Our Centre’s Whistleblowing Policy
WHISTLEBLOWING POLICY
1. Purpose
2. Reportable Incidents
Below is a list of examples (which is not exhaustive) of reportable incidents covered by this policy concerning SAGECC’s corporate governance, accounting and financial reporting, internal controls, or auditing matters:-
- Impropriety, corruptions acts of fraud, theft and/misuse of SAGECC’s properties, assets or resources (including confidential information)
- Breach or circumvention of internal controls or policies
- Irregularities in financial reporting
- Unlawful offence being committed
- Sexual or other forms of harassment
- Abuse of power and authority
- Corruption and bribery
- Concealment or willful suppression of any wrongdoing
- Any other serious improper matters which may cause financial or non-financial loss to the Centre, or damage to the Centre’s reputation.
3. Protection against Reprisal and Confidentiality
When raising concern or providing information about an actual, suspected, or anticipated wrongdoing, done in good faith, the individual, be it an employee, or anyone else, shall be protected against any reprisal such as employment termination, retribution, or harassment.
SAGECC will not tolerate any retaliation against any person that has raised concern or provided information about any actual, suspected or anticipated wrongdoing. Further, all care will be taken to restrict the disclosure of the identity of such person, which shall be treated as confidential information at all times.
It is recognized that an individual may choose to remain anonymous in certain cases. Concerns or information provided anonymously will still be given due consideration by SAGECC but will be investigated on their own merits.
4. Reporting Procedure
Concerns may be raised with or information provided to the following:
Private & Confidential
For the Attention of Audit Committee Chairman
1 Jurong West Central 2 #06-04 Jurong Point Shopping Centre
Singapore 468886
Such reports are preferably made in writing, in the form of a letter, and in detail setting out the background and history of events as well as the reason(s) for concern.
Alternatively, reports with supporting documents detailing the background, history of events and reason(s) for concern may be emailed to whistleblowing@sagecc.org.sg.
In the event that any reports are sent to, and received by SAGECC Management, the recipient shall forward such report to the Audit Committee Chairman and notfiy the sender of the same.
5. Investigation Process
SAGECC takes every report submitted seriously. Upon receiving a report, the Audit Committee Chairman will immediately look into it and determine as soon as possible whether or not an investigation of the issue raised in the report should be carried, after assessing the materiality or relevance of the concern or information provided.
Assessment of the concern or information shall be made with due consideration given to the following factors:
- Seriousness of the issue raised;
- Credibility of the concern or information; and
- Likelihood of confirming the conrer or information from the attributable sources
If the issues raised in the report warrants investigation, the Audit Committee Chairman will determine the appropriate stakeholders that will act as the investigation officer(s) within 7 days of the assessment referred to above. The investigation officer(s) shall commence work immediately upon appointment and shall report directly to the Audit Committee on the progress of the investigation.
The amount of contact between the whistle blower (if no anonymous) and the person(s) investigating the concern raised or information provided will be determined by the nature and clarity of the matter reported. Further information may be sought from the whistle blower during the course of investigation.
The Audit Committee is authorized and empowered to take steps to facilitate the conduct and completion of the investigation by the investigation as soon as practicable. When the investigation is completed, the investigating officer(s) will submit a report to the Audit Committee detailing the following for its necessary action:
- Full findings of the case
- Corrective actions recommended, if any;
- Recommended changes to existing processes / procedures to ensure that violations will not be repeated, if any.
