Investigation Counsel P.C. wishes to announce the commencement of a proposed securities class action against HSBC Holdings plc (“HSBC” or the “Bank”) and David Bagley, HSBC’s former global head of compliance. Bates Barristers, a prominent Toronto-based litigation boutique, will be acting as plaintiff’s co-counsel. The action is being brought on behalf of all investors, subject to certain exclusions, who purchased common shares or ADRs of HSBC between July 31, 2006 and July 11, 2012 (the “Class Period”) and who held those shares or ADRs at the end of the Class Period.

A Statement of Claim has been filed with the Ontario Superior Court of Justice. The legal claims are based on alleged breaches of Part XXIII.1 of Ontario’s Securities Act (addressing secondary market liability) and common law negligent misrepresentation.

HSBC is alleged to have made misrepresentations in relation to its longstanding and systemic compliance, control, and ethical failures, including the Bank’s violations of applicable anti-money laundering and anti-terrorist financing legislation and its alleged participation in schemes to manipulate benchmark interest rates LIBOR and EURIBOR. During the Class Period, it is alleged that HSBC never disclosed these failures and misled investors by touting its commitment to sound corporate governance, its disciplined, ethical culture of risk management, and its adherence to a Code of Ethics, Group Values and Business Principles, and external codes of conduct such as the UK Corporate Governance Code, UN Global Compact, the OECD Guidelines for Multinationals, and the Wolfsberg Anti-Money Laundering Principles. The Bank also allegedly misled investors by representing, expressly and implicitly, that it had properly designed and effective internal controls and comprehensive risk management systems, policies, and practices across its global operations including within Canada.

The truth about these matters was partially revealed in July 2012, causing the Bank to lose approximately $20 billion of market capitalization. Class members, in turn, suffered substantial financial harm.

Investigation Counsel is working with Paul Bates Barrister in the prosecution of this matter.

Inquiries regarding this proposed class proceeding can be directed to John Archibald at Investigation Counsel at (416) 637-3152 or

In order for Investigation Counsel to notify you of important developments in this action when permitted or required to do so by the Ontario Court, please fill out the HSBC Class Action Information Form below.


* This Is Not A Claim Form You are not obligated to fill in this form and, if you choose to do so, you are not retaining Investigation Counsel P.C. to act on your behalf. Your personal information will not be disclosed to a third party without your consent or unless it is required by law.