The Bank supports a whistleblower program, an important mechanism for preventing and detecting fraud or misconduct, and for enabling fast and coordinated incident responses. The Bank remains committed to fostering and maintaining an environment of utmost confidentiality where all personnel can act appropriately without fear of reprisal and be treated with utmost confidentiality.
Under this policy, it is the responsibility of all personnel, including the Board, officers and employees, to comply with the rules and regulations of the BPI group, and to report violations or suspected violations of this policy. Anybody who knowingly aids, abets, conceals or deliberately permits the commission of any irregular or fraudulent act directed against the group shall be considered as guilty as the principal perpetrators of the fraud or irregularity. Hence, all personnel, including the Board, officers and employees of the group, are obliged to cooperate with investigations initiated under the policy.
The policy also presumes that the employees of the group act in good faith and will not make any false accusations when reporting the wrongdoing done by another employee. An employee who knowingly or recklessly makes statements or disclosures that are not in good faith shall be subject to disciplinary action, which may include termination.
Procedure for Reporting
The Board, including all officers and employees, as well as customers, suppliers, and all stakeholders, can report any violation of policies, procedures and applicable laws and regulations which include, but are not limited to, the following: fraud, sexual harassment, theft, stealing, conflict of interest, information security violation, violation of bank policies, rules and regulations, and any other acts which are inimical to the interests of the BPI group.
The whistleblower may approach any of the following officers who are the designated contacts for the Bank and the primary reporting line: head of the Human Resources Management Group, Chief Internal Auditor, and Chief Risk Officer.
Under extraordinary circumstances, the whistleblower may also course the complaint through other reporting lines, like the President or the Chairman of the Bank’s Audit Committee.
The whistleblower may send or communicate a report, formally or anonymously, through a face-to-face meeting with the primary contacts or communicate in writing, by telephone, in person, or through the external email email@example.com or the internal e-mail BPI Eye Report Box.
Upon receipt of the whistleblowing report, the personnel to whom the report was disclosed shall immediately initiate the investigation by turning over the details, documents, if any, of the reported case to the investigating unit of the Bank.
The investigation of the whistleblowing report shall follow the due process as stipulated in the Bank’s manual of operations on standards in handling fraud and irregularities.
An individual who makes a “protected disclosure” shall not suffer harassment, retaliation, or adverse employment consequences. Any person who retaliates against any individual who makes a protected disclosure shall be subject to discipline, including termination.
The right of a whistleblower to protection against retaliation does not include immunity for his or her wrongdoing or participation in the reported irregularity, should such participation be eventually verified and proven during the course of the investigation.
In case the whistleblower believes he has been subjected to retaliation, he may seek redress or file a formal complaint to the head of the Human Resources Management Group, Chief Internal Auditor, or the Chief Risk Officer.
In 2018, BPI received a total of 34 reports through its BPI Eye Report Box, all of which have been fully resolved. The nature of the reports included customer issues (47%), queries (32%), administrative matters (15%), external fraud (3%), and operational lapses (3%).
The Whistleblower Policy is disclosed in the Manual on Corporate Governance or can also be viewed here.