1. Introduction
UBBfh Bank is dedicated to maintaining the highest standards of ethical conduct, transparency and accountability. We recognise that a robust whistleblowing framework is essential for identifying and addressing misconduct, unethical practices and regulatory breaches. This statement outlines the procedures for reporting concerns and the protections afforded to whistleblowers in accordance with best practices and applicable legal requirements.
2. Scope and Purpose
2.1 Scope
This statement applies to all employees, contractors, suppliers, and stakeholders associated with UBBfh Bank. It covers concerns related to, but not limited to:
Financial irregularities and fraud Breaches of regulatory or legal obligations Misconduct or unethical behaviour Internal control weaknesses Cybersecurity and data protection breaches 2.2 Purpose
The purpose of this whistleblower statement is to:
Provide clear, secure and confidential channels for reporting concerns Ensure that all reports are handled impartially, with due diligence and in a timely manner Protect whistleblowers from any form of retaliation or victimisation Foster a culture of integrity, accountability and continuous improvement 3. Reporting Procedures
3.1 How to Report
Whistleblowers are encouraged to report concerns through one or more of the following channels:
Dedicated Whistleblowing Hotline: A secure and confidential telephone line accessible 24/7 for reporting concerns. [] – All email communications are encrypted to ensure confidentiality. A secure, anonymous reporting portal is available via our intranet or the dedicated URL [insert URL]. Concerns can also be reported directly to the Compliance Office or the Internal Audit team. 3.2 Information to Provide
When reporting a concern, please include as much detail as possible, such as:
The nature of the concern and relevant dates Names and roles of the individuals involved Supporting documentation or evidence (if available) Any attempts made to address the issue internally 4. Confidentiality and Anonymity
UBBfh Bank is committed to maintaining the confidentiality of all whistleblower reports. Measures include:
All reports are treated confidentially, and personal details are securely stored. Whistleblowers may choose to remain anonymous. In cases where identity is disclosed, the information will only be used for the investigation. All data provided during the reporting process is managed in accordance with data protection legislation. 5. Investigation Process
5.1 Receipt and Acknowledgement
Upon receipt of a whistleblower report, the Compliance Office will conduct an initial assessment to determine the appropriate course of action. An acknowledgement will be sent to the whistleblower (if identity is known) outlining the next steps and expected timelines. 5.2 Investigation and Resolution
Independent Investigation: A designated, independent team will conduct a thorough investigation. The process will be impartial, ensuring that all parties receive fair treatment. Findings will be documented, and remedial actions will be implemented as required. Whistleblowers will be updated on the progress of the investigation, subject to confidentiality and legal constraints. 6. Protection Against Retaliation
UBBfh Bank unequivocally prohibits any form of retaliation against individuals who report concerns in good faith. Protective measures include:
All employees, contractors and stakeholders are protected under our non-retaliation policy. Any acts of reprisal will be subject to disciplinary action. Whistleblowers are provided with access to counselling services and legal advice if required. The Compliance Office will monitor the situation to ensure that the whistleblower is not subject to any adverse consequences. 7. Review and Continuous Improvement
UBBfh Bank is committed to continuous improvement of our whistleblowing framework:
The whistleblower policy and procedures are reviewed annually to ensure effectiveness and compliance with evolving legal and regulatory requirements. Regular training sessions and awareness programmes are conducted to educate staff about the importance of whistleblowing and their rights under this policy. Feedback from whistleblowers and internal stakeholders is actively sought to enhance the system further. 8. Conclusion
UBBfh Bank values the integrity of its operations and the input of its stakeholders. Our whistleblower statement underscores our commitment to transparency, accountability and a safe, supportive work environment. We encourage all employees, contractors and associated parties to report any concerns without fear, secure in the knowledge that their disclosures will be treated with the utmost seriousness and confidentiality.
For further information or clarification on the whistleblowing process, please contact the Compliance Office at [] or via the dedicated hotline.
