Whistleblowing Policy Disclosed on the Bank Official Website

 

The Whistleblowing policy

 

The Bank is committed to upholding and enhancing corporate governance standards and strongly values the ethical conduct and integrity of its staff members. To this end, the Bank has established a whistleblower policy (hereinafter referred to as the "Policy"), so that external parties who have dealings with the Bank (such as customers and suppliers) can report through specific channels established by the Policy if they find that the Bank has or may have committed improper acts.

 

This “Implementation Rules” are hereby formulated in accordance with relevant provisions of BOCHK Group whistleblowing policy and the National Bank of Cambodia's Prakas on <Internal Control of Banks and Financial Institutions> relevant whistleblowing requirement.

 

Scope of Whistleblowing

 

The scope of reporting under this policy includes but is not limited to the following improper behaviors:

  1. Issues concerning the Bank’s financial matters, such as providing false financial data to external parties or using fictitious invoices for reimbursement;

  2. Issues concerning the Bank’s internal control, such as loopholes identified in certain business processes or procedures;

  3. Issues concerning the Bank’s staff members committing bribery or corruption;

  4. Issues concerning the Bank’s staff members being suspected of money laundering, terrorist financing, tax evasion, weapons proliferation financing or violation of sanctions requirements;

  5. Other possible improper conducts; and

  6. Any behavior attempting to conceal the abovementioned misconducts.

 

For comments or suggestions on our services or products, unless they involve any of the above-mentioned improper conduct, you should report them to the Bank's customer feedback unit. If necessary, you can submit your comments through the "Contact Us" section of our website.

 

 

Channels for Whistleblowing

 

The whistleblower can make report to any one of our Integrity Supervisor, Compliance Officer or Head of Audit Department within the reporting scope listed in this policy.

 

Please fill in the "Report Form" and submit your report through the following channels:

 

To the Bank's officer-in-charge

 

Email address: whistleblowing@bankofchina.com.kh

 

Mailing address: Canadia Tower, 21st Floor, No. 315, Ang Duong St. (Corner of Monivong Blvd), Phnom Penh, Cambodia, P.O. BOC110. (the envelope should be marked “to be opened by addressee only”) The recipient can mark as either Integrity Supervisor, Compliance Officer or Head of Audit Department.

 

If the report involves Bank's officer-in-charge, the whistleblower can report to the Group through the BOCHK website. We encourage whistleblowers to provide clear and sufficient information or contact information in order to avoid delaying or hindering the Bank's investigation into the case.

 

Anonymous Whistleblowing

 

The Bank accepts anonymous whistleblowing. However, anonymous reports may be difficult to follow up due to the inability to obtain further information from the reporter. Therefore, the Bank encourages reporters to provide their real names and contact information to facilitate subsequent follow-up work.

 

Protection of Whistleblowers

 

The Bank encourages whistleblowers to make reports in good faith. The Bank will strive to ensure that the identities of all whistleblowers are kept confidential, and will firmly support their actions and protect their rights.

 

If any person pursues or retaliates against a person who makes a report under this policy, the Bank reserves the right to take appropriate action against him or her.

 

False Report

 

If the whistleblower makes a false report maliciously, the Bank reserves the right to take appropriate action against him/her to recover any loss or damage caused by the false report.

 

Confidentiality of reported incidents

  1. The whistleblower must keep confidential the facts of the report, the content of the report and the identity of the persons involved to ensure that the investigation is not hindered.

  2. The report and its related data are confidential to the Bank. Anyone involved in handling or contacting the report must strictly protect the privacy and rights of the whistleblower and the person being reported in accordance with the laws during the handling and contact process of the report, and must not make any acts of leaking secrets, otherwise the company will hold the relevant persons accountable.

  3. The Bank may need to disclose the identity of the whistleblower for investigation purposes. If such a situation occurs, the Bank will notify the whistleblower that his or her identity may be disclosed if feasible.

  4. If the investigation develops into criminal prosecution, the whistleblower may be required to provide evidence to the relevant law enforcement agency or cooperate in the investigation. In certain cases, the Bank may need to refer the report to the relevant law enforcement agency and may not be able to notify or consult the whistleblower in advance.

Investigation of reported incidents

 

  1. The Bank will arrange for dedicated personnel to follow up promptly on reports received through the designated channels of this policy.

  2. If the reporter provides contact information, the dedicated personnel will notify the reporter that the report has been received and provide the investigation results after the investigation is completed.

  3. If there is sufficient evidence that the reported incident may involve criminal offenses or corruption, the Bank will report the matter to the local law enforcement agency. Once the incident is referred to the law enforcement agency, the Bank will cooperate with the investigation of the relevant law enforcement agency. If the investigation develops into criminal prosecution, the whistleblower may be required to provide evidence to the relevant law enforcement agency or cooperate in the investigation. In certain cases, the Bank may need to refer the report to the relevant law enforcement agency and may not be able to notify or consult the whistleblower in advance.

     

Privacy Policy Statement

The Bank attaches great importance to personal data privacy and is committed to maintaining the security and confidentiality of personal data collected by the Bank. Any personal data provided by the whistleblower to the Bank through the reporting channels listed on this website is equivalent to consent to the use of such personal data in accordance with the Bank's Privacy Policy Statement. The personal data collected will only be used for purposes directly related to the reported incident notified by the whistleblower. Unless permitted or required by law, the Bank will not use the whistleblower's personal data for any other purpose without the consent of the whistleblower. For details on the Bank's management of personal data, please read the Bank's Privacy Policy Statement carefully.