HSBC Whistleblowing Arrangements in Italy

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 Italy 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 Italy

(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:

  • breaches within the scope of the Italian Law 231/2001,
  • breaches of the systems and Law 231/2001 Compliance Program;
  • breaches within the scope of the European Union or national acts listed in the Annex to the aw 24/2023 or of the national acts constituting implementation of the European Union acts indicated in the Annex to the European Whistleblowing Directive, although not listed in the Annex to the Italian Whistleblowing Decree, relating to the following areas: (i) public procurement, (ii) financial services, products and markets and prevention of money laundering and terrorist financing, (iii) product safety and compliance, (iv) transport safety, (v) protection of the environment, (vi) radiation protection and nuclear (vii) food and feed safety, animal health and welfare, (viii) public health, (ix) consumer protection and (x) protection of privacy and personal data and security of network and information system;
  • breaches relating to fraud or any other illegal activities affecting the financial interests of the EU and;
  • breaches relating to the internal market, as referred to in Art. 26 (2) TFEU (free movement of goods, persons, services, and capital) including infringements of competition law rules, state aid rules and corporate tax rules.

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 the external channel 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 Italian 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.

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 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 Italy Privacy Notice. 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 This link will open in a new window.
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 800 909 794. 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 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.