Whistleblowing Policy

Any whistle-blower who wishes to report any suspected detrimental action or improper conduct by any employees, council members, contractors of the TC should make a written report (in sealed envelope marked “Private & Confidential”) as soon as possible to the TC’s Secretary, or TC Audit Committee Chairman at the following address:

Block 504C Canberra Link, 01-63, Singapore 753504

He may also do so through the email:

secretary@sbtc.org.sg

The content of the mailed report / email shall include the following:

• The name and address of the whistle-blower
• The time and date of the alleged act
• Clear description of the alleged act
• Documentary/audio/visual evidence of the alleged act committed, if any.

All concerns raised shall be treated with strict confidentiality. However, the whistle-blower is expected to identify himself when raising a concern. This is to facilitate the investigation as well as to reply the Whistle-blower promptly. By providing his name, it is also easier to interview him where this is required during the investigation.

A complaint can also be filed even when the Whistle-blower is not able to identify a particular person, or perpetrator of the detrimental Actions or Improper conduct.

1. The TC Secretary, or an Officer directed by the Chairman of TC Audit Committee, will lead the investigation. Such investigation shall be conducted in a fair and objective manner without any presumption of guilt. Where necessary, the investigation team may consult and seek legal advice. Where there are elements of criminal offence and corruption, the matter may be referred to the Police or the Corrupt Practices Investigation Bureau (CPIB).

2. The investigation team should handle all matters with confidentiality and aim to complete the investigation promptly. All relevant documents received by investigation team shall be recorded and filed.

3. To safeguard against possibility of bias, prejudice or conflict of interest, the person who is the subject of complaint shall not participate or be involved in the investigation team.

4. The investigation team shall outline the detailed procedures for the investigation. It shall be granted full and unhindered access to all material evidence, including interviews with witnesses, etc.

5. Upon receipt of the report on the findings of the investigation, the TC Secretary, or TC Audit Committee Chairman, (whichever the case may be) will evaluate the findings. If he is not satisfied with the findings of the investigation, he may:
 (a) Order a fresh investigation, or request that further investigation be conducted by the same investigation team or new investigation team consisting of new members, or
 (b) Conduct his own investigation.

6. Appropriate action may be taken against the parties at fault, with concomitant corrective actions to address any lapses in controls and procedures, if applicable.

7. If the detrimental action or improper conduct is proven, the TC Secretary, or TC Audit Committee Chairman, may also decide on the appropriate course of action to be taken, which may include the following:
 (a) Reprimand, take disciplinary action, impose punishment
 (b) Transfer to another department / relocate place of employment
 (c) Terminate or suspend employment
 (d) Report the matter to the relevant authorities
 (e) Any other action deemed appropriate by TC

8. Preventive Measures for the Future
Make recommendations to the relevant department to implement procedures, or take preventive measures to minimize or prevent future repetition of the detrimental action or improper conduct.

9.The decision on the corrective actions to be taken, including the action taken against the person(s) found to have committed the detrimental action or improper conduct, shall be communicated in writing (after consulting with the Corporate Communication Team) to the whistleblower.

10.Complaints relating to the TC Chairman, TC Secretary and TC Audit Committee Chairman shall be referred to as follows :
 TC Chairman  -> TC Audit Committee Chairman or TC Vice Chairman
 TC Secretary -> TC Audit Committee Chairman
 TC Audit Committee Chairman -> TC Chairman
who shall be responsible for commissioning the investigation and deciding on how the investigation should proceed.

Protection shall be provided to the whistle-blower so that the person against whom a complaint is made cannot take any retaliation against the whistle-blower. The protection accorded to the whistle-blower is not limited, or affected in the event that a complaint made by the whistle-blower in good faith, does not lead to any corrective action taken against the person(s) against whom the complaint or report has been made.

Whistle-blowers, who had reported a concern which is subsequently found to be unsubstantiated, should not be subjected to any disciplinary action if he has reported the concern in good faith. However, if the complaint is made out of a malicious, frivolous and vexatious allegation or consideration of personal gain, the whistle-blower may be subjected to disciplinary or Police action.

The TC Secretary, or Chairman of the TC Audit Committee, shall maintain a Complaint Register for the purpose of recording details of all complaints received, including the date, nature and the status of such complaint.

The Complaint Register shall be handed over to succeeding TC Secretary, or Chairman of the TC Audit Committee.