BSF Anti-Bribery & Corruption Policy
The Anti-Bribery & Corruption (ABC) policy of Banque Saudi Fransi 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.
- 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.
Scope and Applicability
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
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);
Anti-Bribery and Corruption Framework
Guiding Principles
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.
1. Zero tolerance for bribery and corruption: BSF follows a zero-tolerance target and approach when it comes to bribery and corruption. We in BSF do not, and will not, pay or receive bribes in any form or offer improper inducements to anyone for any purpose, and will not tolerate any kind/form of bribe or corrupt behaviour, from our staff members, our customers, business partners, and third parties we retain or that perform services or deliver business on the bank’s behalf. Bribery and corruption are not accepted in any form.
2. Identify, mitigate, and manage bribery and corruption risks: BSF will put in place an ABC Risk Assessment framework to identify, mitigate, and manage bribery and corruption risks through a risk-based approach. This must include the consideration and assessment of risks relating to its staff members, customers, and third parties. The bank must implement appropriate systems, controls, processes, and procedures to mitigate and manage its bribery and corruption risks identified through the bribery and corruption risk assessment.
3. Whistleblowing and reporting of ABC matters: BSF will foster a culture of speaking out to encourage people to report any suspicion of a bribery and/or corruption incident, or other concern relating to ABC, without fear of reprisal. The basis of this culture will be an independent whistleblowing program that will enable staff members, customers, and third parties to report any suspicion of a bribery and/or corruption incident, or other concerns relating to bribery and corruption.
4. Staff member due diligence: BSF through the Human Resources Group (HRG) will put in place procedures and measures to ensure background checks & screening of prospective staff members which will include any conflict of interest.
5. Third-party due diligence: BSF through its Procurement Division, will put in place procedures and measures to ensure background checks & screening of prospective third-party procurement relationships, to fully identify the individuals or entities the bank is doing business with, and to enable the bank to make a considered decision on whether to enter into or continue business relationships with the relevant individuals or entities.
6. Remedial action: It is essential to BSF’s bribery and corruption strategy that any internal control failures that contributed to a bribery or corruption incident shall be remediated as a matter of urgency, and it is the responsibility of the owner of the relevant control to inform the ABC Division of the remedial action to be taken and to implement the necessary remedial actions. Implementation of remedial actions will be followed up, monitored by the Anti-Bribery Corruption Division and overseen by the Audit Committee.
Framework Overview
BSF’s framework for the prevention of bribery and corruption is multi-faceted. The essential elements are:
- A commitment by the board and senior management to a strategy that includes the goal of prevention of bribery and corruption;
- The establishment of ABC Policy and circulation of the policy;
- The establishment of key internal control procedures within different areas of the Bank designed to identify and stop potential acts of bribery and corruption;
- The empowerment of the Compliance Group to establish the Anti-Bribery and Corruption & Whistleblowing function to oversee and guarantee a transparent and impartial investigation by the concerned investigation unit in the bank for all referred cases with potential acts of bribery and corruption reported through whistleblowing or any other channels;
- The reporting of identified acts of bribery and corruption to appropriate senior management and government authorities;
- Appropriate disciplinary action against those involved in potential bribery or corruption will be taken by the concerned departments;
- It is a regulatory requirement that the bank’s communications with NAZAHA must be conducted through SAMA, according to SAMA circular number (351000036570) dated (20/03/1435H) & circular number (391000065310) dated (09/06/1439H).
BSF Whistleblowing Policy
The Whistleblowing policy of Banque Saudi Fransi 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:
- To promote a culture of openness, accountability and integrity within the bank.
- To encourage all levels of the organization including Board of Directors, Board committee members, employees, applicants for employment, temporary staff, trainees, agency staff, contractors, sub-contractors, a supplier, other vendors, consultants, clients or any other stakeholders to report any non-compliance to laws, regulations, any actual or suspicions inappropriate conduct, malpractice or misconduct to the appropriate authorities in confidence with no fear of retribution/retaliation.
- To provide a centralized channel for reporting of all suspicious incidents.
- To protect individuals from reprisal as a result of having disclosed/reported wrongful conduct.
Policy Applicability
The Whistleblowing policy intended to enable those who become aware of wrongdoing in the bank to report their
concerns at the earliest opportunity so that the case can be properly investigated. This policy is supported by BSF’s
senior management. It applies to all BSF employees and Stakeholders, including but not limited to:
- Board members, Board and Management Committees’ members, and senior management
- Employees, temporary staff, trainees, agency staff, and consultants
- Outsourced and insourced personnel
- All suppliers or vendors, contractors, and sub-contractors
- Users of BSF’s computing facilities, emails, or internet
- Clients
Legal Protection from Harassment and Victimization to the
Whistleblower
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.
Confidentiality of Whistleblower information
Reported allegations will be treated with strict confidentiality. As such, to the extent permitted by law and regulation,
the Board of Directors and/or the authorized person(s) must treat the details of all whistleblowers in confidence and will
do their best not to reveal identities. However, it must be appreciated that the investigation process requires revealing the
source of the report, in the event of such information is critical for the investigation to continue. However, revealing the
identity of the whistleblower must be on a need-to-know basis
Anonymous Reporting
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.
Whistleblowing Reporting Process
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
Reporting
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;
- The Whistleblowing portal, which is available on the official BSF website. https://register.alfransi.com.sa/WBSCF/en/Home
- Whistle blower Voice Mail (011) 289-1133
- Postal address: Banque Saudi Fransi, 7569 Al Madhar - Al Murabba, Unit No. 2, Riyadh 12624 - 2722
Bank employees can report incidents directly to the Anti-Bribery & Corruption and Whistleblowing Division of the Compliance
Group through the following channels:
- Calling the independent Whistleblowers Hot-line (011) 289-1133 (available24/7);
- Using the Whistleblowing hyperlink on BSF Intranet page;
- Emailing the Whistleblowers Helpline WBHelpline@alfransi.com.sa
- Whistleblower Voice Mail (011) 289-1133
- Postal address: Banque Saudi Fransi, 7569 Al Madhar - Al Murabba, Unit No. 2, Riyadh 12624 - 2722
Communication and Training
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.
