An Alternative Channel

A channel through which Whistleblowers can report a Concern Anonymously or by disclosing his/her identity.

Anonymity / Anonymous

Anonymity relates to the identity of the Whistleblower. A Whistleblower is Anonymous when any Employee, including Authorized Persons, within the organization, does not know his /her identity.

Authorized Persons

Authorized Persons are persons who are strictly necessary for the handling and/or investigation of the Whistleblower’s Concern. The Reporting Officer, in consultation with BARCC, determines the persons who are/become Authorized Person on a case-by-case basis, with special consideration given to potential conflicts of interest and Confidentiality. On a strict ´need to know´ basis, Authorized Persons (could) include:

  • Internal Audit
  • CEO
  • CRO
  • Human Resources Director
  • Head of Legal & Compliance
  • Representatives of
  1. Human Resources department;
  2. Security & Information Technology.
  3. Risk Management including Operational Risk.
  • External consultants (e.g. lawyers).
  • CEO

The first Line of Defense who is the ultimate business responsible at his/her level of the organization,

Confidential/ Confidentiality

Confidential/Confidentiality refers to the non-disclosure of certain information such as the identity of the Whistleblower, the content of the Concern as well as any other details related to the Concern and any Investigation of the Concern. This also includes any information that relates to the identity of the Whistleblower.


A report raised by a Whistleblower about an actual or suspected irregularity or misconduct within EDB that leads or could lead to a violation of:

  • EDB Business Principles; and/or
  • Any EDB Policy; and/or,
  • Any law or regulation.

Unless a specific procedure has been established for certain complaints (for example certain types of labor law matters or personal grievances), in which case the relevant procedure must be followed.


Any person employed by, outsourced to, or seconded to EDB.

Good Faith

A Concern is reported in Good Faith when the Concern is not raised maliciously and when it is based on reasonable facts and/or circumstances that allow for the assumption that the Concern is sufficiently grounded.

Full Investigation

The investigation following the Preliminary Investigation conducted in accordance with the EDB Policy (if any).


Preliminary Investigation and/or Full Investigation.

Preliminary Investigation

An inquiry to determine:

  • Whether the reported Concern is within the scope of this Policy; and, if so,
  • Whether there are reasonable facts and/or circumstances to start a Full Investigation in order to confirm or reject the Concern.

Reporting Officer

Chief Internal Auditor who has been appointed to manage Whistleblower cases confidentially by:

  • Receiving Concerns from and communicating with (potential) Whistleblowers;
  • Conducting a Preliminary Investigation; and
  • Providing information to the BARCC and other Authorized Persons on a strict ´need to know´ basis.


Retaliation is any adverse action taken against a Whistleblower as a result of reporting the Concern or taken against any other Employee who provides information, who causes information to be provided, or who otherwise assists in an Investigation.

Examples of such adverse actions could include, but are not limited to, harassing, threatening, firing or demoting, reducing benefits, transferring to another part of the organization, changing working hours or office location or changing responsibilities.


Any staff member, customer, person/party providing EDB with services, consultants and other party dealing with EDB who reports a Concern in accordance with this guidelines.






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