Whistle Blowing Policy
A. Introduction
Yong-en Care Centre (YCC) is committed to a high standard of compliance with financial reporting, accounting, internal control and auditing requirements, code of conduct and any law or legislation relating thereto. This policy aims to provide an avenue for staff, volunteers and external parties to raise concerns and offer them assurance that they will be protected from reprisals or victimisation for whistle blowing in good faith.
B. Definition
Whistle blowing is defined as a voluntary and deliberate disclosure of malpractice (whether individual or organisational) by a person (also known as whistle blower) who has or has had privileged access to information, data or event about an actual, suspected or anticipated misconduct, violation, misfeasance or wrongdoing within or by YCC that is within its ability to control.
C. Scope
This policy is applicable to all staff, volunteers and external parties who have dealing or relationship with YCC, including beneficiaries, customers, suppliers, contractors, donors and the public.
D. Matters that may be reported
Below is a list of examples (without limitation) of reportable matters covered by this policy:
(i) Impropriety, corruption, acts of fraud, theft and/or misuse relating to YCC’s funds, properties, assets or resources;
(ii) Misconduct relating to YCC’s financial reporting, accounting, internal control or auditing matter;
(iii) Conduct or deed which is an offence under law or a breach of law;
(iv) Conflict of interest without disclosure;
(v) Breach of YCC’s policies or code of conduct or wrongful discrimination;
(vi) Concealing of information relating to any malpractice or misconduct;
(vii) Any misconduct that may cause loss (whether financial or non-financial) to YCC or damage its reputation;
(viii) Fraud against YCC’s members or making of fraudulent statements to the public, government or state authorities;
E. Confidentiality and Protection against Reprisal
1) When any individual – in good faith – raised a concern or provided information about an actual, suspected or anticipated wrongdoing, that individual, be it an employee or anyone else, shall be protected against any unfair reprisal including employment termination, adverse impact on employment benefits, retribution, punishment or harassment.
An employee of YCC who retaliates against someone who has reported a matter in good faith is subject to disciplinary action in accordance with YCC’s prevailing policy.
2) However, YCC shall not condone any frivolous, mischievous or malicious allegation. Employees, found making such allegation shall be subject to disciplinary action in accordance to YCC’s prevailing employment or personnel policy or code of conduct.
3) Any concern, report or information about an actual, suspected or anticipated wrongdoing and its source shall be treated with strictest confidence.
Exceptions to the above include:
(a) When YCC is under legal obligation to disclose such information or report provided;
(b) When the information or report is already in the public domain;
(c) When the information or report is given in strict confidence to legal or auditing professionals for the purpose of obtaining professional advice; and
(d) When the information or report is given to the police or any regulator for criminal, regulatory or similar investigation.
4) Concerns expressed anonymously are difficult to act upon effectively; however, they may be considered, taking into account the severity and credibility of the issues raised and the likelihood of confirmation of the allegation from attributable sources and information provided. Hence, the whistle blower is encouraged to provide his/her contact information so that clarifications could be sought during investigation. If a whistle blower chooses to make such reports anonymously, he/she shall not be entitled to the investigation outcome of the case reported.
F. Address for the report
The concern may be raised with or the report/information may be provided to:
YCC at whistleblowing@yong-en.org.sg
Marked Private and Confidential and
Marked to the attention of the Audit Committee Chairman
The report should preferably be made in writing, either in the form of a letter or email (or both), and in detail setting out the background and event history as well as the reason(s) for concern. See Annex C.
G. Procedures
1) Assessment of the concern or information shall be made with due consideration given to the following factors:
(I) Seriousness of the issue raised;
(II) Credibility of the concern or information; and
(III) Likelihood of confirming the concern or information from the attributable sources.
2) Depending on the nature of the concern raised or information provided, the investigation will be conducted, involving one or more of the following individuals or entities (and any other body that Management Committee may recommend or deem desirable):
(a) The audit committee
(b) The external auditor, and/or
(c) The police, commercial affairs department or similar body.
3) The level of contact between the whistle blower and the person(s) investigating the concern raised or information provided will be dependent on the nature and clarity of the matter reported. Further information may be sought from the whistle blower during the course of the investigation.
4) When the investigation is completed, the investigating officer(s) will report the findings to, or the investigation report will be forwarded to, the audit committee for its necessary action.
5) The Governance sub-committee shall advise the Management Committee as soon as is reasonably possible of any actual or suspected misconduct, violation, misfeasance or wrongdoing within or by YCC that it is aware of.
6) Depending on the wrong-doing or the alleged wrong doer, the Governance Sub-Committee may also be the Investigating Officer who will then submit its investigation report to a specially appointed panel consisting of relevant Management Committee members to consider its recommendations.
7) The specially appointed Panel will then approve the recommendations and follow-up measures.
Yong-en Care Centre
Approved: 15 November 2021
Reviewed: 22 March 2022
