Your Partner, Your Bank
Whistle Blowing Policy
Setting the standard for ethical practice within our organization.
We have adopted a Whistle Blowing Policy in our organization to maintain the highest possible standards of ethical and legal conduct. The Policy is in furtherance of the Bank’s desire to strengthen the Bank’s system of integrity and fight against corruption, fraud and related offences. In line with our Governance Policy, we require our employees as well as our partners, customers, and other relevant parties to disclose acts of fraud, corruption or misconduct by bank personnel.
Who is a Whistleblower or a Complainant?
A Whistleblower or a Complainant is any party who expresses or is proven to be about to express a complaint, allegation or report which indicates the fraud, corruption or any other misconduct under the policy of Bank Personnel participating in a Bank Venture. Such complaint/allegation/report must be made in good faith, knowing or reasonably believing that the complaint/allegation/report submitted is true.
What Misconduct can you Report?
Typical disclosures include, but are not limited to, the following:
- Unlawful acts or orders requiring violation of a law, gross waste, mismanagement, abuse of authority, substantial and specific dangers to public health and safety.
- Failures to comply with statutory obligations.
- Fraud, which means an act or omission, including a misrepresentation, that knowingly and recklessly misleads, or attempts to mislead, a party to obtain financial or other benefit or to avoid an obligation.
- Corruption, which means the offering, giving, receiving, or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party.
- Coercive practices, which mean impairing or harming, or threatening to impair or harm, directly or indirectly, any party or the property of the party to influence improperly the actions of a party.
- Collusive practices, which mean an arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of a party.
How do you make a Complaint?
A complaint can be registered anonymously using our Hotline Facilities which are available 24 hours a day and 365 days a year:
The Board of Directors
P.O Box 271
64 Hillsborough Street
What Happens when you register a Complaint of Fraud or Misconduct?
- All allegations are registered and screened by the Chairman, Audit Committee of the Board of Directors.
- Once registered, all allegations will be evaluated to determine its credibility, materiality and verifiability. The complaint will be evaluated to determine whether there is a legitimate basis to warrant an investigation.
- Where the preliminary evaluation reveals tangible and credible information that supports the existence of conditions identified by the Policy, a full investigation will be launched to resolve the matter as the Bank deems appropriate.
How will you be protected?
We will make every effort to protect the identity of the Whistle Blower/Complainant but reserve the right to reveal your identity when the Bank reasonably determines that this is necessary. Retaliation which includes any act of reprisal, harassment or vengeance as a result of a Whistle-Blowing Report/Allegation made under the policy, shall not be permissible against any Whistleblower or Complainant. However the protection that the Bank can give to external parties is dependent on the prevailing circumstances and our capabilities. We reserve the right to determine the capabilities of the Bank in this regard.