Whistle Blowing Policy

(ETHICAL REPORTING)

Effective Date: 1 May 2023
Approved By: James Kuan (ED)
Document Owner: HR Dept

INTRODUCTION

The Singapore Christian Home (“SCH”) is committed to maintaining high levels of integrity, ethics, honesty, and safety in its services and operations. SCH is also committed to encouraging open communication within the organization. In line with this commitment, SCH encourages its employees and volunteers to report their concerns about any reasonable belief of wrongdoing, misconduct, and breach of policies, laws, or regulation (‘concern’) that they witness or suspect to be occurring within the organization, so that these concerns can be investigated and addressed accordingly.

Whistle blowing refers to a voluntary and deliberate disclosure by an employee or volunteer who has direct dealings with SCH, to a party appointed by SCH, of any malpractice, illegal, or unlawful conduct, or willful commissions at work, or potential irregularities in procedures within SCH. Such an act or irregularity may be likely to be committed or in the process of being committed or have already been committed.

WHO IS COVERED BY THIS POLICY

This Policy applies to all employees and volunteers of SCH.

OBJECTIVES OF THIS POLICY

To provide an avenue for all employees and volunteers of SCH to come forward to raise their concerns about any matter that may adversely impact the organization;
To enable SCH to investigate and address any reported concern at the earliest possible stage;
To develop an ethical and responsible culture at SCH, where wrongdoings, misconduct or breaches of laws and regulations will not be tolerated, risks are appropriately managed, and where openness and accountability are valued;
To enable SCH to have a structured approach to receiving and handling whistle blowing reports; and
To give employees the assurance that they will be safe from reprisals or victimization for whistleblowing in good faith.

AUTHORITY

SCH’s Board has the authority and oversight of this Policy. The Board delegates to the Audit Committee the operation and oversight of this Policy. The Audit Committee may at its discretion delegate the investigation of complaints and implementation of this Policy to any such person it deems fit.

PROTECTION AGAINST REPRISALS

SCH does not tolerate any harassment or victimization against those (the whistleblower) who raise concerns in good faith under this policy. If an employee or volunteer has raised a concern and feels that he or she is being victimized because of doing so, the employee or volunteer should advise SCH Management or SCH Board hotline regarding this issue.

All investigations arising from a whistle-blowing report will be undertaken in an objective and impartial manner.

No action will be taken against anyone who raises a concern in good faith reasonably believing it to be true, even if the employee’s or volunteer’s concern turns out to be unsubstantiated. Employees or volunteers who report their concerns will not be disciplined nor their careers affected, provided their concerns are raised in good faith.

All investigations into a whistle-blowing report will be kept confidential, as far as reasonably practical.

Employees or volunteers who have reported their concerns should refrain from discussing or disclosing information being investigated with anyone not connected to the investigation while investigations are ongoing.

SCH will fully protect the identity of the whistleblower to the fullest extent permissible by the law.

APPLICABLE CONCERNS

Examples of reportable concerns include fraudulent actions, corruption, accounting manipulation, endangerment to public health or inappropriate conduct. (Please see Appendix 1 for selected detailed examples of concerns applicable under this Policy).

NON-APPLICABLE CONCERNS

This Policy does not apply to grievances or complaints about an employee’s or volunteer’s personal matters or feelings, or disagreement with decisions taken by SCH, unless SCH’s reputation is at risk.

MECHANISMS FOR RAISING CONCERNS

Confidentiality

SCH values its employees’ or volunteers’ input in upholding the organization as an ethical, honest, and safe workplace. Therefore, employees or volunteers are encouraged to raise concerns openly with management. If an employee or volunteer asks for his/her name to be kept confidential, every effort will be made to ensure confidentiality as far as reasonably practicable.

REGULAR REVIEW OF EFFECTIVENESS OF POLICY

SCH undertakes to review the Whistle-blowing Policy periodically for relevance and effectiveness and will take into consideration any feedback to improve it.

HANDLING AND INVESTIGATING OF REPORTED CONCERNS

Acknowledgement of Reported Concerns

All APPLICABLE CONCERNS will be acknowledged upon receipt, unless the report has been made anonymously and the employee’s or volunteer’s contact details were not provided.

Acknowledgement shall be through email (if the email address had been provided) or through the channel agreed between the whistle-blower and SCH.

Processing and Investigating Reports

REPORTING ON SCH INTERNAL STAFF (WHISTLEBLOWING FLOWCHART 1)

Employees or volunteers are encouraged to raise any such concerns with the employee’s or volunteer’s direct supervisor as a first step. They may report concerns which may adversely impact the organization, to relevant Departmental Head or email to Hotline@schome.org.sg

Relevant Department Head shall raise the concerns to HR Manager.
The HR Manager shall discuss with the Executive Director on the follow-up investigation actions.

If concern is not resolved, it shall be raised up to the attention of HR Committee Chairman or to the President.

HR Manager shall follow up with HR Committee Chairman or President for the next course of actions.

REPORTING TO SCH MANAGEMENT/ PRESIDENT/ BOARD MEMBERS (WHISTLEBLOWING FLOWCHART 2)

Employees or volunteers are encouraged to raise any concerns on SCH Management staff, President or the Board Members that may adversely impact the organization to SCH Board Members via email to HotlineBoard@schome.org.sg .

HR Sub Committee Chairman shall escalate to

Audit Chairman if complaint is on SCH Management or SCH Chairman
President if complaint is on SCH Board Members

HR Sub Committee Chairman shall follow up for next course of actions with Audit Committee Chairman or the President.

The Audit Committee will ensure that investigations are carried out using the appropriate channels, resources, and expertise, and with the highest integrity.

All investigators are to handle matters in an independent, unbiased manner in fact and appearance.

UPDATE OF PROGRESS OF THE INVESTIGATION

SCH Board understands that employees or volunteers reporting concerns would be interested in the outcome of investigation into their reports but is unable to communicate feedback to those reporting anonymously.

Employees or volunteers should note that SCH Board will have to exercise discretion over what it may disclose about the investigations, findings, and outcomes, even while it appreciates the efforts made to bring up concerns to safeguard SCH.

SCHEDULE 1 – INVESTIGATION PROCESS

INFORMATION TO INCLUDE

When raising a concern, the employee or volunteer should focus on what he or she thinks is the risk to the organization and the basis for the concern. While a concern may only be an intuition, that concern is still valid, and should be reported. However, the employee should try to articulate objectively the basis for his or her intuition. Employees or volunteers should include the following information, with as much detail as possible:

Date, time, place and nature of the concern;
Identity of person(s) of interest (such as a list of names and job titles or roles within SCH, where applicable);
Details and background of the concern (such as a description of the concern, specific examples of actions that caused it, the frequency, and the basis for the concern);
Copies of any relevant documents, (such as financial statements, invoices or emails), or the location of the documents or information (such as the name of a computer folder or file name, or the physical location of the document), and
Any other relevant information.

Reports in writing may be made using the template provided in Appendix 3.

Once the employee or volunteer has reported his or her concern/s, the employee or volunteer should refrain from sharing the reported concern(s) with other parties or from taking further action, such as addressing the concern(s) on his or her own.

Appendix 1.

Examples of Events That May be Deemed a Legitimate Concern.
The typical subjects depicted in the table below contains a list of non-exhaustive examples.

Appendix 2 Do’s and Don’ts

DO'S

Raise a concern to your manager or via the channels set out in the SCH Ethical Reporting policy.

Let the facts speak for themselves - think of yourself as a witness not a complainant.

Act in good faith - all we ask is that you tell the truth.

Tell us what the risk is, so we can address it.

DON'TS

Keep a concern to yourself, if in doubt, raise it.

Raise grievances through the whistleblowing channel - there's a grievance policy for that.

Try to be a private investigator, raise the concern through the proper channels so we can investigate for you.

Forget to at least give contact details - if we can't contact you, we can't ask for more information or give you.