Whistle-blowing Policy

1.1 PURPOSE AND SCOPE

PAP Community Foundation (“PCF”) is committed to a high standard of corporate governance and compliance with all laws and regulatory requirements. Malpractice, impropriety or statutory non-compliance by the management, staff or volunteers in the course of work shall not be condoned by the organisation.

This Whistle-blowing policy aims to provide a means through which PCF employees or members of the public can in good faith, report any activity that infringes on PCF’s code of conduct or violates the law so that the organisation may take up relevant action. It also serves to assure the Whistle-Blower that he/she is protected from reprisals.

This policy applies to all PCF employees, volunteers and all external parties who have business relationships with PCF. These parties include customers, vendors, contractors, applicants for employment, and the general public.

1.2 DEFINITION

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 information and events, or about an actual, suspected, or anticipated wrongdoing which are within PCF’s ability to control.

1.3 REPORTABLE INCIDENTS

The Policy is intended to cover serious concerns that could have a significant impact on PCF, including:

1. Unethical & improper practices or alleged wrongful conduct in matters of financial reporting, internal controls or other related matters.
2. Impropriety, corruption and bribery, acts of fraud or suspected fraud.
3. Embezzlement, misappropriation, theft or unlawful use of PCF’s properties, assets or resources.
4. Conduct which is an offence or breach of law.
5. Abuse and misrepresentation of power or authority.
6. Serious conflict of interest without disclosure.
7. Intentional provision of incorrect information to the authorities.
8. Disclosure of confidential information to outside parties.
9. Intimidation, discrimination or harassment of employees and external parties during the course of work.
10. Irregularities in financial reporting, questionable accounting or audit matters
11. Falsification or fraudulent alteration of documents (contractual agreements, invoices, purchase orders etc.)
12. Unsafe work practices that endanger the health or safety of persons or environment
13. Acts of retaliation, intimidation or harassment, discrimination or unfair treatment against staff who have made an allegation or assisted in the investigation of an allegation

The above list is intended to give an indication of the kind of conduct that may be considered as “wrong-doings” and is not meant to be exhaustive. Where in doubt, the Whistle-Blower should consider consulting his or her Reporting Officer or follow the procedure for reporting under this Policy.

1.4 PROTECTION AGAINST REPRISALS

This policy is intended to safeguard any Whistle-Blower from discrimination resulting from making a report.

PCF prohibits discrimination, retaliation, or harassment of any kind against a Whistle-Blower who submits a complaint or report in good faith. If a staff member raises a genuine complaint pursuant to this Policy, he or she will not be at risk of losing his or her job, or suffering from retribution or harassment as a result. If the staff is acting in good faith, it does not matter if he or she is mistaken.

Any employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

PCF, however, does not condone any frivolous, mischievous or malicious allegation. Employees found making such allegations, shall be subjected to disciplinary action by PCF Disciplinary Panel.

1.5 CONFIDENTIALITY

PCF encourages the Whistle-Blower to identify himself/herself when raising a complaint or providing information relating to the complaint.

All complaints will be treated with strict confidence. Reports of violations or suspected violations will be kept confidential to the extent possible, in accordance with the need to conduct an adequate investigation.

1.6 PROCEDURE FOR REPORTING

This Policy encourages the individual reporting, to provide his or her name and contact details in order to facilitate appropriate follow-up and investigation. Any complaint lodged anonymously shall be investigated based on its own merit.

A complainant may address his or her complaint to any of the below:

The following persons will be notified for any reports made via the general whistleblowing email or postal mail.

a. Chief Executive Officer

b. Head of Corporate Governance

c. Head of Internal Audit

The designated party receiving the complaint shall determine whether an investigation on the report made by the complainant shall proceed under this Policy, be redirected to the appropriate channel or whether no further action is considered necessary.

In the course of the investigation, the Whistle-Blower may be contacted to provide further information or clarification.

All Whistle-Blowing reports covered under this Policy shall be investigated as soon as possible and be resolved. Upon completion, the details of the investigation shall be reported to the Audit & Risk Committee within 3 months of receiving the Whistle-Blower’s report.

All investigation reports on completion are to be retained at the CEO’s office to ensure confidentiality as well as for future reference.