Tanglin Club

Whistle Blowing Policy and Procedures

1. Introduction

1.1 Tanglin Club is committed to a high standard of ethics, honesty, openness and accountability. The Club is also committed to comply with accounting, financial reporting, internal controls and auditing requirements and any legislation relating thereto. In line with these commitments and in order to enhance good Governance, transparency and safeguard the integrity of the Club, the Whistle blowing policy is intended to provide the following:

  • i) An avenue for raising concerns related to any illegal or unethical behaviour such as fraud, corruption and other misconduct.
  • ii) Assurance that those who disclose such information will be adequately protected and that action would be taken on the disclosure.

1.2 According to the intent of this policy, whistle blowing is the reporting of alleged unethical conduct of Employees, Management, Section committee members, Subcommittee members, Task Force members, Comprehensive Maintenance Initiative (CMI) members, General Committee members and other stakeholders by an employee or other person to appropriate authorities.

1.3 This policy aims to provide to create a work environment where employees, vendors, service providers, customers and other stakeholders are able to raise concerns on misconduct, irregularities or malpractices, without fear of harassment and/or victimisation and with an assurance that their concerns will be taken seriously and investigated, and the outcome duly communicated.

 

2. Types of Whistle Blowers

2.1 There are two types of whistle blowers namely:

2.1.1 Internal whistle blowers

  • i. Employees who report incidents of misconduct in an organisation involving a peer/colleague, a supervisor or indeed a top management official.
  • ii. Employees who will abuse the system to voice out their personal grudges, unfairness and/or operational issues.

2.1.2 External whistle blowers – customers, suppliers, service providers, other members of public who report wrong doings of employees to the General Manager and/or President of the Club.

 

3. Objective

3.1 This policy aims to set out the Club’s written, formal whistle blowing policy, consisting of responsible and effective procedures for disclosure or reporting of misconduct and impropriety so that appropriate remedial action can be taken if concerns are deemed legitimate.

3.2 It is intended to encourage employees and other stakeholders to report unethical or illegal conduct or conduct of employees, management, section committee members, subcommittee members, task force members, CMI members, general committee members and other stakeholders to appropriate authorities in a confidential manner without any fear of harassment, intimidation, victimisation, reprisal of anyone for raising a concern under this policy. Specific objectives of the policy are to:

  • Encourage timely reporting of alleged malpractices/misconduct;
  • Provide a means for discreet and confidential channel for escalation of concerns without fear of reprisal;
  • Ensure consistent and timely institutional response to reported improprieties and awareness of whistle blowers of their options/rights;
  • Ensure appropriate oversight by the General Committee members;
  • Serve as a means of preventing and deterring misconduct that may be contemplated but has not yet taken place;
  • Protect the rights of the Club and that of its members;
  • Promote and development of a culture of openness, accountability and integrity.

 

4. Scope

4.1 This policy is designed to enable employees and other relevant stakeholders report acts of impropriety to appropriate authorities. The report should however not be based on mere speculation, rumours or gossip but on personal knowledge of verifiable facts or circumstances to indicate that the reportable misconduct has occurred or likely to occur.

4.2 All employees are protected from victimisation, harassment or disciplinary action as a result of any disclosure, where the disclosure is made in good faith and is not made maliciously or for personal gain.

 

5. Definition

5.1 Whistle blowing is defined as a deliberate, voluntary disclosure of individual or organisational malpractice by a person who has or has had privileged access to data, events or information about an actual, suspected, or anticipated wrongdoing within or by the Club that is within its ability to control.

 

6. Reportable Incidents

6.1 Below is a list of examples (though not exhaustive) of reportable incidents covered by this policy:

  • Concerns about the Club’s banking and treasury, procurement, accounting, business sensitive information, internal controls or auditing matters;
  • Breach of or failure to implement or comply with the Club’s policies or code of conduct;
  • Actions detrimental to Health and Safety or the Environment;
  • Any form of criminal activity;
  • Impropriety, corruption, acts of fraud, theft and/or misuse of the Club’s properties, assets or resources;
  • Abuse of power or authority;
  • Conflict of interest without disclosure;
  • Intentional provision of incorrect information to public bodies;
  • Concealing information about any malpractice or misconduct;
  • Fraud against stakeholders, or the making of fraudulent statements to stakeholders and regulatory authorities;
  • Acts to mislead, deceive, manipulate, coerce or fraudulently influence any internal or external accountant or auditor in connection with the preparation, examination, audit or review of any financial statements and records or operations of the Club;
  • Improper conduct or unethical behaviour that undermines universal or core ethical values such as integrity, respect, honesty, accountability, fairness, etc.;
  • Failure to comply with legal obligations or statutes;
  • Other forms of Corporate Governance breaches;
  • Sexual or physical abuse of any employee, customer, applicant, service provider and other relevant stakeholders;
  • Conduct translating to gross waste of resources;
  • Any other improper matters which may cause financial or non-financial loss to the Club, or damage to the Club’s reputation.

6.2 The above list is intended to give an indication of the kind of conduct which might be considered as reportable incidents. In case of doubt, the whistle blower should seek to speak to his or her immediate superior or follow the procedure for reporting under this Policy.

 

7. Protection Against Reprisal

7.1 If an employee raises a genuine concern under this Policy, he or she will not be at risk of losing his or her job or suffering from victimisation or harassment as a result. Provided that the employee is acting in good faith, it does not matter if he or she is mistaken.

7.2 For external party who raises a genuine concern in good faith, he or she will not be barred from future quotation or tenders of jobs/services in the event he or she is mistaken.

7.3 However, the Club does not condone frivolous, mischievous or malicious allegations. Employee(s) making such allegations will face disciplinary action, as appropriate.

7.4 For external party, if the investigations reveal that he or she make the complaint for malicious intent or for personal gains, appropriate action may be taken, including reporting to the police.

 

8. Confidentiality

8.1 The Club encourages the whistle blower to identify himself or herself when raising a concern or providing information. The whistle blower’s identity as well as concerns raised will be treated with strictest confidentiality.

8.2 Exceptional circumstances under which information provided by whistle blower could or would not be treated with strictest confidentiality include:

  • Where the Club is under the legal obligation to disclose the information provided;
  • Where the information is already in public domain;
  • Where the information is given on a strictly confidential basis to legal/auditing or other professionals for the purposes of obtaining professional advice/assistance;
  • Where the information is given to the Police or other authorities for criminal investigation.

8.3 In the event Management is faced with a circumstance not covered by the above, and where the whistle blower’s identity is to be revealed, Management will endeavour to discuss this with the whistle blower first.

 

9. Whistle Blowing Procedure

9.1 A whistle blower may raise concerns either by declaration or anonymously through any of the following:

  • Formal letter or Email to Audit Committee Chairman.

9.2 If the concerns raise affect the Audit Committee Chairman, the formal letter or email to be directed to the President of the Club.

9.3 Reporting Format

The concern(s) shall be presented in the following format:

  • Background of the concern(s) (with relevant dates);
  • Reason(s) why the whistle blower is particularly concerned about the situation. Supporting evidence for the allegations, if available, would be helpful in the investigation.

9.4 Investigation Process of Concern(s)

9.4.1 The purposes of the investigation are to:

  • Establish if a issue has occurred based on the concern(s) raised, and if so, to what extent; and
  • To minimise the risk of issue, prevent any further loss of assets, damage to the reputation of the Club and if possible protect all sources of evidence.
  • Establish if the issue is a general operational issue and not within the whistle blowing scope as listed in 6.1,

9.4.2 The Audit Committee Chairman shall within five (5) working days of receipt of the concern(s) from the whistle blower, acknowledge receipt of the concern(s) raised.

9.4.3 The Audit Committee Chairman will then assess with the Audit Committee whether the concern(s) raised fall within the scope of the whistle blowing or not. If preliminary assessment shows that the concerns falls within the whistle blowing reportable incidents, the Audit Chairman will then report the concern(s) received to the General Manager and President or in absence of the President, the Vice President.

9.4.4 The Audit Committee would then be invited to the next General Committee (GC) Meeting to present to the issue to the GC.

9.4.5 The GC would then make a decision on the appropriate action to be taken.

9.4.6 If there is criminal activity or fraud has taken place, the matter may be referred to the police and where necessary, appropriate legal action taken.

9.4.7 Dependent on the severity, nature, credibility of the concern(s) and information provided, the investigation may be conducted involving one or more of these persons or entities:

  • The External or Internal Auditor (EIA);
  • Forensic Professionals (FP);
  • The Police or Commercial Affairs Department (PCAD); and/or
  • The Corrupt Practices Investigation Bureau (CPIB).

9.4.8 If the issue does not fall within the whistle blowing scope as listed in 6.1, then the Audit Chairman will then pass on the issue to President or in absence of the President, the Vice President, who will then task the General Manager to take appropriate action.

9.4.9 Where necessary, the Audit Committee Chairman or as directed by the Audit Chairman, the General Manager will keep the whistle blower informed of the progress and the outcome of the investigation, within the constraints of maintaining confidentiality or observing legal restrictions generally.