Whistleblowing Policy and Procedure
1. Objective
The Company is committed to ensure its business and operations are conducted in an ethical, moral and legal manner. In line with this commitment, the Company is implementing the Whistleblowing Policy and Procedure (WBP) to provide an avenue for all staff, interns, consultants, contractors, vendors, suppliers and/or customers to disclose any alleged illegal, unethical, questionable practices or improper conduct committed or about to be committed within the Company. The disclosure shall be treated in strict confidence and without risk of reprisal.
2. Scope of Reporting
Any irregular and improper conduct, including but NOT limited to the following:
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- Fraud or Dishonesty
- Theft or Embezzlement
- Bribery, Corruption
- Sexual Harassment
- Abuse of Power
- Breach of Applicable Law and Regulations, Including Any Illegal Activities (including but not limited to Money Laundering and Terrorism Financing Activities)
- Breach of Group/Company's Policies and Procedures
- Insider Trading
- Conflict of Interest
- Improper Use or Falsification of Management and Financial Information
- Misuse of Company's Property and Information
- Bullying, Intimidation, Harassment
- Gross Mismanagement or Dereliction of Duties
3. Reporting Procedure
3.1 To report any irregularity/misconduct committed or about to be committed (including any criminal act), the Whistleblower is encouraged to provide the relevant details in the web form when the user clicks on the PBALERT Link (see below item 4.1) or send an Email to PBALERT@campubank.com.kh.
3.2 The Whistleblower is responsible for ensuring that the disclosure is made in good faith, free from malicious intent, and is not for personal gains or with a vested interest. This is also not a channel for taking up any personal grievances.
3.3 Disclosures are expected to be made on reasonable grounds. However, reports made that are frivolous, not true, misleading, or made mala fide or with malicious intent may result in disciplinary or other action.
4. Reporting Channels
4.1 Disclosure via the PBALERT Link (click here). A web form will be populated once the link is invoked for the Whistleblower to insert relevant details.
4.2 Disclosure via Protected Email Address at:PBALERT@campusecurities.com.kh
4.3 The above is secured and protected channels accessible only by authorised personnel.
4.4 The Company at its discretion, may keep the Whistleblower informed of the outcome of any investigation within the constraints of maintaining confidentiality or observation of legal restrictions.
5. Protection Accorded to Whistleblower(s)
5.1 The Company encourages the Whistleblower to disclose his/her identity to enable him/her to be accorded the necessary protection and to facilitate investigation. Nevertheless, the Whistleblower may choose to remain anonymous, although, in certain circumstances, it may limit the conduct of a comprehensive investigation due to insufficient information.
5.2 The Company will accord protection of confidentiality to the Whistleblower to the extent reasonably consistent with the need to conduct an adequate investigation.
5.3 The Company 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 supervision.
6. Withdrawal of Disclosureower(s)
The Whistleblower who wishes to withdraw his/her disclosure is required to write to PBALERT@campusecurities.com.kh together with supporting reason(s) for the withdrawal. Notwithstanding such withdrawal, the Company reserves the right to proceed with an investigation on the matters arising from the disclosure.
7. Other Reporting Channels
The Whistleblower may also lodge a report with the police, the Securities and Exchange Regulator of Cambodia (SERC), the Anti-Corruption Unit (ACU), or/and any other enforcement agencies and forward a copy of the said report to the Company to enable the Company to conduct its internal investigations.