INTRODUCTION
1. The Singapore Red Cross Society (SRC) is committed to the highest standards of honesty, transparency, ethical and legal conduct and accountability. In this regard the SRC is committed to a high standard of compliance with accounting, financial reporting, internal controls, corporate governance and auditing requirements and any legislation relating thereto.
AIM
2. In line with this commitment, we provide this avenue for parties to raise concerns regarding malpractice, statutory noncompliance, actual or suspected improprieties in financial transactions and any other wrongdoing.
SCOPE
3. The issues which may be raised covers such following wrongdoings, although not limited to these:
- Fraudulent activities/transactions
- Personal and profession misconduct
- Unauthorised access to and/or disclosure of information
- Embezzlement, misappropriation, theft, or criminal misuse of Society’s monies and resources
- Corruption, bribery, cheating
- Aiding and abetting illegal activities
4. Whistleblowing enables staff, registered members and volunteers of SRC to raise serious and genuine concerns within the Society.
PROTECTION FOR THE WHISTLE BLOWER
5. The whistle blower will be provided with protection from reprisals or victimisation for whistle blowing in good faith. This is carried out to deter wrongdoing and help to promote standards of good financial practice and corporate governance.
6. The Society recognises that the decision to report a concern can be a difficult one to make, not least, because of the fear of reprisal from those responsible for the alleged malpractice. The Society will not tolerate harassment or victimisation and will take action to protect anyone who raises a concern in good faith, even if the concern is later proved to be unsubstantiated. However, the Society will reserve its right to take action against those who give false or misleading information.
APPLICATION
7 This Policy applies to both staff and/or external parties. Staff shall include anyone who is on the payroll of the Society, whether he/she is on permanent, contract, temporary, parttime or other types of employment with the Society. External parties shall include registered members and volunteers of the Society, individual and corporate donors (in cash, in kind, of blood), beneficiaries, individuals or organisations with a business dealing with the Society.
MISUSE OF THE PROCESS
8. The Policy is not meant as a channel for personal or normal HR grievances, which can be taken up through the Society’s grievance handling procedure. Frivolous, unsubstantiated, or unsubstantial claims / complaints will not be considered. The Society does not condone abuse of the Policy for personal gains, or with malicious intent.
PROCEDURE
9. The whistleblower can raise his/her concern through the following channels:
Chairman, Corporate Governance and Nominations Committee, SRC Accountability Office.
Email: chairmanwhistleblower@gmail.com
To ensure confidentiality, the email should be titled “Strictly Private and Confidential To be opened by Addressee Only”
10. Without prejudice to Para 11a and Para 11b; to encourage transparency and accountability, the Policy encourages the whistleblower identify himself/herself. To protect the whistleblower, the Society will handle confidentially the whistleblower’s identity and the information he/she provides. The whistleblower is required under this Policy to put in writing (or to sign against) the information that he/she is providing for the case.
11a. Subject to Para 11b, if a complaint received is anonymous, Chairman, CGNC, will assess it based on the merits of the complaint, its nature and whether the complaint can be verified. If the complaint can be pursued, the same procedures will follow; accept that the whistleblower will not be informed of the outcome of the case.
11b. Except under the most exceptional circumstances, anonymous complaints will not be entertained.
12. Exceptional circumstances under which information provided by the whistleblower could or would not be treated with strictest confidentiality include:
- Where the Society is under a legal obligation to disclose information provided
- Where the information is already in the public domain
- Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice
- Where the information is given to the Police or other authorities for criminal investigation
INQUIRY PANEL
13. On receiving a complaint the Chairman of the CGNC, in consultation with the CGNC, shall decide on the gravity and authenticity of the complaint. If the CGNC is convinced that there is an issue to be looked into, the Chairman of the CGNC shall appoint an Inquiry Panel (“IP”) comprising at least three independent members (i.e. persons not connected to the complaint). Wherever possible, the members will be appointed from amongst the staff and members of the Singapore Red Cross Society.
14. The IP which will study the information provided, and submit a written report (“Report”) to CGNC. The CGNC will study the Report and forward its recommendations to Chairman SRC, and if deemed necessary, to the SRC Council, for a final decision. Should the complaint involve the Secretary General, the members of the CGNC may comprise the IP themselves and refer their findings to the Chairman, SRC and the SRCCouncil. Once an IP has been instituted, Chairman, CGNC shall keep Chairman, SRC informed.
15. Person(s) implicated in a whistleblowing case will NOT be part of the IP. In the event that the implicated person(s) is/are the Secretary General and/or the members of the CGNC and /or the Chairman of the Society, the case could be outsourced to an external party, including the relevant government authorities, if deemed necessary.
16. The whistleblower will be kept informed of the progress of the investigations and, if appropriate, of the final outcome.