Objective
1.1 CaringSG Limited (hereafter “CSG”) is committed to a high standard of professionalism, ethical conduct, and legal compliance. In support of such commitment, CSG provides an avenue for anyone, who has a bona fide concern regarding CSG’s wrongful practices or those of its officers/employees/members, to report them in confidence without fear of reprisal.
1.2 The Board of CSG, in consultation with the Audit and Governance Committee, shall have the overall authority and oversight of this policy to preserve a culture of integrity, accountability and transparency by providing a framework and formal process that promotes whistleblowing, its proper follow-up and resolution.
Scope
2.1 This policy applies to CSG officers/employees/members as well as to all external parties. These parties include CSG beneficiaries, suppliers, contractors, and members of the public.
2.2 Whistleblowing is to be taken seriously, and is not a means by which anyone, including a disgruntled employee, should abuse or sabotage another individual or entity without any just cause or basis. Any whistleblowing must be bona fide, substantiated with reasonable grounds or evidence, and directed to the CaringSG Whistleblowing Emails within a reasonable time. Where necessary, the whistleblower must be prepared to testify or provide a written statement for due legal process.
2.3 CSG will not tolerate the abuse of this whistleblowing process. False allegations made in bad faith could result in disciplinary or other appropriate actions. No disciplinary measures or other actions, however, will be taken against a whistleblower who reports a concern in good faith that later turns out to be false or mistaken.
Policy
3.1 Definition
3.1.1 Whistleblowing is defined as a deliberate, voluntary and bona fide disclosure by any person about an actual, suspected or anticipated wrongdoing by CSG and/or its directors, employees and members.
3.2 Activities/Issues Giving Rise to Whistleblowing
Listed below are examples of activities/issues that warrant whistleblowing:
3.2.1 Theft, abuse or misappropriation of CSG’s assets, using CSG’s assets for own personal benefit or any unlawful purpose, or unlawful dissemination or disclosure of CSG’s proprietary information, know-how and trade secrets;
3.2.2 Fraud
3.2.2.1 Falsification or alteration of CSG’s records, accounts or financial information;
3.2.2.2 Submission of false invoices and claims for reimbursement of expenses;
3.2.2.3 Failure to account for or misuse of CSG’s financial and non-financial assets; and
3.2.2.4 Knowingly provide information which is false or misleading;
3.2.3 Engaging in activities in breach of any laws or legal/contractual obligations;
3.2.4 Unlawful or Unethical conduct. For example, violence, threatened violence, bullying, bribery or acceptance of monies, gifts or monetary benefits in exchange for personal favours;
3.2.5 Making statements or remarks which are defamatory or cause disruption to racial harmony;
3.2.6 Sexual harassment or adopting discriminatory practices;
3.2.7 Misuse, including the downloading and sending of information which will infringe intellectual property or confidential information, or result in a breach of the Personal Data Protection Act; information that is derogatory or offensive;
3.2.8 Engage in activities or practices that will pose a danger to health, safety and/or the environment;
3.2.9 Conflict of interest without disclosure, including a close relationship between a superior and his/her direct reporting subordinate; and
3.2.10 Breach of CSG’s policies or its Code of Conduct.
3.3 CaringSG Whistleblowing Emails
3.3.1 Matters of serious concerns should be emailed promptly to the following appropriate parties:
- CaringSG Executive Head at ED@Caring.sg for matters not implicating the Executive Head
- CaringSG Audit and Governance Committee Chair at AGC_Chair@caring.sg for matters implicating the Executive Head
3.3.2 A whistleblower is strongly advised to provide his/her name and contact details when raising a concern to enable two-way communications for clarifications and to obtain further information for follow-up investigations.
3.3.3 The submission of sufficiently-detailed or complete information is important to facilitate our review and investigation. Where possible, please provide the following:
(i) Nature and details of concern/incident
(ii) Name(s) of person(s) implicated/involved
(iii) Date, time and location of wrongdoing/incident(s)
(iv) Duration and/or frequency of occurrence of the incident(s)
(v) Estimated value of money and/or assets involved, if any
(vi) Reasonable grounds or evidence in support of suspected wrongdoing.
Caution: You should not attempt to obtain evidence for which you do not have a right of access since whistleblowers are reporting parties and not investigators.
(vii) Any other information that may assist us in the investigation
(viii) Your name and contact details
(ix) Name(s) and contact details of witnesses, if any
3.3.4 Concerns raised will be independently reviewed by the Audit and Governance Committee. We will ensure strict confidentiality of information provided to us.
3.4 Protection Against Reprisals And Confidentiality
3.4.1 Harassment or Retaliation
CSG recognizes that the decision to report a serious concern or suspicion can be a difficult one, not least because of the fear of reprisal from those responsible for the improprieties. CSG will not tolerate any harassment or victimization and will take reasonable and appropriate action to protect whistleblowers when they raise concerns in good faith. Disciplinary actions will be taken against those who harass, retaliate or discriminate against whistleblowers.
3.4.2 Confidentiality
CSG will safeguard the whistleblower’s identity in strict confidentiality. If a follow-up investigations or due legal process compels us to divulge the source of information and whistleblower identity, the whistleblower will be informed prior to the disclosure.
3.4.3 Anonymous Reporting
3.4.3.1 CSG strongly encourages whistleblowers to include their contact details and preferably their names in the whistleblowing reports. Subsequent investigations may be hindered if two-way communication or contact cannot be made with the whistleblower to obtain further information or clarification.
3.5 Handling of Whistleblowing Report
3.5.1 All concerns raised will be thoroughly considered, and if deemed bona fide/ valid and critically significant, they will be followed-up and investigated. Due consideration will be given to the nature and quality of information received. The whistleblower will be updated on the status of our investigation and follow-up actions if his/her contact details and identity are provided and known to us.
3.5.2 The Board, in consultation with the Audit and Governance Committee, will assess the validity of each report received, and the matter may be dealt with as follows :
a. investigated internally;
b. referred to an external party; and/or
c. referred to appropriate law enforcement agencies.
3.5.3 The Board and/or Audit and Governance Committee may delegate the investigation of a whistleblowing report to an appropriate person or team it deems fit. The independence of the investigation team is a key consideration. The investigation team is empowered to investigate the concern raised while observing strict confidentiality. CSG will provide the necessary support, cooperation and information access to the investigation team as and when needed. Findings from the investigation shall be reported on a timely basis to the Board, and the Audit and Governance Committee for their attention and necessary consideration for further recommended actions. Where appropriate, legal and other external experts may be consulted to assist in the investigation and review of the investigation report.
3.5.4 Relevant key management officers not implicated in the whistleblowing report will, in consultation with the Audit and Governance Committee and with the Board’s approval, manage the investigation and/or follow-up actions of the whistleblowing report. If key management officers are implicated, then the Audit and Governance Committee and/or the Audit and Governance Committee Chair will take over this role.
3.5.5 To close the loop, the whistleblower shall be informed as soon as is appropriate, once the investigation has been completed and/or the recommended follow-up action has been dealt with accordingly.
CSG will periodically review and update this Policy to ensure its continuing design effectiveness.
