Raising a Concern

HSBC is committed to fostering a culture of corporate compliance and ethical behaviour. HSBC's Global Whistleblowing Policy and program is one aspect of the bank's overall approach to prevent and detect misconduct and ensure compliance with laws and regulations. This reflects our values of standing firm for what is right and doing the right thing.

HSBC Australia has adopted a local Whistleblowing Policy to encourage and support the reporting of misconduct, unlawful activity, any improper state of affairs or matters that represent a danger to the public or financial system, in relation to HSBC Australia or its related entities, and to protect a whistleblower from any detriment or retaliation that may arise as a result of their disclosure.

In Australia, whistleblowers are afforded legislative protection by means of full confidentiality. HSBC will maintain confidentiality of whistleblower reports to the fullest extent possible. The identity of a whistleblower must not be disclosed to any other person, unless disclosure is permitted at law which includes for example, where the whistleblower provides consent; the concern is reported to ASIC, APRA, the Australian Federal Police or the Commissioner for Taxation; or the concern is raised with a lawyer for the purpose of obtaining legal advice or representation.

While you are entitled to remain anonymous, the ability for HSBC to better support you, to investigate, ask follow up questions or provide feedback will be reduced if your identity is unknown and you cannot be contacted. It may also be more difficult to put steps in place to protect you from detriment if your identity is not known.

If you do choose to disclose your identity (e.g. by including your name in the report submitted), you understand and agree that your identity will be accessible by the Global Whistleblowing Oversight Team, a team within Global Compliance, and by those who are involved in investigating your concern. There may be times when the Global Whistleblowing Oversight Team or the investigators may have to disclose your identity, for example if there is legal or regulatory requirement, or to help with the investigation.

HSBC encourages its staff and associated parties to raise concerns through their normal contacts, reporting or escalation channels. HSBC encourages its customers to raise concerns via the complaints and feedback page on HSBC Australia's public website.

Occasionally however, an individual may feel that they are unable to raise concerns through these channels. HSBC Confidential is an alternative way of raising concerns, available to all internal and external parties who wish to raise a whistleblowing concern.

Where you have reasonable grounds to suspect that the matter you are reporting concerns misconduct, unlawful activity, an improper state of affairs or matters that represent a danger to the public or financial system in relation to HSBC in Australia or overseas, you are encouraged to report the matter through HSBC Confidential and you will receive certain protections available to whistleblowers under Australian law (when raising an eligible whistleblowing report as defined in the law and described above). You should be able to raise genuine concerns without fear of reprisal. If you believe you have suffered a detriment as a result of raising a concern you should report the matter to HSBC Confidential who will arrange for an independent investigation to be undertaken.

To raise your concern via HSBC Confidential, please use one of the following methods:

1. Online Portal - Completing an online form. Please note that the online portal is hosted by NAVEX Global, an external third party.

2. Telephone - By calling our 24/7 call centres provided by NAVEX Global. The telephone number for Australia can be found by accessing the NAVEX Global online portal.

HSBC's Global Whistleblowing Oversight Team is responsible for the oversight of HSBC Confidential and the handling of cases. Every case will be acknowledged. The length of an investigation will vary depending upon the particular circumstances of each case.

All cases are logged and treated confidentially as far as we can. Your identity is only accessible by the relevant HSBC Confidential team and those who are involved in investigating your concern. We will only disclose your identity where we are required to for legal or regulatory reasons. Please note that in certain cases, it may not be possible to progress an HSBC Confidential investigation without revealing your identity. If this is the case, we will discuss this with you to get your agreement, or to consider alternative channels available to you.

Your concerns will be impartially investigated in an appropriate manner by relevant subject matter experts. We will always aim to provide feedback after the investigation where we can and where it is appropriate for us to do so. The type of feedback provided is dependent on the circumstances of the case. It should be noted that it may not be possible to provide full details of the investigation, or of any action taken as a result, to protect confidentiality, or for legal or regulatory reasons. The lead investigator is responsible for providing appropriate feedback, and for confirming this has been undertaken via the investigation report. It should be noted that it is not appropriate to advise whistleblowers of outcomes of personal conduct issues.

Before using HSBC Confidential, be aware that in accordance with the Anti-Money Laundering and Counter-Terrorist Financing Act 2010 (Cth) ("AML CTF Act"), you must not disclose information that confirms or infers HSBC has formed a suspicion about a customer or that it submitted a Suspicious Matter Report (SMR) to AUSTRAC. Doing so would constitute 'tipping off', which is an offence prohibited by section 123 of AML CTF Act and may be punishable by imprisonment and/or a fine.

As a whistleblower you will consent to your identity being disclosed if you include your name in the report submitted to HSBC Confidential. In the event that you choose not to disclose your identity, you still have a right to request positive action by HSBC in order to offer better protection during the investigation.

In raising a whistleblowing report, you consent that your data provided will be processed and handled for the purpose of investigating the report. Any personal information that is provided by you will be collected and processed in accordance with HSBC Australia's Privacy Policy, the Whistleblower Policy and as set out above.

If you are an internal party to HSBC, you can find the HSBC Australia Whistleblowing Policy in the Policies, Standards and Guidelines section of the HSBC Now Australia Intranet.

Aggregated data from concerns raised through HSBC Confidential are used in presentations and governance reports for management information purposes. Data is collected and collated securely to ensure that the identity of the person who raised the concern is always protected and anonymised. This means that where cases are used in any reports, nothing that may reveal your identity will be disclosed.