Whistle Blowing Policy
Aljunied-Hougang Town Council (“AHTC”) maintains high standards of integrity and holds its staff to the same levels of conduct to comply with the Town Council Act, Town Council Financial Rules, and its accounting, financial reporting, internal controls, governance and any related legislation.
AHTC places heavy emphasis and efforts towards a transparent corporate culture, with zero tolerance for inappropriate practices, wrongdoings and misconduct which may damage the reputation of the Council.
This Whistle-Blowing Policy provides an avenue for any member of public to report any concerns over inappropriate practices, suspected wrongdoings and misconduct.
Whistle-blowing is the term used when a person (whistle-blower) reports any inappropriate practices, suspected wrongdoings and misconduct of the town councillors, contractors and employees of the Town Council.
The Policy intends to facilitate whistle-blowing relating to improprieties, suspected wrongdoings and misconduct including but not limited to:
- All forms of financial or non-financial malpractices or impropriety such as corruption, embezzlement, misappropriation, theft, bribery and extortion, fraud, forgery and falsified claims
- Concerns about AHTC’s accounting, internal controls or auditing matters
- 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 or records
- Any physical, emotional, sexual harassment or bullying
- Unethical behaviour such as abuse of power, position and authority
- Endanger the health and safety of others
- Wilfully making a negligent disclosure relating to a conflict of interest
- Criminal offences governed by the Penal Code of Singapore
- Conceal information about any of the above
This Policy aims to address malpractice and wrongdoing, and these concerns should not be confused with grievances and other like issues that are not of the nature described above, for instance, a personal work-related grievance in relation to employment terms, interpersonal conflict with other employees, feedback on the service levels, disciplinary or performance management process, or termination of employment.
AHTC encourages the whistle-blower to identify themselves when raising a concern or providing information. This is to ensure the authenticity, accountability and effectiveness of the investigation, and facilitate reply to the whistle-blower. After making the report, the whistle-blower should refrain from confronting the person being reported or making further investigation. The investigation process may require the whistle-blower who reported the concern, to render assistance in the investigation.
AHTC will take all reasonable steps to protect the confidentiality and identity of the whistle-blower. All reports and records will be treated with strict confidentiality, except where required by applicable laws and regulations, and to conduct further investigations.
Exceptional circumstances may apply under which information provided may be disclosed include but not limited to:
- Where there is a legal obligation to disclose information provided
- Where the information is already in the public domain
- Where the information is given to legal or audit professionals on a strictly confidential basis for the purposes of obtaining professional advice
- Where the information is given to governmental or regulatory entities as part of investigations into allegations made
4. Anonymous reports
Reports made anonymously are more difficult to act upon effectively and may hinder any investigation. Notwithstanding this, AHTC may consider anonymous reports, taking into account, amongst others:
- The seriousness of the issue raised
- The credibility of the concern
- The likelihood of confirming the allegation from attributable sources and information provided
Any whistle-blower making an anonymous report shall not be entitled to be informed of the investigation outcome. AHTC reserves the final decision whether to take any investigation actions for anonymous reports.
5. Reporting and communication procedures
A whistle-blower who discovers any inappropriate practices, suspected wrongdoings and misconduct of the town councillors, contractors, employees of the Town Council and staff of the managing agent should make a hardcopy written report to the AHTC Audit Committee, which is responsible for the oversight and monitoring of AHTC, and ensures that issues raised are properly resolved by management or any appropriate parties.
The hardcopy written report shall be placed in a sealed envelope marked “Private & Confidential” and attention to the “Chair of the Audit Committee” at:
Aljunied-Hougang Town Council
Block 810 Hougang Central #02-214 Singapore 530810
The report shall include the following in the contents of the letter:
- Name, address and contact number of the whistle-blower
- Time and date of the wrongdoings
- Clear description of the wrongdoings
- Evidence of the wrongdoings committed such as documentary/audio/visual evidence proof, if any
- Any other information
The whistle-blower is recommended to provide as much information and to be as specific as possible to facilitate an effective evaluation of the report submitted.
All reports and submissions will be treated fairly and appropriately, and will be assessed based on the merit of their content, without regard to the identity of the whistle-blower or the person reported. The investigation will be undertaken without any presumption of any wrongdoings.
The Audit Committee Chairman will decide whether to convene an investigation team. The investigation team shall handle all matters with strict confidentiality and with a high level of professionalism.
Upon completion of the investigation, an investigation report shall be submitted to the Audit Committee Chairman for review and evaluation. During this period, the Audit Committee Chairman has the right to:
- Request that further investigation be conducted by the same investigation team;
- Request that a fresh investigation be conducted by an investigation team consisting of new members; or
- Conduct its own investigation
After the review of the findings, the Audit Committee Chairman shall decide on the appropriate actions to be taken against the person reported should an investigation find any inappropriate practices, wrongdoings and misconduct. Appropriate actions include but not limited to the following:
- Against the employee, council member or contractor found to have committed the inappropriate practice, wrongdoing or misconduct:
- Reprimand, take disciplinary action, impose punishment
- Transfer to another department/relocation of place of employment
- Termination or suspension of employment
- Report the matter to the relevant external regulatory authorities such as the Police of the Corrupt Practices Investigation Bureau (CPIB)
- Any other action deemed appropriate by AHTC
- Preventive measures for the future
- Make recommendation to the relevant department to implement procedures or take preventive measures to minimize or prevent the occurrence of the inappropriate practice, wrongdoing or misconduct in the future
- Where permissible under relevant laws, the result of the investigation and actions taken shall be communicated in writing to the whistle-blower
6. Protection of Whistle-Blower
AHTC will endeavour to protect a whistle-blower’s identity if he/she is acting in good faith. However, if the complaint is made out of any malicious intent or frivolous and vexation allegation, the whistle-blower may be subject to police/legal action.
7. Reports Register
The Audit Committee Chairman shall maintain a “Reports Register” for recording details of all reports received, including the date, nature and status. The register shall be handed over to the succeeding Audit Committee Chairman.
8. Policy Review
The Policy shall be reviewed regularly in order to maintain compliance with applicable laws and regulations or accommodate any organisational changes. Amendment to the Policy shall be submitted to the Audit Committee and Steering Committee for consideration and approval.