Dear Whistleblower!

In accordance with the provisions of the Law on whistleblowers No. 165 of 22.06.2023, the employee has the right to make disclosures regarding violations of the law and to be recognized as a whistleblower.

BC “Moldindconbank” S.A. (hereinafter referred to as the Bank) treats with care and seriousness all reports of problems that may involve violations of the law.

Please find below the disclosure channels, but before, please make sure that you know who and what kind of information you can submit.

Employee – an individual who, in the last 12 months, has or has had a relationship with the Bank:

  • as an employee undert he labour law;
  • as a volunteer or trainee;
  • contractual, civil legal relations;
  • as a candidate for a vacant position, participating in a job competition;
  • as a beneficiary of social services;
  • as a shareholder, former or current member of the Bank’s management or supervisory body.

Whistleblowing (reporting) – the disclosure of information obtained in a professional context concerning violations of the law that threaten or prejudice a person’s rights or interests protected by law.

Information relating to breach of law – information, including reasonable suspicion, relating to actual or potential breaches of the law which have occurred or are likely to occur within the Bank in which the employee works or has worked or with which the employee is or has been in contact through his or her work, and information relating to attempts to conceal such breaches.

Breach of law – action or inaction of non-compliance with legal provisions, which seriously or essentially violates the rights of the person or interests protected by law, which has occurred or is likely to occur within the Bank in the areas of: services, products, prevention of money laundering and terrorist financing, preventing and combating corruption, product safety and compliance, environmental protection, consumer protection, protection of privacy and personal data, security of networks and information systems, etc.

Regardless of the channel used, the disclosure must include at least the following information:

  • name, surname and contact details;
  • place of work, subdivision, position held;
  • professional context in which the information was obtained;
  • data subject, if known;
  • description of the fact likely to constitute a violation of the law, if applicable, evidence in support of the report;
  • data and signature.

By exception, disclosures that do not include the name, surname, contact details or signature of the employee making the disclosure shall be reviewed and resolved to the extent that they contain reasonable suspicion of threats to national security and public order.

Disclosure can be made through the following internal reporting channels:

  • by filling in and signing the Internal Disclosure Questionnaire form available here and sending it by:
    a)e-mail, to the alerta@micb.md;
    b) mail, to the mailbox located in the Bank’s Headquarters, 1st floor, at the address – Chisinau, 38 Armeneasca st.
  • by requesting a face-to-face meeting with the designated person at the Bank’s Headquarters (Chisinau, 38 Armeneasca st.). The appointment of a face-to-face meeting shall be made by sending a message to the e-mail address alerta@micb.md, indicating: name and surname, proposed date and time, contact details.

The Bank receives, records, reviews and resolves internal disclosures of breaches of law through its designated subdivisions: the Compliance Department and the Internal Audit Department, if the disclosure concerns members of the Bank’s Managing Board and employees of the Compliance Department.

The disclosure ceases to be examined when it meets the conditions laid down in Article 16 of the Law no.165 of 22.06.2023 on whistleblowers.

If the disclosure exceeds the Bank’s competence, it shall be transmitted for examination to other public entities, according to their competences, while respecting confidentiality.

The Bank shall take care to protect the identity of whistleblowers, any third party named in the report and the confidentiality of such report, within the limits defined by applicable laws and regulations.

If you consider that the whistleblowing cannot be reported through the channels provided by the Bank, you are entitled to use the reporting channels of the competent authorities, as defined in the Law no.165 of 22.06.2023 on whistleblowers.

Regardless of how you decide to communicate with the Bank, we will retrieve your messages and act to correct/clarify the issues raised.