NTUC-U Care Fund: Whistle-blowing Policy

1     PURPOSE 

The NTUC-U Care Fund (hereinafter refer to as “the Fund”) is committed to uphold good transparency and disclosure practices. The Fund strongly believe in being a responsible and responsive charity, fully accountable to all stakeholders.

This policy aims to:

1. Deter wrongdoing and commit to good corporate governance and practices.

2. Provide a trusted avenue for employees, external parties and other stakeholders to raise concerns about actual or suspected improprieties in relation to financial reporting or other matters, without fear of reprisals for whistleblowing in good faith.

3. Ensure measures are in place to facilitate proper investigation of the reported concern and appropriate follow-up actions to be taken.

2     SCOPE

(a) Some examples of concerns include, but not limited to:

• Concern about the Fund’s accounting, internal controls or auditing matters;
• Breach of the Fund’s policies or code of conduct;
• Serious conflict of interest without disclosure;
• Impropriety, corruption, acts of fraud, theft and/misuse of the Fund’s properties, assets or resources;
• Conduct which is an offence or breach of law;
• Abuse of power or authority;
• Any other serious improper matters which may cause financial or non-financial loss to the Fund, or damage its reputation;
• Intentional provision of incorrect information to public bodies;
• 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 of the Fund;
• Concealing information about any malpractice or misconduct

(b) The above list of concerns is not exhaustive. In case of doubt, the whistle-blower should seek to speak to the employee’s immediate superior or follow the procedure for reporting under this Policy.

3     PROTECTION AGAINST REPRISALS

(a) When a genuine concern is raised about an actual or suspected wrongdoing, and done in good faith; it does not matter if the individual is mistaken. The individual who raised the concern, be it an employee or anyone, will be protected against reprisals such as employment termination, retribution or harassment.

(b) However, the Fund shall not condone frivolous, mischievous or malicious allegations. Employee(s) making such allegations will face disciplinary action in accordance with NTUC’s Disciplinary Procedures.

4     CONFIDENTIALITY

(a) Concern or information about an actual or suspected wrongdoing as well as its source shall be treated with strictest confidence, with the below exceptions:

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

(b) In the event where the whistle-blower’s identity is to be revealed and not within the above exceptions, the Fund will endeavour to discuss with the whistle-blower first.

5     REPORTING PROCEDURE

(c) Concerns or information are preferably raised or provided in writing (letter or e-mail), in detail, setting out the background and history of events and the reason(s) for the concern. 

(d) The NTUC-U Care Fund encourages the whistle-blower to identify himself/herself when raising a concern or providing information, in case further clarification or information is required. Concerns or information provided anonymously will still be given due consideration but will be investigated on the Fund’s own merits.

(e) The earlier the concern is raised, the easier it is for the Fund to take action.

(f) The Fund expects the whistle-blower to provide his/her concern in good faith and to show to the appropriate officer that there are sufficient grounds for his/her concern.

6     INVESTIGATION AND RESPONSE

(a) Any concern raised or information provided will be investigated, with consideration given to the following factors:

• Severity of the issue raised
• Credibility of the concern or information
• Likelihood of confirming the concern or information from attributable sources

(b) Depending on the nature of the concern raised or information provided, the investigation may be conducted involving one or more of these persons or entities:

• The Audit Committee
• The External or Internal Auditor
• The Police or Commercial Affairs Department

(c) The amount of contact between the whistle-blower and the person(s) investigating the concern raised or information provided will be determined by the nature and clarity of the matter reported. Further information provided may be sought from the whistle-blower during the course of the investigation.

(d) The investigating officer(s) will communicate the findings of the investigation(s) to the Audit Committee for their necessary action.