The Whistleblowing System
The Bank is committed to upholding and enhancing corporate governance standard and strongly values the ethical conduct and integrity of the employees. In this respect, the Bank establishes a whistleblowing system (hereinafter referred to as “the System”), so that in case of encountering any actual or possible violation of legal and regulatory requirements or improprieties in relation to the businesses or other matters of the Bank/the Bank’s staff members, staff members and external parties (e.g. customer and suppliers) dealing with the Bank can make reporting to the Bank via designated channels as set up in the System.
The System is established based on the requirements as stipulated in BOCHK whistleblowing systems, as well as the requirements of the Law on Commercial Banks and the Introduction on Implementation of Data Protection Law of LAO P.D.R.
Scope of Reporting
The scope of reporting covered by the System mainly includes any misconduct of the following areas:
1. Issues concerning the Bank’s financial matters, such as providing false financial data to external parties, using fictitious invoices for reimbursement or other fraudulent behavior;
2. Major issues concerning the Bank’s internal controls, such as major loopholes in 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 violation of sanctions requirements;
5. Other unethical or questionable practices of the Bank’s staff members that may involve violation of legal and regulatory requirements or improprieties; and
6. Any behavior attempting to conceal the abovementioned misconducts.
For customers’ comments and suggestions on the Bank’s services or products, they should be made to the Bank’s relevant unit in charge of customer opinions handling for follow up. For staff appeal, please follow the Bank’s applicable mechanisms to submit the case. If necessary, such opinions can be made via “Contact Us” as stated in the Bank’s official website.
Reporting channels
Whistleblowers may make reports to the Head of Internal audit in the Bank (“officer-in-charge” who is responsible for handing the whistleblowing reports), if the matters concerned are within the scope of reporting. Whistleblowers may complete the “Whistleblowing Form” and submit via the following channels:
Postal address: Internal Audit of BOKHK Vientiane Branch, VIENTIANE CENTER, KHOUVIENG ROAD NONCHAN VILLAGE, SISATTANAK DISTRICT, VIENTIANE CAPITAL, LAO P.D.R (in an envelope clearly marked “to be opened by addressee only”)
Email address: whistleblowing@la.bank-of-china.com
If the reported cases involve officer-in-charge of the Bank, the whistleblowers can make reports to BOCHK Group according to the information disclosed on BOCHK’s official website.
Anonymous Reporting
The Bank accepts anonymous reporting. An anonymous reporting, however, might lead to difficulties in conducting the investigation because the Bank 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 Bank encourages whistleblowers to make reporting in good faith. The Bank 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 Bank shall reserve the right to take necessary action against that person.
Unfounded Reporting
In the event of a whistleblower making unfounded reporting maliciously or abusing the reporting mechanism for personal objectives, the Bank shall reserve the right to take necessary action against that whistleblower, 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 Bank. 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 Bank shall hold the relevant persons accountable.
- The Bank might have to disclose the identity of the whistleblowers in the course of investigation. If that happens, the Bank shall wherever possible notify the whistleblower concerned in advance 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 Bank 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 Bank 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, as well as providing the investigation results permitted by applicable laws and regulations to him/her upon completion of the investigation.
3. In case there is sufficient evidence to suggest that a reporting may involve criminal offence or corruption, the Bank’s designated units 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 Bank shall provide full support to the authorities in relation to the investigation.
Privacy Policy Statement
The Bank highly values personal data and privacy and strives to preserve the confidentiality and security of all the personal data which the Bank may collect. By providing any personal data to the Bank through the whistleblowing channels as specified on this website, whistleblowers are consenting to the Bank’s use of his/her personal data as set out in the Bank’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 Bank manages personal data, please refer to the Bank’s Privacy Policy Statement.
