Whistle Blowing Policy and Procedures

  1. PURPOSE AND OUTLINE
    Autism Association (Singapore) (“AA(S)”) is committed to proper governance, professional management, statutory compliance and integrity. It does not tolerate malpractice, impropriety, statutory non-compliance or wrong doing.

    In line with the commitment the Board of Management (“BOM”) approved and adopted this Whistle Blowing Policy to ensure that arrangements are in place for whistle-blowers who may raise concerns about actual or possible improprieties without fear of reprisals in any form.

    The Whistle Blowing Policy (“Policy”) provides an avenue for you to raise concerns and offer reassurance that you will be protected from reprisals or victimisation for whistle blowing in good faith.
     
  1. DEFINITIONS
    Whistle-blower: A whistle-blower is an individual who submits in good faith a complaint or concern to AA(S) regarding any improper or illegal conduct within AA(S). The whistle-blower’s role is as a reporting party, not an investigator or a finder of facts and does not determine the appropriate corrective or remedial action that may be warranted.
     
    Good Faith: Good faith is evident when the report is made without malice or consideration of personal benefit and you have a reasonable basis to believe that the report is true. However, a report does not have to be proven to be true to be made in good faith. Good faith is lacking when the disclosure is known to be malicious or false.
     
  1. WHO IS COVERED BY THIS POLICY
    This Policy applies to all AA(S) Staff, BOM Members, Audit Committee Members, and external parties.
     
  1. OBJECTIVES
    The intended objectives of this Policy are to:
  • Deter wrongdoing and to promote standards of good corporate practice and governance.
  • Provide proper avenues for you to raise concerns about actual or suspected improprieties in matters of financial reporting, irregularities or other matters and receive feedback on any action taken.
  • Reassure you that you will be protected from punishment or unfair treatment for disclosing concerns in good faith in accordance with this procedure.
  • Assist to develop a culture of openness, accountability and integrity.
     
  1. REPORTABLE INCIDENTS
    Some examples of concern covered by this Policy, include:
  • Impropriety, corruption, acts of fraud, theft and/or misuse of the AA(S)’s properties assets or resources.
  • An individual abusing his/her official AA(S) position in connection with unauthorised activity for financial or non-financial gain.
  • A failure to comply with a legal obligation (e.g. breach of a contractual or other common law obligation, statutory duty or requirement, malpractice or breach of a code of conduct).
  • Concerns about AA(S)’s accounting or internal control matters.
  • Breach of or failure to implement or comply with AA(S)’s policies or code of conduct.
  • Conflict of interest without disclosure.
  • Intentional provision of incorrect information to public bodies.
  • Compromising health and safety of staff/students/clients/external parties.
  • Physical / Verbal / Emotional / Sexual Abuse on staff/students/clients/external parties.
  • Concealing information about any malpractice or misconduct.
  • Any other serious improper matters which may cause financial or non-financial loss to AA(S) or damage to AA(S)’s reputation. 

The above list is intended to give an indication of the kind of conduct which might be considered as “reportable”.  In cases of doubt, you should seek to speak to your immediate supervisor(s), or his/her immediate supervisor(s), or whoever is appropriate and accessible safely, or follow the procedure for reporting under this Policy.

The Policy does not apply to personal grievances concerning an individual’s terms and conditions of employment, or other aspects of the working relationship, or disciplinary matters.

These will continue to be administered and reviewed by AA(S)’s Human Resource policies. The Policy should therefore be read in conjunction with the existing Human Resource policies framework in AA(S).

 

  1. PROTECTION AGAINST REPRISALS
    If you raise a genuine concern under the Policy, you will not be dismissed from AA(S), be at risk of reprisals or harassment provided that you are acting in good faith. Reprisals of any form shall not be tolerated.  Any act of alleged reprisal should be reported immediately and it will be promptly investigated.

    AA(S) does not condone frivolous, mischievous or malicious allegations. Staff making such allegations will face disciplinary action.

     

  2. CONFIDENTIALITY
    AA(S) requires you to identify yourself when raising a concern or providing information.  All concerns will be treated with strictest confidentiality.

    Concerns expressed anonymously are much less persuasive and may hinder investigation work as it is more difficult to look into the matter or protect your position..

    Exceptional circumstances under which information provided by you could or would not be treated with strictest confidentiality include:
  • Where AA(S) 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.
  • Where the information involves life threatening situations.

In the event AA(S) is faced with a circumstance not covered by the above, and where your identity is to be revealed, we will endeavour to discuss this with you first.

  

  1. HOW TO RAISE A CONCERN OR PROVIDE INFORMATION
    Concerns or information should preferably be provided in writing following the channels of reporting below. You may also report acts of misconduct verbally.

    You may email to any of the following parties:
      • Chairman of AA(S).
      • Vice Chairman of AA(S) 
      • Chairman of AA(S) Audit Committee

Please submit the concerns via this link

Reporting should be made as soon as is practicable. It is essential for AA(S) to have all critical information in order to be able to effectively evaluate and investigate the concerns raised. AA(S) recommends that you be detailed in setting out the background and history of your concerns, details of the parties involved, dates or period of time, the type of concerns and the reasons for your concerns, evidence substantiating the concerns raised, where possible, and contact details.

For staff, you can raise your concerns to your immediate supervisor(s) or escalate your concerns to your next-level supervisor(s), or whoever is appropriate and accessible safely, based on the internal organisation hierarchy.

For external parties, you can also raise your concerns directly to the Chairman and/or Vice Chairman of AA(S) and/or Chairman of AA(S) Audit Committee.

All concerns received will be investigated by BOM, with or without the involvement of the Chairman and/or Vice Chairman of AA(S).

Although you are not expected to prove the truth of the allegation, AA(S) expects you to provide your concerns in good faith and to demonstrate that there are sufficient grounds for your concerns.

  

  1. HOW AA(S) WILL RESPOND 
    AA(S) assures you that any concerns raised or information provided will be thoroughly investigated, but consideration will be given to the nature and quality of information provided. AA(S) will revert to you acknowledging that the concerns raised have been received.

    The Management (and/or BOM) will conduct the initial investigation(s) of the concerns received.  The matters raised may be:
  • Investigated internally
  • Referred to the external auditor(s)
  • Referred to appropriate law enforcement agencies
  • Investigated by an independent inquiry. 

All findings of the investigation(s) shall be reported to the relevant Board Committee(s) for their attention and necessary action.

 

Last modified on Wednesday, 11 December 2019 09:27