HSBC Whistleblowing Arrangements in Ireland


HSBC's ‘Speak-up’ culture, as part of the Conduct Framework, encourages our people to raise concerns in confidence without fear of any form of retaliation through our HSBC Confidential Whistleblowing Channel. As well as employees, HSBC also welcomes concerns raised by any Eligible Person.

Who is an Eligible Person who can raise a concern using HSBC Ireland Whistleblowing arrangements?

You can raise a whistleblowing concern to HSBC if you are:

(Internal to HSBC)

  • an HSBC employee
  • an intern of HSBC
  • a volunteer at HSBC
  • a leader at HSBC
  • a member of the administrative, management or supervisory body of any HSBC entity in Ireland

(External to HSBC)

  • an ex-employee, as long as the information you report was collected when you worked at HSBC
  • being hired, as long as the information you report was collected during your hiring
  • a shareholder or HSBC partner
  • an external or occasional collaborator with HSBC, such as a consultant
  • a supplier to HSBC
  • a subcontractor or co-contractor
  • someone with general meeting voting rights

Scope of the Whistleblowing arrangement

The Whistleblowing arrangements allows you to raise concerns about:

  • Criminal offences,
  • Failure to comply with legal obligations,
  • Breaches of certain European Union law covering matters such as public procurement, protection of the environment and protection of privacy and personal data, and security of network and information systems.
  • Endangering the health and safety of individuals
  • Damaging the environment
  • Miscarriage of justice
  • Misuse of public funds
  • Oppressive, discriminatory, grossly negligent, or grossly mismanaged acts or omissions
  • Concealment or destruction of information about any of the above wrongdoing or any attempt to conceal or destroy such information.

To illustrate, the whistleblowing concerns, may include, but are not limited to:

  • inappropriate personal behavior
  • market abuse
  • mistreatment of a client
  • fraud
  • theft
  • corruption
  • non-compliance with competition law
  • creating a dangerous working environment
  • intimidation and harassment
  • discrimination and concealment of facts or misconducts

If HSBC Confidential is not the most appropriate channel to deal with your report, we may discuss the matter with you and redirect your concern to an alternative channel.

Investigations
Reported concerns will be subject to internal investigation conducted by independent and competent experts. At the end of the investigation, we will provide you with as much feedback as we can about the outcome of the case.

Anonymity
You can raise concerns anonymously, but we encourage you to provide contact details to help us complete our investigation more easily and thoroughly.

Confidentiality
All cases are logged and treated confidentially, with your identity 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.
Information that could identify you will only be disclosed with your permission, unless we are legally required to share such information in case of legal proceedings.
Sometimes, it may not be possible for us to conduct our investigation without revealing your identity. If this is the case, we will discuss it with you and make sure you agree before moving forward.

Protection
You can always raise a whistleblowing concern safely, without fear of retaliation. To receive protection under Irish legislation, whistleblowing concerns must meet the criteria defined by law, be raised in good faith and without direct financial compensation.

Data protection
The HSBC Confidential Whistleblowing Channel complies with the provisions of the EU General Data Protection Regulations (GDPR).

How to raise a Whistleblowing Concern?

If you are an Eligible Person Internal to HSBC, you can report your concerns through HSBC Confidential in 3 ways:

1. By Completing an online form.
To avoid any compatibility issues, please use a Microsoft Edge or Google Chrome internet browser when submitting your report. If you want to remain anonymous you can provide an email address, which will be encrypted and it will not be disclosed to HSBC. Encrypted email addresses will be used to facilitate communication between the Whistleblower and HSBC.

2. By Phone through our 24/7 Line.
If you make your report orally, during the call you can ask for a video or physical meeting. It must take place within a reasonable time after we receive your request.

Please note that the above 2 methods for raising concerns are hosted by NAVEX Global, an external third party.

3. Directly to our Whistleblowing Local Designated Person, using the following email address: colin.babe@hsbc.com
If you are an Eligible Person External to HSBC, please report your concerns directly to our our local Whistleblowing Responsible Officer, using the following email address: colin.babe@hsbc.com

For Eligible Persons both Internal and External to HSBC, we encourage you to use our internal whistleblowing channels before going to any external channels set up by public authorities. However, you are not precluded from using an external channel first.

Personal Data
However, if you choose to raise your concerns with us, the information we collect will be kept confidential at all times. To see how we process your personal data through HSBC Confidential, check the HSBC Continental Europe Ireland Privacy Notice (Data Privacy | HSBC Ireland).  This Privacy Notice applies to all personal data processed by entities of the HSBC Group acting as data controllers. It explains how we use this data, who we share it with and what steps we take to ensure its confidentiality and security.

How to raise a concern?

You can alert us in 2 ways:

1. Online
Complete our Online form via this link EthicsPoint.
This is hosted by NAVEX Global, an external third party. To avoid any compatibility issues, please use a Microsoft Edge or Google Chrome internet browser when submitting your report.

2. By phone 1800 903 307. This service is also provided by NAVEX Global.
If you make your report orally, you can ask for a video or physical meeting. It must take place no later than 20 working days after we receive your request.

However, if you choose to raise your concerns with us, the information we collect will be kept confidential at all times.

We always encourage our people to use our internal channels before going to any external channels.

In any event, whistle-blowers will not lose the protection they enjoy if they decide to use external channels according to the applicable regulation.