The Anti-Bribery & Corruption (ABC) policy of BSF is intended to establish the framework for preventing bribery and corruption across bank’s operations /businesses. The policy’s purpose is:
To ensure that the Bank has established and is applying a comprehensive mechanism to combat bribery and corruption;
To set the roles and responsibilities of different stakeholders in terms of combatting bribery and corruption and ensure that it is subject to appropriate oversight and respective roles and responsibilities are communicated to the stakeholders across the Bank;
Establish an appropriate control environment for reporting of any potential bribery and corruption activity, which may impact or involve the Bank; and
Guide staff members on the Bank’s commitment against bribery and corrupt practices and to assist staff members in preventive measures concerning combating bribery and corrupt practices.
The ABC policy is applicable across all businesses and operations of BSF. The policy applies to the Board of Directors (BOD), Board Committees, Senior management, officers, staff members, outsourced / insourced staff, contractors, vendors, and consultants. This policy is supported by BSF’s senior management.
Anti-Bribery and Corruption Governance The ABC policy describes roles and responsibilities of the related stakeholders in relation to oversight, monitoring and implementation of the ABC Policy. Key stakeholders of ABC governance mechanism include Board of Directors, Board Audit Committee, MD & CEO, Compliance, Legal & Governance, Human Resource functions, Procurement Division, Anti-Fraud Management Division, and All Groups/ Divisions/ Departments/ Units/ Staff Members and Subsidiaries. Compliance function identifies existing and potential needs for anti-bribery and corruption awareness training and coordination with Human Resource Group to create and deliver the necessary training to staff members (including outsourced/ insourced staff);
BSF shall not participate in acts of corruption or pay or receive bribes, either directly or indirectly (e.g. through agents or introducers). Furthermore, the Bank prohibits the staff members and any members of third-party vendors, consultants, suppliers, etc. from engaging in acts of corruption and from paying or receiving bribes from public or private officials or entities, whether directly or indirectly. BSF commits to prevent all forms of corruption and conflict of interest including but not limited to: facilitation payments, gifts/invitations, extortion, fraud, embezzlement, money laundering, conflict of interest, illegal financing of political parties. Following the above, it is BSF policy to ensure that it has taken all reasonable steps to prevent and control any bribery or corruption acts involving the Bank or staff members or third parties by implementing processes and procedures that create a protective culture and environment in which bribery and corruption risks can be identified and mitigated. The following are BSF principles for Anti-Bribery and Corruption and are aligned with the OECD guidelines for anti-corruption and integrity.
BSF’s framework for the prevention of bribery and corruption is multi-faceted. The essential elements are:
The Whistleblowing policy of BSF provides a high-level strategy of BSF in dealing with Whistleblowing
incidents. It is intended to ensure that all employees (BSF staff as well as outsourced and insourced personnel)
and stakeholders feel supported in speaking up in confidence and reporting suspected matters such as unethical behavior
or inappropriate conduct within the bank.
The key objectives of Whistleblowing Policy are:
The Board of Directors will not tolerate harassment or victimization and will make every effort to protect employees and other
stakeholders and ensure that the reporting party shall not suffer any adverse repercussions as a result of making disclosure in
good faith.
Where feasible, the employee or the reporting party (who chooses to disclose his/her identity) will be contacted when their
concern has been investigated to ascertain whether they have suffered any detriment as a result of their whistleblowing.
If at any time, either during or after the investigation, an employee or any reporting party feels that they have suffered any
detriment as a result of whistleblowing, they should directly contact BSF Anti-Bribery & Corruption Head.
The allegation must be investigated and reported to the Senior management. The report shall be escalated to the related
board committee if necessary.
Reports can be made anonymously. However, BSF encourages employees and stakeholders to put their name to allegations, as concerns expressed anonymously are often much more difficult to investigate.
Bank’s employees and other stakeholders are encouraged to express their concerns as early as possible, as this will make it easier to act. BSF aims to encourage transparency and will support and protect anyone who reports a genuine concern in good faith under this policy, even if it turns out to be mistaken. A whistleblower needs no approval nor permission of any kind and can directly report an incident or concern
BSF Management strongly encourages all BSF employees and other stakeholders to report all actual or
possible ethical issues, violations of rules, regulations and institutional policies; in good faith
and prohibits any retaliatory action against any individual or party for reporting legitimate concerns or
questions regarding ethical matters or for reporting actual or suspected violations
Prompt reporting of a violation can substantially reduce the adverse consequences of the violation for all
involved parties e.g. the bank, the whistleblower, and third parties. All type of incidents may be reported as follows
For external parties such as; Service Providers, Vendors, Customers, Shareholders and any other person who has
legitimate concerns over any wrongdoing within the Bank, they are encouraged to come forward and voice those concerns
through;
Bank employees can report incidents directly to the Anti-Bribery & Corruption and Whistleblowing Division of the Compliance Group through the following channels:
BSF Compliance Group coordinates with the Human Resources Group to ensure that all employees are aware of the whistleblowing process. This is achieved through the annual regular compulsory training and awareness programs conducted by Human Resource and Compliance Group through presentations, newsletters, e-mails and circulars and awareness materials for all employees and staff in the bank.
