This policy is designed to enable all employees of the Society and related third parties to raise concerns, in confidence, about actual or suspected wrongdoing involving the activities of the Society. Examples of misconduct within the scope of this policy are set out in “Misconduct, malpractice and irregularities” section below.

 
This policy is not intended to replace the staff complaints policy in Staff Handbook covering complaints by staff members.

Persons making appropriate reports in good faith under this policy will be supported and protected by the Society, even if the concerns raised turn out to be unsubstantiated.

 
Any staff member who victimizes or retaliates against those who have raised concerns under this policy will be subject to disciplinary actions. 

All employees and other related parties are encouraged to take the initiative to disclose any actual or suspected misconduct relating to the Society which come to their notice. If there are questions about the contents or application of this policy in specific circumstances, staff of the Risk Management, Compliance and Internal Audit Department, at email address enquiry_RMD@hkspc.org, can provide the necessary guidance.

A report should be made in writing and be addressed to the Audit and Risk Management Director, and be sent by email (to whistleblowing@hkspc.org) or sent by post marked “strictly confidential” to “Audit and Risk Management Director, G/F, 387 Portland Street, Mong Kok, Kowloon”. It may (but need not) be made using the standard report form below. The report, should include full details of the concern, including the personnel involved and the reasons for the concerns as well as any supporting evidence, if applicable.

 
Any report which the Society concludes is made maliciously or in bad faith may result in disciplinary or other appropriate action being taken against the whistleblower. 

The following activities are considered to be a non-exhaustive list of possible misconduct that should be reported under this policy: 

• any illegal activity (e.g. fraud);
• any breaches of legal or regulatory requirements;
• any breaches of conduct or internal control requirements;
• any physical or mental abuse, mistreatment and bullying of someone;
• any financial mismanagement, including misappropriation of assets and false financial reporting;
• any actual or attempted bribery or corruption;
• any action that results in a potential danger to someone’s health or safety;
• any other improper or unethical behavior, and
• any deliberate concealment of information concerning any of the matters listed above.  

The Society will make every effort to keep the whistleblower’s identity confidential. The whistleblower must keep the fact that he or she has filed a report, the nature of concerns and the identity of the personnel involved confidential to the extent possible.

 
The Society will not tolerate any act of “tip off” which means any person knowing or suspecting that a concern has been raised under this policy, discloses to any other person any information which will likely prejudice the investigation. The person who discloses such information will be subjected to disciplinary actions.

 
There may be situations in which, because of the nature of the investigation, it will be necessary to disclose the whistleblower’s identity including to any law enforcement authorities such as ICAC and the Hong Kong Police, in which case the Society will inform the whistleblower that his or her identity is likely to be disclosed. 

Although the Society will handle all reports, it encourages persons to put their name on any report. A failure to disclose the identity of the person making the report will materially hinder any follow up or investigation by the Society.