WHISTLEBLOWING POLICY AND PROCEDURES

1. OBJECTIVE
  The Bank is committed to ensure its business and operations are conducted in an ethical, moral and legal manner. In line with this commitment, the Bank is implementing the 'Whistleblowing Policy and Procedures' (WBP) to provide an avenue for staff, interns, consultants, contractors, vendors, suppliers and/or customers to disclose any illegal, unethical, questionable practices or improper conduct committed or about to be committed within the Bank. The complaints shall be treated in strict confidence and without risk of reprisal.
2. SCOPE OF REPORTING
 

Any irregularity and improper conduct, including but NOT limited to the following:

• Fraud or Dishonesty
• Breaches of Policies, Procedures and applicable Laws and Regulations
• Bribery, Corruption
• Abuse of Power
• Conflict of Interest
• Theft or Embezzlement
• Insider Trading
• Misuse of Bank's Property and Information
• Harassment, Sexual Harassment and/or
• Intimidation

3. REPORTING PROCEDURES
  3.1 To report any irregularity/misconduct committed or about to be committed (including any criminal offence), a whistleblower is required to provide the relevant details in a format as attached (CLICK HERE) via email to PBALERT@campubank.com.kh.
  3.2 The whistleblower is responsible to ensure that the disclosure is made in good faith, free form malicious intent, and is not for personal gains.
  3.3 This procedure strictly prohibits frivolous, vexatious, mala-fide, bogus disclosure for personal gain or with personal agenda.
  3.4 If the subsequent investigation reveals that the disclosure was made with malicious intent, appropriate action can be taken against the whistleblower.
4. REPORTING CHANNEL
  Disclosure via Protected Email Address at: PBALERT@campubank.com.kh
The above secured channel is accessible by authorized personnel only.
5. PROTECTION ACCORDED TO WHISTLEBLOWER
  5.1 The Bank will accord protection of confidentiality to the whistleblower to the extent reasonably consistent with the need to conduct an adequate investigation.
  5.2 The Bank will take all reasonable steps to protect the whistleblower against any discrimination, retaliation or harassment, corresponding to its internal policies and scope under its purview and jurisdiction.
6. WITHDRAWAL OF DISCLOSURE
  A whistleblower who wishes to withdraw his/her disclosure is required to send an email to PBALERT@campubank.com.kh together with supporting reason(s) if any for the withdrawal. Notwithstanding such withdrawal, the Bank reserves the right to proceed with investigation on the matters arising from the disclosure.
7. OTHER REPORTING CHANNEL
  A whistleblower may also lodge a report with the police, the National Bank of Cambodia (NBC), Anti-Corruption Unit (ACU) or any other enforcement agency and forward a copy of the said report to the Bank to enable the Bank to conduct its own internal investigations.