Referral Designation Types
A referral is the introduction or support of a candidate or Contingent Worker to JPMC at any stage in the recruiting, hiring or onboarding process. Referrals must fit into one of three referral designation types: 1) Government Officials and their Agents; 2) Client, Potential Client or Other Business Contact, or 3) Personal/Professional.
The Anti-Corruption Policy requires pre-clearance before any offer is extended to a candidate who was referred to the firm for potential employment by a 1) Government Official and Their Agents, or 2) Client, Potential Client, or Other Business Contact. Therefore, employees must accurately identify the source of the referral.
If multiple referral designation types are applicable, select the only one option based upon the order of highest risk, with Government Officials and their Agents having the highest level of risk followed by Client, Potential Client or Other Business Contact followed by Personal/Professional. For more guidance on selecting the accurate referral designation, see the FAQs.
Definitions of the referral designation types are as follows:
- Government Officials and their Agents: The referral is from a Government Official. Pursuant to the Anti-Corruption Policy, Government Officials includes all officials, employees (regardless of position, rank or level), or agents of any of the following:
- U.S. and non-U.S. Government bodies, departments, agencies, instrumentalities, corporates or other political subdivisions of a national, state or local government body. This is construed broadly, which would encompass employees of entities such as public pension funds, public universities and school districts, public hospitals, port and water authorities, and economic development corporations
- Government-controlled entities (e.g., a sovereign wealth fund or state-owned entity)
- Non-Government Supervisory and Regulatory bodies, including Self-Regulatory Organizations (e.g., FINRA, MSRB, Federal Reserve Bank of New York)
- Public international organizations (e.g., The World Bank, International Monetary Fund, United Nations)
- Political parties or candidates for political office
As identified above, this also comprises Agents of Government officials, including any person acting for or on behalf of any such government or department, agency, or instrumentality. Illustrative examples of Agents of Government officials would include, but are not limited to the following
- Municipal Advisor or Financial Advisor to a government or municipality
- Bond Counsel or other counsel to an issuer of public debt
- Advisor, consultant or intermediary (including Third Party Intermediaries) to a Government Official
- a person or entity with whom JPMC has, expects to benefit from, or is trying to obtain a business, financial or commercial relationship (e.g., actual or prospective customers or clients), or
- the following business relationships where the party is acting as an intermediary, conduit or gatekeeper to a business, financial or commercially beneficial relationship for JPMC:
- Lobbyists for any LOB or Corporate Function;
- Institutional Consultants recommending AWM investment management services to others;
- Investment Banks recommending CIB and CB roles in transactions to others;
- Outside Counsel recommending CIB and CB roles in transactions to others;
- External Accountants and Consulting Firms recommending CIB and CB roles in transactions to others;
- Third Party Intermediaries (TPIs) for any LOB or Corporate Function.