The Whistleblowing System
The Whistleblowing System
The Company is committed to upholding and enhancing corporate governance standard and strongly values the ethical conduct and integrity of the employees. In this respect, the Company establishes a whistleblowing system (hereinafter referred to as “the System”), so that in case of encountering misconduct which might have happened or will possibly happen, external parties dealing with the Company (e.g. customer and suppliers) can make reporting to the Company via designated channels as set up in the System.
Scope of Reporting
The scope of reporting covered by the System includes but not limited to any misconduct of the following areas:
- Issues concerning the Company’s financial matters, such as providing false financial data to external parties or using fictitious invoices for reimbursement;
- Issues concerning the Company’s internal controls, such as loopholes identified in certain business processes or procedures;
- Issues concerning the Company’s staff members committing bribery or corruption;
- Issues concerning the Company’s staff members being suspected of money laundering, terrorist financing, tax evasion, weapons proliferation financing or violation of sanctions requirements;
- Other possible improper conducts;
- Any behaviour attempting to conceal the abovementioned misconducts.
In relation to comment or suggestion on the Company’s services, unless it is within the scope of misconduct as listed above, they should be made to the Company’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 Company’s website.
Reporting Channels
Whistleblowers can make a reporting within the scope as listed above to the Manager of Internal Audit of BOCI-Prudential Trustee Limited (“BOCI-Prudential”), or directly to the Audit Committee of the Company.
Whistleblowers may complete the “Whistleblowing Form” and submit via the following channels:
To the Manager of Internal Audit of BOCI-Prudential
Mailing address: Suites 1501-1507 & 1513-1516, 1111 King's Road, Taikoo Shing, Hong Kong
(the envelope should be marked “to be opened by addressee only”)
Email address: whistle_blower@bocpt.com
To the Chairman of the Audit Committee of BOCI-Prudential
Mailing address: Suites 1501-1507 & 1513-1516, 1111 King's Road, Taikoo Shing, Hong Kong
(the envelope should be marked “to be opened by addressee only”)
Email address: auditcommittee@bocpt.com
Anonymous Reporting
The Company accepts anonymous reporting. An anonymous reporting, however, might lead to difficulties in conducting the investigation because the Company is not able to obtain further information from the whistleblower. In this connection, whistleblowers are encouraged to provide their identities and contact information to facilitate further follow up.
Protection for Whistleblowers
The Company encourages whistleblowers to report in good faith. The Company shall keep the identity of the whistleblowers in strict confidence, unswervingly support their acts and protect their legitimate rights.
In the event of someone retaliating or seeking revenge against any whistleblowers who made reporting according to the System, the Company shall reserve the right to take necessary action against that person.
Unfounded Reporting
In the event of whistleblowers making unfounded reporting maliciously, the Company 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
- Whistleblowers should keep his/her reporting confidential, including the facts, subject issues and parties involved, so as to avoid hindering the investigation.
- Reporting and its related information are confidential information to the Company. Anyone handling or having access to the information shall strictly follow the legal requirements to protect the privacy, rights and interests of the whistleblowers and the parties being reported against. There should not be any unauthorized disclosure, or the Company shall hold the relevant persons accountable.
- The Company might have to disclose the identity of the whistleblowers in the course of investigation. If that happens, the Company shall wherever possible notify the whistleblower concerned of the circumstance.
- 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 Company is required to refer the reporting to relevant enforcement authorities without prior notice to the whistleblower or seeking his/her consent.
Investigation
- Upon receipt of reporting via channels under the System, the Company shall designate an officer-in-charge to promptly follow up on the case.
- If the whistleblower has provided contact information, the officer-in-charge shall acknowledge receipt of the reporting to the whistleblower, as well as provide the investigation results to him/her upon completion of the investigation.
- In case there is sufficient evidence to suggest that a reporting may involve criminal offence or corruption, the Company 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 Company shall provide full support to the authorities in relation to the investigation.
Privacy Statement
The Company highly values personal data and privacy and strives to preserve the confidentiality and security of all the personal data which the Company may collect. By providing any personal data to the Company through the whistleblowing channels as specified on this website, whistleblowers are consenting to the Company’s use of his/her personal data as set out in the Company’s Privacy 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 Company manages personal data, please refer to the Company’s Privacy Statement.