BOC Life (the “Company”) is committed to upholding and enhancing corporate governance 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 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 Company/the Company’s staff members, 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 mainly includes the followings:
- Issues concerning the Company’s financial matters, such as providing false financial data to external parties, using fictitious invoices for reimbursement or other fraudulent behaviour;
- Major issues concerning the Company’s internal controls, such as major loopholes in 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 unethical or questionable practices of the Company’s staff members that may involve violation of legal and regulatory requirements or improprieties, as well as incidents likely to cause great damage to the Company’s reputation;
- 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 Company’s services or products, they should be made to the Company’s relevant channel in relation to customer opinions handling for following up. If necessary, such opinions can be made via “Contact Us” as stated in the BOC Life 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 BOC Life. 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 BOC Life.
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@boclife.com.hk
To the Chairman of the Audit Committee of BOC Life
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: bocgl_acchairman@boclife.com.hk
Anonymous Reporting
The Company 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 Company encourages whistleblowers to report in good faith. The Company 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 Company 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 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 and legitimate rights / interests of the whistleblowers and the parties being reported against. There should not be 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 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 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. 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.
- 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 Policy 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 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 Company manages personal data, please refer to the Company’s Privacy Policy Statement.