are absent for work (due to sickness, injury or any other reason) excluding annual

and public holidays, for over the stipulated period under PRC Labor Law or other

relevant laws, rules or regulations, such conduct will be considered as a serious breach of

rules or policies of the Office and your service relationship with the Office may be

terminated without notice. Alternatively, the Office has the right to take or accept such

conduct on your part as having resigned from the Office without prior notice to the

Office.

If you are absent because of any injury or accident caused by someone else (for example,

in a road traffic accident), you will be required to repay any sickness/other absence

payments made to you and the Office will seek to recover the equivalent compensation

for loss of earnings from the third party. However, such repayments will only be sought

when the actual compensation is received from the third party.

8. TERMINATION


Rev. May 19, 2011

Subject to the rules governing notice during or upon the expiry of your probation period,

and on the confirmation of your continued service relationship, the period of notice to be

given in writing by FESCO, the Office or by you to terminate your employment and/or

service for the Office is set out in your Employment Agreement and/or the Dispatching

Agreement.

If you commit a serious breach of the rules or policies of the Office, or a violation of any

applicable laws and regulations (no matter whether any penalty has been imposed), or

you are temporarily incapable to perform your duties for more than 30 days due to the

situations including but not limited to detention by the Police or any other competent

authorities, the Office may terminate your service relationship with the Office without

notice pursuant to the relevant law, rules and regulations.

The Office reserves the right to pay monies in lieu of notice and any payment made in

lieu of notice will be subject to individual income tax deducted at source but nothing in

this paragraph shall prevent the Office from terminating your service for the Office

without notice or pay in lieu of notice in the appropriate circumstances.

Your final monies properly payable to you (to be paid by cheque) and arising out of the

termination of your service for the Office will be sent to you within the month in which

your service for the Office ended (whether terminated by you or the Office) or soon

thereafter if your service for the Office ends after the 20th

of a month, or within such

period as provided under the relevant law, rules and regulations, subject to and always

provided if the Office shall have a claim against you arising out of your breach of the

Employment Agreement and/or the Dispatching Agreement or your duties to the Office,

the Office may retain such final monies pending determination of the matter.

Should you leave without notice or during your notice period without the permission of

the Office, the Office reserves the right to deduct a day's pay for each day not worked

during the notice period. This may include deductions of pay and/or accrued holiday pay

and/or any other monies contractually due to you. (In any case, where the Office agrees

in writing to waive the need for you to work your notice, this will not apply).

The Office reserves the right to require you to remain away from work during a notice

period (whether you or the Office gave notice and irrespective of the length of any

notice).


Rev. May 19, 2011

Where the Office requires you to remain away from work during a notice period (whether

you or the Office gave notice and irrespective of the length of any notice), you must

comply with any conditions laid down by the Office (including the performance of such

duties as the Office may require in its entire discretion) and whilst on full pay (with all

contractual benefits), and during such time you will not be permitted to work for anyone

else or on your own behalf without the Office's prior written permission. During this

period the Office will require you not to communicate with suppliers, customers or other

employees and in no circumstances should you enter into any contract or arrangement

which would bind the Office. You will be personally liable for such arrangements. The

Office reserves the right to inform other employees and third parties that you have

resigned or given notice in its absolute discretion.

On the last day of your service for the Office , or at such time during your service for the

Office as the Office shall determine, you must return to the Office, all correspondence,

drawings, documents, papers and any copies which you may have taken in whatever form

as well as any other property belonging to the Office which may be in your possession or

under your control. The Office reserves the right to charge for any equipment which has

been lost or not returned.

9. COPYRIGHTED MATERIALS

You cannot copy or distribute copyrighted material (e.g., software, computer files,

documentation, articles, graphics) unless you have confirmed that the Office has the right

to copy or distribute the material. Failure to observe a copyright may result in legal

action by the copyright owner. When in doubt about whether you may copy copyrighted

material, consult the Office‟s Legal Department. Violation of this provision will be

considered as a serious breach of the rules or policies of the Office and your service for

the Office may be terminated without notice.

10. CONDUCT & PERFORMANCE EXPECTATIONS


Rev. May 19, 2011

The Office will provide the necessary information, training and tools for employees to

perform their job duties.

Although each situation is unique, should improvement in job performance be needed,

guidance and counselling are generally provided. These may take a variety of different

forms, such as verbal or written counselling.

The Office expects all employees to behave in a respectful and professional manner at all

times. The Office expects employees to follow this Handbook and to demonstrate the

Values and Standards embodied in this Handbook and sound and ethical business

standards. Although not an exclusive list, job expectations include:

Avoid any actions which are dishonest or fraudulent or which jeopardize the

security of the Office operations, its employees or clients, including

falsification, misrepresentation, alteration, or destruction of any the Office

records or property, providing false or misleading information on an

employment application form or on any other Office records.

Comply with the Office‟s cash balancing or cash control standards.

Perform your job duties, as requested, according to the established performance

standards and guidelines. Maintain all licenses required for your job. Provide

support for colleagues‟ goals and work.

Avoid any actions of refusal or failure to abide by or obey instructions.

Avoid behaviours that are disruptive or that antagonize or harass clients,

vendors or other employees, or that reflect negatively on the Office.

Employees who are related to one another or are in close personal relationships

with one another are not to be in direct (or chain of command) reporting

relationships. This will avoid any conflict, as well as possible security and

morale issues. Disclose to your immediate supervisor or manager if you have

any potential conflicts of interest.

Engage in proper, appropriate and authorized use of Office property,

equipment, or premises (or that of others), including copying, photographing,

reproducing or utilizing Office documents, Office property or property of

others.

Carry out the Office‟s guidelines regarding proprietary and/or confidential

Office, client and employee information.


Rev. May 19, 2011

Compliance of all applicable laws and regulations.

Conduct yourself in a professional manner at all times.

Failure to meet with any of the above expectations will be considered as a serious breach

of the rules or policies of the Office and your service for the Office may be terminated

without notice.

11. WORK ENVIRONMENT

In order for us to maintain a positive work environment for all of our employees, you are

required not to engage in or permit any fellow employee to engage in, any sexual, racial

or other harassment or other unlawful discrimination against any person (whether or not a

fellow employee) in the course of your service with us. You should strictly observe the

Silicon Valley Bank Harassment-Free Workplace Policy attached hereto as Appendix 1.

Violation of this provision will be considered as a serious breach of rules or policy of the

Office and your service for the Office may be terminated without notice.

12. HEALTH & SAFETY

We will take all reasonable steps to ensure your health, safety and welfare whilst at work.

You must familiarise yourself with the Safety Policies and Guidelines attached hereto as

Appendix 2.

The Office will make reasonable accommodations for employees with life-threatening

illnesses. It will also take necessary steps to ensure that the health and safety of

employees, clients, and business contacts are not endangered by any employee‟s illness.

In most circumstances, employees may not refuse to work because they are afraid of

contracting a life-threatening illness from a co-worker. Under no circumstances will

discrimination or harassment of an employee with a life-threatening illness be tolerated.

Violation of this provision will be considered as a serious breach of rules or policies of

the Office and your service for the Office may be terminated without notice.


Rev. May 19, 2011

All employees share the responsibility for maintaining a workplace free from violence or

the threat of violence. Any employee, who believes he or she is a victim of threatening

behaviour, harassment, or other violence or threat of violence, or is a witness to this

behaviour, must report it immediately to a supervisor, manager, or high levels of

management.

Employees should be aware that many episodes of violence arise from individuals who

are not employees and may even be family members of the employee. Please do your

part to monitor and maintain our mutual safety by complying with safety and security

policies.

The Office does not tolerate violence or the threat of violence in or out of the workplace.

Violation of this provision will be considered as a serious breach of rules or policy of the

Office and your service for the Office may be terminated without notice. The Office will

further take all necessary steps to ensure that violent or threatening behaviour does not

occur, which may involve mandatory referral to a mental health professional, discipline

or termination of the service for the Office and/or bring the matter to the attention of the

Public Security Bureau. Examples of unacceptable behaviour include: threatening to

harm another person in any way; striking or physically challenging another person;

engaging in dangerous, threatening or unwelcome horseplay; bringing any article that

could be construed as a weapon to work or any work-sponsored event; or engaging in any

activity that causes or may cause an unsafe work environment. Jokes about weapons,

violence or the threat of violence are also considered to be threatening.

Failure to observe safety rules including intentional misuse of equipment which is likely

to endanger another‟s health and safety may also lead to dismissal without notice.

13. COMPLAINT RESOLUTION

The Office encourages you to try to resolve concerns, problems or complaints as they

arise through direct discussion.

The Office‟s managers and executives practice an “open door” policy, and employees are

encouraged to raise suggestions and voice concerns on a regular and/or “as needed” basis.


Rev. May 19, 2011

Many situations of potential conflict can be resolved quickly by communicating directly

with the person whose behaviour you believe is inappropriate. If you feel comfortable

doing so, tell that person to stop and that the conduct makes you feel uncomfortable.

The Office will take prompt and appropriate steps to prevent harassment or other

inappropriate behaviour. This may include additional training or education, coaching,

counselling, disciplinary action, transfer, demotion or termination. The results of the

investigation will be communicated to the complainant, the alleged offender and, as

appropriate, to any others directly involved.

The Office will not tolerate any retaliation against anyone who has raised concerns,

reported harassment, participated in, or cooperates in any way with an investigation of

employee complaints.

Any employee who reasonably believes that he or she is aware of substantial misconduct

that ranges from questionable accounting practices to harassment of discrimination is

encouraged to file a report to either the Head of the Office or the Human Resources

Business Partner. You may also contact any member of the Steering Committee. Refer to

Appendix 6 for a list of Steering Committee members and their contact information. You

may also contact the Chairman of the Audit Committee, SVB Financial Group Board of

Directors. Refer to the SVB intranet for more information.

Additionally, you may make anonymous and confidential reports of unethical conduct by

logging onto www.ethicspoint.com from any computer with access to the Internet or by

calling their toll-free Hotline at 866-ETHICSP (866-384-4277). All reports are taken

seriously and are promptly investigated.

SVB “EthicsPoint” Hotline

Calls Within the U.S.

866-ETHICSP (866-384-4277)

Calls Outside the U.S.

Dial Country Access Code and 866-ETHICSP (001-866-384-4277)

Web site Submission: www.ethicspoint.com

Available 24 hours a day, 7 days a week

All CONTACTS ARE CONFIDENTIAL



866-ETHICSP (866-384-4277)


Dial Country Access Code and 866-ETHICSP (001-866-384-4277)



http://www.ethicspoint.com/




Rev. May 19, 2011

14. CONFIDENTIALITY AND FIDELITY

You are required to comply with the Confidential Information and Invention Assignment

Agreement for Employees attached hereto as Appendix 3 and familiarize yourself with

the terms and requirements of the same. You should be sensitive to the risk of

inadvertent disclosure resulting from open doors, speaker phones, cellular phones, and

when transmitting confidential information by fax or other electronic media. You must

secure confidential information, whether in physical or electronic form, according to the

applicable procedures. Confidential information should not be taken to an employee‟s

home unless as necessary to conduct the Office business.

The Office appreciates that not all employees will remain with the Office forever and it is

not its intention to prevent employees from using in future employment their skills and

experience gained with the Office. Nevertheless the Office will take such measures as

are necessary to protect its confidential information and trade secrets.

Unauthorised disclosure of confidential information will be considered as a serious

breach of the rules or policies of the Office and your service for the Office may be

terminated without notice. Further, it may lead to civil proceedings to restrain you from

disclosing the information to a third party or making personal use of it without authority

from the Office or for damages if loss to the Office results from unauthorised disclosure.

All employees are required to conduct dealings with their colleagues, suppliers, external

organisations and the public at large with total honesty and integrity, and to maintain the

reputation and image of the Office at all times. Violation of this provision will be

considered as a serious breach of the rules or policy of the Office and your service for the

Office may be terminated without notice.

If you have a suspicion that a member of staff is divulging confidential information to

competitors, then you should inform either the Head of the Office or the Human

Resources Business Partner immediately.

15. CONFLICT OF INTEREST

Ethical Conduct


Rev. May 19, 2011

The Office‟s employees may encounter situations that require them to make an ethical

judgment and in such situations, the Office requires employees to conduct themselves in

a manner that is fair, reasonable, and honest. The Office requires employees to act within

the following boundaries:

Interests in Competitors, Suppliers and Customers. Subject to the provisions in this part,

in order to avoid real or perceived conflicts of interest, you may not obtain a financial

interest in a privately-held client, prospective client, company, competitor, or supplier in

the business niches that SVB serves, or a venture capital or private equity fund in the

business niches that SVB serves. During the term of your service relationship, you shall

not directly or indirectly obtain more than a 2% equity or other financial interest in a

publicly-traded company in the business niches that SVB serves or that is a competitor

(e.g. another bank) or supplier unless prior approval has been given by your manager and

the Head of Human Resources following the procedures below. If you are on a client‟s or

prospective client‟s account management team (including, but not limited to, relationship

managers, regional managers and credit officers) or if in the normal course of your job

duties you make decisions regarding a client or supplier such as procurement or account

management decisions you are considered a “Client Decision-maker” and shall not

directly or indirectly obtain a financial interest in such client, prospective client or

supplier unless prior approval has been given by your manager and the Head of Human

Resources following the procedures below. In addition, if you are a Client Decision-

maker and have a pre-existing investment in a company that becomes a client or supplier,

you must immediately inform your manager and the Head of Human Resources such

investment and provide the details thereof as required by your manager and the Head of

Human Resources and may need to either divest your interest in such company or cease

handling any business for SVB involving such company. Under some exceptional

circumstances, the foregoing types of investments may be permitted on a case-by-case

basis, but only with the advance written approval of your manager and the Head of

Human Resources. You are encouraged to address any questions or requests for

approval of an exception to this standard to the Head of Human Resources.

Related Employees. You must avoid initiating or approving personnel actions affecting

reward or discipline of employees or applicants where there is a family relationship or a

personal involvement.


Rev. May 19, 2011

Use of the Office Property. You may not use the Office property, facilities, or equipment

for personal gain. You may not operate a private business from Office grounds, on

Office time, or with Office materials.

Loan Applications. Loan applications submitted to lending officers by relatives or close

personal friends (or entities controlled by relatives or close personal friends) should be

submitted to other lending officers of equal or higher position for processing and

approval. This rule also applies to processing and approving overdrafts and waiver of

service fees.

Personal Investments. You may not make an investment as a result of an opportunity that

arises out of any employee‟s professional relationship with a client, prospective client or

venture capital fund.

Perception of Impropriety. You must avoid any actions that can be perceived as

improper or unfair in dealing with customers, suppliers or any other person.

Violation of any of the above provisions will be considered as a serious breach of the

rules or policies of the Office and your service for the Office may be terminated without

notice.

Business Courtesies

Giving or receiving common courtesies (such as business meals) usually associated with

accepted business practice is acceptable. However, in any such dealings, employees

should not request, accept, offer to give or give anything of value, the express or implied

purpose or result of which is to influence the bona fide business relationships between the

Office and such person or entity.

Gifts, Advantages & Entertainment

U.S. and PRC:


Rev. May 19, 2011

Except to regulators, government officers or other public officers, where specific rules

apply, SVB recognizes that the giving and receiving of gifts and entertainment is an

important part of developing and maintaining business relationships. Employees are

encouraged at all times to ensure that their activities in this area align with the following

key principles:

Ensure that the intent or purpose behind the gift or entertainment activity is open and

honest, and aligns with SVB‟s Core Values and Standards. Anything that is designed

to improperly influence a business relationship or to bribe another not only

contravenes our Core Values but may also be illegal.

Adhere to the SVB Employee Expense Reimbursement Policy, which provides

specific guidelines on business development-related events, gift and entertainment

limits.

When representing SVB internationally, exercise appropriate local discretion. The

attached Appendix 5 provides additional information on local business practices and

customs in each of SVB‟s international locations. and strict compliance to the

provisions herein and in the Appendix is required (where there is a conflict between

the general rules herein and the specific local rules, you are advised either to comply

with the stricter rule, or seek clarification from your manager and the Head of Human

Resources). Violation of this provision will be considered as a serious breach of the

rules and policies of the Office and your service for the Office may be terminated

without notice.

Employees must seek guidance from their manager if, after reviewing the policies and

appendices referenced above, they are uncertain whether their activities are in

compliance.

Further, a gift given by you or an agent for you in connection with Office business must

not violate restrictions against bribes under PRC laws and regulations and the U.S.

Foreign Corrupt Practices Act.

Other Outside Positions

You may not serve as an officer, director, advisory director, honorary director, committee

member, or in any management position of an outside business organization without the

prior written approval of the Head of the Office and the Head of Human Resources. You

may not serve as an officer, director, advisory director, advisory director, honorary


Rev. May 19, 2011

director, committee member, or in any management position for an SVB client without

also obtaining the prior written approval of the CEO. Violation of this provision will be

considered as a serious breach of the rules or policies of the Office and your service for

the Office may be terminated without notice.

16. INSIDER TRADING

If you are in possession of “material nonpublic information” (or “inside information”)

about another company, you must not trade in or recommend the purchase or sale of the

stock or other securities of that company until the information has been made available to

the public. Inside information includes any material information, written or oral, that is

not generally available to the public. Not only are employees prohibited from buying or

selling securities based upon inside information, the law also imposes liability upon

anyone who discloses inside information to an outsider who uses that information to trade

in securities or passes the information along to someone else who does. Violation of this

provision will be considered as a serious breach of the rules or policies of the Office and

your service for the Office may be terminated without notice.

17. DISCIPLINARY OFFENCES

Without prejudice to any conduct mentioned elsewhere in this handbook that will subject

you to dismissal without notice,

(i) if you commit misconduct of a minor nature, you will receive an oral or written

warning from your supervisor or a higher level of management. You should

treat such warning seriously and refrain from committing any further

misconduct. Examples of minor misconduct include but is not limited to bad

time keeping, unreasonable or persistent absenteeism and other minor breach of

rules listed in this handbook;

(ii) if you commit misconduct of such nature that it fundamentally breaches the

contractual relationship between you and the Office or is a gross violation of

the rules, policy and/or principles set out in this handbook, you may receive a


Rev. May 19, 2011

written notice from your supervisor or a higher level of management asking

you to stop or rectify the breach. Alternatively, you may be dismissed without

notice. Other than such serious breaches as expressly stated in this

Employment Handbook, examples of gross misconduct include repeated

breaches of the rules and principles of this handbook, fraud, breach of

confidentiality, violent behaviour and being committed of a criminal offence;

(iii) you will also be subject to dismissal if you have shown incapability to perform

your job efficiently and competently. In cases of incapability, the Office may if

it chooses to, implement appropriate procedures, arrangements and/or training,

if necessary, with a view to encouraging you to improve to an acceptable level.

If you still prove to be incapable of performing your duties thereafter, you will

be dismissed after a notice has been served upon you.

18. BEHAVIOURAL RULES

Alcohol & Drugs

Alcoholic drink must not be brought into the Office's premises for consumption.

Drinking which affects your performance or behaviour at work may be a reason for

dismissal when it affects your capability or results in intolerable behaviour, intolerable

absence, lateness, etc. This also applies to the possession of and being under the

influence of drugs except where medically prescribed. The Office considers excessive

drinking to be gross misconduct justifying dismissal without notice.

The Office reserves the right to ask any employee to submit to a drug test where an

employee‟s conduct, behaviour or work performance gives reason to believe that an

employee is under the influence of drugs. Violation of this provision will be considered

as a serious breach of the rules or policies of the Office and your service for the Office

may be terminated without notice.

Betting & Gambling, etc.

You are not allowed at any time to engage in gambling of any nature on the Office's

premises, nor be involved in the distribution or traffic in betting slips.


Rev. May 19, 2011

Also, you are not allowed to sell tickets for events outside the business, organise raffle

tickets or undertake private trading on the Office's premises or car park.

Violation of the above provisions will be considered as a serious breach of the rules or

policies of the Office and your service for the Office may be terminated without notice.

Smoking

The Office maintains a smoke-free work environment and expects all employees to

strictly observe designated smoking areas outside the office building. Smoking in the

Office‟s premises will be a disciplinary offence and will thus be subject to disciplinary

action and persistent breaches of this provision will be considered as a serious breach of

the rules or policies of the Office and your service for the Office may be terminated

without notice.

Harassment

The Office believes in treating all employees and clients with sensitivity and respect,

consistent with our Core Values and Standards, regardless of physical or mental

disability, and consistent with our obligations under laws. The Silicon Valley Bank

Harassment-Free Workplace Policy should be observed from time to time, and failure to

comply with the same will be a disciplinary offence and will thus be subject to

disciplinary action that may lead to dismissal without notice.

19. MISCELLANEOUS

Performance Appraisals

These ensure the Office's objectives are achieved and assists in identifying training needs

and ensures your continuous development. Therefore, in relation to the performance of

your duties, and in order for us to discuss your future progress, you will be required to

participate in any appraisal scheme which we may have from time to time and for this

purpose participation means being involved in the scheme as appraiser, an appraisee, or


Rev. May 19, 2011

both. A copy of your appraisal will be kept in your personal file. Appraisals will be with

your immediate superior.

However, informal monitoring may continue throughout the year and you may be asked

to attend discussions with your immediate supervisor.

Professional Appearance

The Office endorses a “business casual” dress style in its work locations, on an “as

appropriate” basis. All employees, even those who do not have direct customer contact,

represent the Office in the community at large. Since it is important to project an image

of competence and efficiency upon which the Office‟s reputation has been built,

grooming and dress is to be neat and professional at all times. Formal or traditional

business attire is to be worn when appropriate to business circumstances.

Expenses

The Office will reimburse all expenses properly incurred by you in the proper

performance of your duties provided that on request you provide the Office with such

receipts or other evidence of actual payment of such expenses that the Office may

reasonably require. You should discuss anticipated expenses with your reporting

manager prior to incurring them.

Claims for reimbursement of expenses should be made on a calendar month basis as soon

as possible after the end of the month, but more frequent claims may be made if

reasonable and necessary. Advances may be obtained in respect of specific expenses to

be incurred with prior approval and they will be given only on the understanding that

they will be wholly accounted for by the submission of a business expense claim form

within 7 days of the receipt of the advance. Advances which are no longer required must

be returned immediately. The Office reserves the right to withhold from your salary

payments of any advances which have not been accounted for. Employees must take all

reasonable steps to minimise expenses.

Statement to Media


Rev. May 19, 2011

All media inquiries regarding the Office and its parent / subsidiary companies must be

referred to the Director of Public Relations. Only the CEO, the CFO and the Director of

Public Relations are authorized to make or approve public statements pertaining to the

Office or its operations. No employees, unless specifically designated, are authorized to

make statements to the media. Any employee wishing to write and/or publish an article,

paper, or other publication on behalf of the Office must first obtain approval from the

Head of the Office before publication. Violation of this provision will be considered as a

serious breach of the rules or policies of the Office and your service for the Office may

be terminated without notice.

Income Pay and National Insurance

Withholding tax on your remuneration and compulsory contributions to the statutory

insurance scheme will be deducted from salary payments in accordance with the relevant

law, rules and regulations.

Car Park

The Office is not bound to provide you with staff car parking facilities and does not

accept liability for damage or loss incurred whilst your vehicle is parked on the Office's

premises.

Any motor vehicle brought onto the Office‟s premises by an employee must be insured in

respect of third party risks.

Any unauthorised use of the Office‟s car park for up to 3 times will be considered as a

serious breach of rules or policy of the Office and may lead to dismissal without notice.

Lost Property


Rev. May 19, 2011

Property lost or stolen should be reported to the Client Services Manager at once.

Property found in the Office's premises should be sent to the Client Services Manager

and items of value will in turn be passed to the Public Security Bureau.

Other Employment & Outside Activities

You must devote the whole of your time, attention and abilities during your hours of

work to your duties for the Office. You may not, under any circumstances, whether

directly or indirectly, undertake any other duties of any kind (whether for personal and/or

business purposes) during your hours of work for the Office. You must not in any

circumstances engage in any employment outside your hours of work with the Office.

Unless special permission is obtained, you must not undertake outside activities which

would involve your absence from work or result in reduced personal efficiency.

Violation of this provision will be considered as a serious breach of the rules or policies

of the Office and may lead to termination of your service for the Office without notice.

Personal Effects

Personal effects should at no time be left unattended and the Office does not accept

responsibility for their damage or disappearance.

Private Telephone Calls, Correspondence and use of the Office's Facilities

The Office relies a good deal on telephone communications and it is important that the

system is kept free for the conduct of business. Non-essential private telephone calls are

therefore discouraged, but necessary and brief private telephone calls at your expense are

permitted from the office telephones. The Office‟s e-mail policy is set out below. This

concession must be exercised in such a way that there is no more than a minor disruption

of your work if and when making a private telephone call. However, we reserve the right

to withdraw this facility if reasonably believing that it is working unsatisfactorily, or is


Rev. May 19, 2011

being abused. Similarly, you are requested not to make private use of the Office's

photocopier, fax or postal (including franking) facilities.

Private correspondence must not be sent to the Office's address, nor should

correspondence relating to work be sent to a private address. The Office accepts no

liability for any private letters which may arrive at the Office's premises and can give no

guarantee that they will not be opened. The Office's stationery must not be used for

personal correspondence. No orders for goods or services other than those required and

authorised by the Office for its business may be placed in the Office's name. Overall,

you must not use the Office's time, resources or materials for private purposes, and must

avoid any conduct which may be prejudicial to the efficiency or reputation of the Office.

Failure to observe these rules will be a disciplinary offence and will thus be subject to

disciplinary action that may lead to dismissal without notice.

Mobile Telephones

Use of personal mobile telephones should be minimised in the workplace unless the use

is work related. Personal mobile telephones are permitted to be used in an emergency.

Computer system

Employees should not make any unauthorised modification to any software, hardware or

other component of the Office‟s computer system.

Employees should not install any software or hardware without such software or

hardware and its relevant licences or terms and conditions of use being inspected and

approved by a representative of senior management with overall responsibility for IT.

Failure to observe these rules will result in disciplinary action being taken against you,

and that may lead to dismissal without notice.

Employees must do their utmost to protect the security of the computer system and guard

against virus attack.


Rev. May 19, 2011

Employees have no expectation of privacy in, and SVB may monitor at any time without

notice, all communications conducted on or through SVB computers, equipment, systems

or network.

You are required to comply with the End User Services Policies and Procedures attached

hereto as Appendix 4. Failure to comply with the same will be a disciplinary offence and

will thus be subject to disciplinary action that may lead to dismissal without notice.

SVB Electronic Communications and Messaging Systems

The Office‟s computer systems contain messaging facilities which are intended to

promote effective communication within the organisation on matters relating to business.

Personal messages may be sent but these should respect the primary purpose of the

messaging systems. This means the messaging systems should not be used for a purpose

detrimental to your job responsibilities, for spreading gossip, or for personal gain or in

breach of any of the Office‟s standard employment policies on issues, such as sexual

harassment.

Messages sent on the messaging systems are to be written in accordance with the

standards of any other form of written communication and the content and language used

in the message must be consistent with best Office practice. Messages should be concise

and directed to those individuals with a need to know. General messages to a wide group

should only be used where necessary.

Confidential information should not be sent externally by any form of messaging without

express authority and unless the messages can be lawfully encrypted.

Messages sent over the Office‟s systems can give rise to legal action against the Office.

Claims of defamation, breach of confidentiality or contract could arise from a misuse of

the system. It is therefore vital for messages to be treated like any other form of

correspondence and where necessary hard copies to be retained. You are also reminded

that messages are disclosable in any legal action commenced against the Office relevant

to the issues set out in the messages.

The Office reserves the right to retrieve the contents of messages for the purpose of

monitoring whether the use of the messaging system is legitimate, to find lost messages


Rev. May 19, 2011

or to retrieve messages lost due to computer failure, to assist in the investigation of

wrongful acts, or to comply with any legal obligation.

If you are given access to the messaging systems you are responsible for the security of

your SVB equipment and you must not allow the SVB equipment to be used by an

unauthorised person.

You should therefore keep your personal passwords confidential and change it regularly.

When leaving your SVB equipment unattended or on leaving the office you should

ensure you log off the system to prevent unauthorised users using your equipment in your

absence.

Should you receive an electronic message which has been wrongly delivered to you, you

should notify the sender of the message for redirecting the message to that person.

Further in the event the message contains confidential information, you must not disclose

or use that confidential information. Should you receive an electronic message which

contravenes this policy, the message should be brought to the attention to your immediate

supervisor.

Failure to observe these rules will result in disciplinary action being taken against you,

and that may lead to dismissal without notice.

Internet

The Office recognises that the Internet is a valuable commercial tool.

Employees are requested to make considerate use of the Internet and to refrain from using

the Internet for personal purposes.

The transmission and distribution of indecent and offensive images, programmes and

documents is a serious disciplinary matter.

The Office will routinely monitor Internet activity.


Rev. May 19, 2011

Punctuality

In order to ensure a high standard of efficiency and service, punctuality is very important.

If you are late you must advise the Office of the reason, in advance wherever possible,

and you will be expected to make up the time that day. Persistent lateness will be subject

to disciplinary action that may lead to dismissal without notice. You should also not

leave before your finishing time without your immediate supervisor‟s express consent.

Bad Weather

You are expected to make every reasonable effort to get to work during bad weather.

Whistle-blowing policy

All organisations face the risk of things going wrong or of unknowingly harbouring

malpractice. The Office believes it has a duty to identify such situations and to react

accordingly.

By encouraging a culture of openness, the Office wants to encourage you to raise issues

which are of concern to you at work.

If there is anything which you think the Office should know about, please use the

following procedure:

1.) If you are concerned about any form of malpractice, you should normally first

raise the issue with your immediate supervisor.

2.) However, if you feel unable to tell your immediate supervisor, please raise the

issue with the Head of the Office.


Rev. May 19, 2011

3.) If you have raised concerns and you are still concerned, or the matter is so serious

that you feel you cannot discuss it with either of the two persons mentioned

above, you should raise the matter with your Human Resources Business Partner,

any member of the Steering Committee or the Chairman of the Audit Committee,

SVB Financial Group Board of Directors. You may also make an anonymous and

confidential report by logging onto www.ethicspoint.com from any computer with

access to the Internet or by calling their toll-free Hotline at 866-ETHICSP (001-

866-384-4277).

After you have raised your concern, the Office will decide how to respond in a

responsible and appropriate manner under this policy.

In so far as is possible, the Office will endeavour to keep you informed of any decisions,

enquiries and investigations which have been carried out. Please note that the Office may

not be able to inform you of matters which would infringe the duty of confidentiality

which is owed to others.

Staff should of course on the other hand not engage in any fraudulent activity or any

activity in connection with his employment that may constitute a crime, e.g. defrauding

tax authorities or commercial bribery. The Office‟s management is not responsible for

individual criminal acts. No staff is allowed to remove the Office‟s chop from the

Office‟s premises or use it without the authorisation of an Officer or use any name card

that is not provided by the Office. Any failure to comply with such obligations will lead

to dismissal without notice and a possible claim for indemnity by the Office.

References

The Office does not give open references but will respond to specific requests from third

parties who should be asked to contact the Office direct. The Office reserves the right

not to provide a reference but any reference that is given will take into account the whole

of your service. Your employment is subject to the receipt of satisfactory references.

Rules



Rev. May 19, 2011

Various rules exist for the smooth, effective and safe operation of business and the

welfare and interest of those who work for us. If you are subject to any particular rules

then, once you have been informed, you will be expected to comply with them.

However, from time to time we may exercise our right to change existing rules or to

introduce new ones with which you as an employee will be required to observe.

Information about particular rules will normally be provided in circular to staff on notice

boards, or otherwise brought to the attention of those required to observe them. A breach

of any such rule may render you liable to disciplinary action. However, rules should be

seen as essential in generating a convivial working environment, preferring to develop

the Office on the basis of mutual respect and co-operation.

The SVB Employment Handbook is available in English and Chinese. Where there

are any inconsistencies between the two versions, the English version shall prevail.

Neither this handbook nor the plans or benefits described in this handbook creates an

agreement for employment, nor a guarantee of employment, between Silicon Valley

Bank and any employee. The Employment Agreement between FESCO and the

employee will prevail where there is conflict between the Employment Agreement and

this handbook regarding any plans or benefits contained therein. Silicon Valley Bank

reserves the right to amend or discontinue any program at any time with or without

notice and as in its sole judgment may be necessary. However, any amendments made

to the rules and principles are not binding upon the employee unless they are expressly

made known to the employees. Should any provision of this document be declared

illegal or unenforceable by any court of competent jurisdiction and cannot be modified

to be enforceable, such provision shall immediately become null and void, leaving the

remainder of this document in full force and effect.


Rev. May 19, 2011

Appendix 1

Silicon Valley Bank Harassment-Free Workplace Policy


Rev. May 19, 2011

Appendix 2

Safety Policies and Guidelines


Rev. May 19, 2011

Appendix 3

Confidential Information and Invention Assignment Agreement for Employees


Rev. May 19, 2011

Appendix 4

End User Services Guidelines Manual


Rev. May 19, 2011

Appendix 5

Gift & Entertainment Guidelines – China

General Overview

Chinese law prohibits gift giving that amounts to commercial or criminal bribery.

Gifts, cash, advantages or entertainment for the purposes of bribery are

prohibited.

Recommended Business Gifts & Practices

A gift to a “company" should be given to the most senior person, as they

represent the company. Gifts given to people at the same level should be of

similar value.

Recommend gifts displaying the SVB logo; location-related gifts (e.g. coffee

table book about California); good Cognac or other fine liqueur; fine pen (not

red ink).

Gifts should always be wrapped, ideally in red paper.

Reference the book “Kiss, Bow or Shake Hands” for more context on

international business practices and norms. You can find a copy at your local

bookstore.

Inappropriate Business Gifts & Practices

Watches; sharp-edged items (e.g. scissors, knives); black or white wrapping

paper; handkerchiefs.

Anything containing the number 4 (Number 4 is considered unlucky).

Giving a valuable gift to one person versus giving something to the whole

group is considered inappropriate.

Gift & Entertainment Guidelines – India

General Overview

Gifts, cash or entertainment for the purposes of bribery are prohibited by Indian

law.


Ties, pens, clocks; gifts representing your country (e.g. Swiss chocolate, French

perfume); gifts with the SVBFG logo.

If visiting someone's home, bring chocolates, Indian sweets or flowers. If your host

drinks, Scotch whisky is a favorite.

Wrap gifts in red, green or yellow, as these are all considered lucky colors.

Reference the book “Kiss, Bow or Shake Hands” for more context on international

business practices and norms. You can find a copy at your local bookstore.


Rev. May 19, 2011


Serving alcohol or pork to a Muslim; serving beef or giving a leather item to a

Hindu.

Refusing an offer of coffee or tea, especially in someone's home.

Black or white wrapping paper is considered unlucky.

India is a large, diverse country. Customs vary by region, so ask one of our employees in India or another local contact for advice.

Gift & Entertainment Guidelines – Israel

General Overview

Gifts, cash or entertainment for the purposes of bribery are prohibited by Israeli

law. There is a strict distinction between gifts within the private sector and gifts to

members of the public sector.


Dinner, tickets to sporting events; gifts (flowers, wine chocolates) on major

holidays (Jewish New Year, Passover).

Invitations to newly opened international offices; invitations to events with

famous musicians/actors.

Reference the book, “Kiss, Bow or Shake Hands” for more context on


bookstore.


Non-kosher food.

Scheduling events/activities on religious/national holidays (e.g. Yom Kippur,

National Memorial Day).

Gift & Entertainment Guidelines – United Kingdom

General Overview

There are various restrictions under both U.K. common law (non-statutory) and

statutory law surrounding the giving of corporate gifts or entertainment. Gifts,

cash or entertainment for the purposes of bribery are prohibited.


Giving gifts is not a normal part of British business culture. Some British

business colleagues may feel embarrassed to receive any gift at all. The only

exception would be at the conclusion of a deal when it might be appropriate to


Rev. May 19, 2011

give a unique commemorative item to mark the occasion. Such items might be

gold, silver, or porcelain, with a suitable inscription. Alternatively, other

small gifts such as a pen or a book, again suitably inscribed, would be

acceptable.

Drinks, meals, invitations or tickets to events (sports, theater, musical) are all

acceptable forms of gifts.

Business gifts are never exchanged at Christmas but it may be appropriate to

send a card, particularly as an expression of thanks to business associates but

also as a means of maintaining valuable contacts. In the unlikely event that

you yourself receive a gift, you should be sure to reciprocate.

Reference the book “Kiss, Bow or Shake Hands” for more context on


bookstore.


The U.K. has similar norms to the U.S. in the giving of business gifts.


Rev. May 19, 2011

Appendix 6

SVB Steering Committee Members Telephone Numbers

President & CEO, Silicon Valley Bank & SVB Financial Group Greg Becker

001-408- 654-7345

Head of Relationship Management

John China

001-650-233-4207

Chief Marketing Officer

Brian Dennehy

001-408-654-3022

General Counsel

Mary Dent

001-650-320-1119

Chief Financial Officer

Michael Descheneaux

001-408- 654-7437

Head of Human Resources

Chris Edmonds-Waters

001-415-764-4706

Chief Credit Officer

Dave Jones

001-408- 654-7778

Vice Chairman of Silicon Valley Bank

Head of Strategic Relationships

Harry Kellogg

001-650- 233-4229

Head of US Banking

Joan Parsons

001-650-320-1159

Chief Strategy & Risk Officer

Marc Verissimo

001-408- 654-5582

Chief Operations Officer

Bruce Wallace

001-408- 654-3412



866-ETHICSP (866-384-4277)


Dial U.S. Country Access Code and 866-ETHICSP

(001-866-384-4277)



All CONTACTS ARE CONFIDENTIAL

http://www.svb.com/company/executive.asp?bio=gbecker

http://www.svb.com/company/executive.asp?bio=mdent

http://www.svb.com/company/executive.asp?bio=mdescheneaux

http://www.svb.com/company/executive.asp?bio=cewaters

http://www.svb.com/company/executive.asp?bio=hkellogg

http://www.svb.com/company/executive.asp?bio=mverissimo



Rev. May 19, 2011

Appendix 7

Overtime Approval and Claim Form

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