Whistle Blowing Policies & Procedure



The HFC Bank Whistleblower Protection Policy is a mechanism by which HFC bank employees may voice serious concerns or escalate serious matters on a confidential basis, without fear of reprisal, dismissal or discriminatory treatment. The policy is aligned to both HFC bank’s values and the HFC bank Employee Code of Conduct and is one of a number of policies and procedures within HFC bank to support and promote honest and ethical behaviour. The Policy is intended as a last option, when all other internal reporting avenues have been exhausted or are not available.




All HFC bank employees (including contractors and consultants) are covered by the Policy. The Policy is intended to address serious matters, including:


  • Dishonest, fraudulent, corrupt or illegal behaviour; accounting or internal control matters;
  • Audit-related matters, including non-disclosure or a failure to comply with internal or external audit processes;
  • Improper conduct or unethical behaviour; or conduct endangering health and safety.


Protection under the policy


HFC bank has a strong values-based culture that encourages openness, integrity and accountability. Under the Policy, HFC bank employees who make a complaint in good faith, and in accordance with the Policy, are protected against reprisals, being dismissed or otherwise being subject to discriminatory treatment as a result of making the complaint.


Complaint Procedures


An HFC bank employee can make a complaint under the Policy by contacting a Whistleblower Protection Officer. HFC bank’s Whistleblower Protection Officers are as follows:


  • Chairman of the Board Audit Risk Sub-Committee;
  • Manager Internal Audit; or
  • If both are unavailable, Reserve Bank of Fiji (if applicable).


Upon receiving a complaint, the Whistleblower Protection Officer through the Committee hereafter referred as Board Audit Risk Sub Committee may appoint a Whistleblower Investigations Officer to investigate the matter. Where there are allegations of criminal conduct, the Whistleblower Protection Officer will consider whether the matter should be referred directly to the police.


Investigating Procedures

It will be the task of Whistleblower Investigations Officer to assess the complaint and recommend a course of action. HFC bank will treat all disclosures made under this Policy in a confidential, sensitive and secure manner. Generally, if the complaint concerns the actions of another HFC bank employee, that person will be informed of the complaint if HFC bank considers it appropriate to do so, subject to consideration relating to the anonymity of the HFC bank employee making the compliant (if applicable).


If a Whistleblower Investigations Officer is appointed, they will submit a report on the outcome of their investigation to the Whistleblower Protection Officer and or the Committee including any recommended actions. The Whistleblower Protection Officer will then consider the recommendations of the report and if appropriate, these will be implemented through advice of the Board of HFC bank.


If the report relates to finance or audit – related matters, the Whistleblower Protection Officer will consider whether the matter should be referred to HFC bank’s Board Sub Committee, or may refer the matter to HFC bank’s external auditors. If the report relates to breaches of the law, regulations or HFC bank’s own policies, the Whistleblower Protection Officer may refer the matter to HFC banks Audit Risk Sub – Committee.



HFC bank employees, contractors or consultants who make complaints in good faith can rely on the protection afforded by the Policy. Complaints relating to:

  • Financial misconduct;
  • Accounting or internal accounting control matters; or
  • Auditing matters, including non – disclosure or a failure to comply with internal or external audit processes can be made on an anonymous basis.

In all other instances, HFC bank strongly encourages HFC bank employees to identify themselves when making a compliant to the Whistleblower Protection Officers. No action will be taken against an HFC bank employee who, in good faith, makes an allegation, which is not later confirmed by subsequent investigation. However, disciplinary action may be taken against an individual making malicious or vexatious allegations.

How to Report?

You can make a complaint under the Policy by contacting our Whistleblower Protection Officer

Phone: (679) 999 1824

E-mail: whistleblower@hfc.com.fj


Post Mail: Marked as “Confidential”
C/- Manager Internal Audit,
P. O. Box 161,
Suva, Fiji     


Hand Deliver:

Marked as “Confidential”
C/- Manager Internal Audit
HEAD OFFICE: Level 3, 371 Victoria Parade,

WhistleBlower Policy Flyer – Internal


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