Whistleblowing Policy

Objectives

The objectives of this policy are to:

• provide avenues for the stakeholders (e.g. the general public, employees, volunteers, donors and beneficiaries) of Tzu Chi Singapore to raise concerns and define a way to handle these concerns;
• enable the Board of Directors to be informed at an early stage about acts of misconduct;
• reassure whistleblowers that they will be protected from punishment or unfair treatment for disclosing concerns in good faith in accordance with this procedure; and
• help develop a culture of openness, accountability and integrity.

Whistleblowing Scope

The areas covered by this policy include, but not limited to, the following:

• Conduct which is an offence or breach of law;
• Impropriety, corruption, acts of fraud, theft and/or misuse of properties, assets or resources of Tzu Chi Singapore;
• Concerns about financial & internal controls integrity of Tzu Chi Singapore;
• Non-disclosure of conflict of interest;
• Breach of policies and procedures or code of conduct;
• Deliberate concealing of information about any ongoing or past malpractice or misconduct that has yet to be reported;
• Abuse of authority for personal gain;
• Discrimination or physical abuse of any personnel under employment or serviced; and
• Discrimination to any member of staff or service recipient on grounds of gender, race or disability.

Confidentiality of the Whistleblower

Tzu Chi Singapore shall treat all information received confidentially and therefore undertakes to treat all whistleblowing reports as either confidential or anonymous. The whistleblower may choose to remain anonymous or reveal his identity when making his report. Where the identity of the whistleblower is revealed, Tzu Chi Singapore will keep the whistleblower’s identity confidential and will not be disclosing his identity to any persons other than the appointed investigators, where necessary.

Exceptional circumstances under which information provided by the whistleblower could not or would not be treated with strictest confidentiality include:

1. where Tzu Chi Singapore is under a legal obligation to disclose information provided;
2. where the information is already in the public domain;
3. where the information is given on a strictly confidential basis to legal or any professionals for the purpose of obtaining professional advice; or
4. where the information is given to the police or other statutory authorities for criminal investigation.

In the event that Tzu Chi Singapore is faced with a circumstance not listed above, where the revelation of the whistleblower’s identity is deemed necessary, the Audit Committee Chairman will endeavour to discuss this with the whistleblower first.

No action of any kind will be taken by Tzu Chi Singapore against a whistleblower nor will his designation in Tzu Chi Singapore be adversely affected by his merely raising the concerns/issues or making an allegation against a company official; provided always that he raises the concerns/issues or allegations in good faith and without malice and has reasonable ground believing them to be true.

Any malicious or frivolous complaint or allegation made by an employee against Tzu Chi Singapore’s official or fellow colleague, however, may result in Tzu Chi Singapore, after proper investigation, taking disciplinary action against him.

Reporting Procedure

Reporting Options

The whistleblower may email the subject matter to the Audit Committee Chairman via Audit_Committee@tzuchi.org.sg.

Report Format

The report must be in writing. Pertinent details including but not limited to, background, history of events and rationale of the subject matter shall be logged via the whistleblowing report.

We shall maintain a whistleblowing log for all whistleblowing reports received.

Assessment

All reports made in good faith shall be properly assessed, reviewed and dealt with. Considerations shall be given to the following factors when conducting the investigation:

1. seriousness of the issue raised;
2. credibility of the concern or information; and
3. likelihood of confirming the concern or information from attributable sources.

The Audit Committee Chairman shall decide on the need to appoint an internal investigator based on the merits of each report. Depending on the nature of the subject matter, the internal investigator may involve one or more parties from the following:

1. external auditor;
2. internal auditor;
3. forensic accountant;
4. Commissioner of Charities; or
5. the Police or Commercial Affairs Department.

Upon investigation, the appointed investigator shall submit a report detailing the investigation outcome. Based on the investigation report, the Audit Committee Chairman, upon consultation with the Board of Directors, shall determine the appropriate actions to be taken to address the whistleblowing report received.