The Whistleblowing System

The Group is committed to upholding and enhancing corporate governance standard and strongly values the ethical conduct and integrity of the employees. In this respect, the Group establishes a whistleblowing system (hereinafter referred to as “the System”), so that in case of being aware of any actual or possible violation of legal and regulatory requirements or improprieties in relation to the businesses or other matters of the Group/the Group’s staff members, external parties dealing with the Group (e.g. customer and suppliers) can make reporting to the Group via designated channels as set up in the System.

The System is established based on the requirements as stipulated in the Appendix C1 “Corporate Governance Code” of the Listing Rules and is applicable to BOC Hong Kong (Holdings) Limited and its affiliated entities.

Scope of Reporting

The scope of reporting covered by the System mainly includes the followings:

  1. Issues concerning the Group’s financial matters, such as providing false financial data to external parties, using fictitious invoices for reimbursement or other fraudulent behaviour;
  2. Major issues concerning the Group’s internal controls, such as major loopholes in business processes or procedures;
  3. Issues concerning the Group’s staff members committing bribery or corruption;
  4. Issues concerning the Group’s staff members being suspected of money laundering, terrorist financing, tax evasion, weapons proliferation financing or violation of sanctions requirements;
  5. Other unethical or questionable practices of the Group’s staff members that may involve violation of legal and regulatory requirements or improprieties, as well as incidents likely to cause great damage to BOCHK’s reputation;
  6. Any behaviour attempting to conceal the abovementioned misconducts.

For reporting falling into the aforesaid scope, the whistleblower should provide detailed information and supporting materials/proof or verifiable link of evidence.

For customer’s comment and suggestion on the Group’s services or products, they should be made to the Group’s relevant unit in charge of customer opinions handling for following up. If necessary, such opinions can be made via “Contact Us” as stated in the BOCHK website.

Reporting Channels

Whistleblowers can make a reporting within the scope as listed above to the General Manager of Group Audit of BOCHK, or directly to the Chairman of the Audit Committee of BOCHK. If the reporting concerns the General Manager of Group Audit of BOCHK, it should be made directly to the Chairman of the Audit Committee of BOCHK.

Whistleblowers may complete the “Whistleblowing Form” and submit via the following channels:

To the General Manager of Group Audit of BOCHK
Mailing address: Group Audit, 41F, Bank of China Tower, 1 Garden Road, Hong Kong
(the envelope should be marked “to be opened by addressee only”)
Email address: whistle_blower@bochk.com

To the Chairman of the Audit Committee of BOCHK
Mailing address: Group Audit, 41/F, Bank of China Tower, 1 Garden Road, Hong Kong
(the envelope should be marked “to be opened by addressee only”)
Email address: acchairman@bochk.com

 

Anonymous Reporting

The Group accepts anonymous reporting. Nevertheless, anonymous reporting, might lead to difficulties in following up owing to the inability to obtain further information from the whistleblower.  In this connection, whistleblowers are encouraged to provide their real identity and contact information for following up if necessary.

Protection for Whistleblowers

The Group encourages whistleblowers to report in good faith. The Group shall conduct fair and impartial, independent, as well as professional investigation and strive to keep the identity of the whistleblowers in strict confidence, protecting their legitimate rights/interests.

In the event of someone retaliating or seeking revenge against any whistleblowers who made reporting according to the System, the Group shall reserve the right to take necessary action against that person.

Unfounded Reporting

In the event of whistleblowers making unfounded reporting maliciously or abusing the reporting mechanism for personal objectives, the Group shall reserve the right to take necessary action against that person, so as to recover any damages or losses caused by the unfounded reporting.

Confidentiality of Reporting

  1. Whistleblowers should keep his/her reporting confidential, including the facts, subject issues and parties involved, so as to avoid hindering the investigation.
  2. Reporting and its related information are confidential information to the Group. Anyone handling or having access to the information shall strictly follow the legal requirements to protect the privacy and legitimate rights/interests of the whistleblowers and the parties being reported against. There should not be unauthorized disclosure, or the Group shall hold the relevant persons accountable.
  3. The Group might have to disclose the identity of the whistleblowers in the course of investigation. If that happens, the Group shall wherever possible notify the whistleblower concerned in advance of the circumstance.
  4. In case the investigation becomes criminal prosecution, the whistleblower concerned might have to provide evidence to the enforcement authorities directly and cooperate with the investigation. Besides, under certain circumstances, the Group is required to refer the reporting to relevant enforcement authorities without prior notice to the whistleblower or seeking his/her consent.

Investigation

  1. Upon receipt of reporting via channels under the System, the Group shall designate an officer-in-charge to promptly follow up on the case.
  2. If the whistleblower has provided contact information, the officer-in-charge shall acknowledge receipt of the reporting to the whistleblower. The investigation results may also be provided to the whistleblower upon completion of the investigation where appropriate, to the extent permitted by applicable laws and regulations.
  3. In case there is sufficient evidence to suggest that a reporting may involve criminal offence or corruption, the Group shall report the case to the enforcement authorities in accordance with the applicable laws of the relevant jurisdiction. Once the case is referred to the enforcement authorities, the Group shall provide full support to the authorities in relation to the investigation.

Privacy Policy Statement

The Group highly values personal data and privacy and strives to preserve the confidentiality and security of all the personal data which the Group may collect. By providing any personal data to the Group through the whistleblowing channels as specified on this website, whistleblowers are consenting to the Group’s use of his/her personal data as set out in the Group’s Privacy Policy Statement. In particular, the personal data will only be used for the direct handling of the whistleblowing reporting but not for any other purposes without the whistleblowers’ consent unless the use is required or permitted by the law. For more information on how the Group manages personal data, please refer to the Group’s Privacy Policy Statement .