HSBC is committed to fostering a culture of corporate compliance and ethical behaviour. HSBC's Global Whistleblowing Policy and program is one aspect of the bank's overall approach to prevent and detect misconduct and ensure compliance with laws and regulations. This reflects our values of standing firm for what is right and doing the right thing.
HSBC Australia has adopted a local Whistleblowing Policy to encourage and support the reporting with respect to HSBC in Australia or overseas of misconduct, unlawful activity, any improper state of affairs or matters that represent a danger to the public or financial system, and to protect a whistleblower from any detriment or retaliation that may arise as a result of their disclosure.
HSBC encourages its staff and associated parties to raise concerns through their normal contacts, reporting or escalation channels. HSBC encourages its customers to raise concerns via their Relationship Manager.
Occasionally an individual may feel that they are unable to raise concerns through these channels. HSBC Confidential is an alternative way of raising concerns, available to internal and external parties who wish to raise a whistleblowing concern.
A whistleblower is a current or past staff member, director, officer, consultant, associate, supplier and their employees, third party provider, broker, auditor and the relatives, dependants or spouse of any such person, or a dependant of a spouse who has reasonable grounds to suspect that the matter they are reporting concerns an issue as described above.
Under Australian whistleblowing laws, personal work-related grievances are not subject to the statutory protections. Personal work-related grievances are matters about an individual’s employment, or former employment, which have implications for them personally.
In Australia, whistleblowers are afforded legislative protection by means of full confidentiality, unless disclosure of the whistleblower’s identity or identifying information is specifically authorised by law or the whistleblower consents to their identity being disclosed. A whistleblower is entitled to remain anonymous, but may not wish to do so. HSBC’s ability to investigate, ask follow up questions or provide feedback will be reduced if the whistleblower cannot be contacted. It may also be more difficult to put steps in place to protect the whistleblower from detriment if their identity is not known.
Information that may lead to a whistleblower’s identification may need to be disclosed to appropriately investigate the report. HSBC will take all reasonable steps to minimise the risk that whistleblowers will be identified in these circumstances.
HSBC’s Global Regulatory Compliance function is responsible for the oversight of HSBC Confidential and the handling of cases. All cases will be reviewed and referred to the relevant independent subject matter experts for the investigation. Every case will be acknowledged. The length of an investigation will vary depending upon the particular circumstances of each case.
Once an investigation has been concluded, an investigator will give feedback where it is possible and practical to do so.