Guide Dogs Singapore Ltd (“GDS”) is committed to conducting its operations in compliance with applicable accounting requirements, financial reporting requirements, internal controls, corporate governance (including, without limitation, the code of governance for charities and institutions of a public character applicable to GDS) and any legislations and regulations relating thereto. Our whistle blowing policy (this “Policy”) aims to provide an avenue for any employee or stakeholder (such as any volunteer, supplier, service user, beneficiary and any other party with a business relationship with GDS) (a “Whistleblower”) to raise concerns about actual, suspected or anticipated wrongdoings or improprieties in matters or concerns within GDS, which may include, without limitation, the following:
- any fraudulent act or forgery;
- misappropriation of GDS’ funds or assets;
- profiteering as result of insider knowledge of GDS’ activities/information;
- disclosure of confidential or proprietary information of GDS to parties not under any form of employment and engagement with GDS;
- accepting or seeking anything of material value from employees or other stakeholders of GDS;
- destruction, removal, or inappropriate use of GDS’ records, assets or facilities;
- breach of GDS’ policies or code of conduct; and
- improper actions or omissions which are likely to endanger GDS’ employees or others.
This Policy does not and cannot reasonably detail or cover every situation that should be reported pursuant to this Policy. If you are in any doubt as to how you should apply any provisions of this Policy, at any point in time, you are encouraged to seek guidance from (in the case of GDS’ employees) your immediate supervisors, the senior management of GDS or the Panel (as defined below).
GDS offers assurance to Whistleblowers that they will be protected from reprisals or victimisation for any whistle blowing done in good faith, regardless of whether he or she is mistaken. GDS will protect the privacy of a Whistleblower who reports the wrongdoing. However, GDS shall not condone any frivolous, mischievous or malicious allegations. Employees of GDS found making such allegations may be subject to disciplinary action.
The reports and identities of the Whistleblowers will be treated in strict confidence to the extent feasible, consistent with the need to conduct a proper investigation of the alleged wrongdoing. Exceptional circumstances under which information provided by a Whistleblower may have to be disclosed includes where GDS is under legal obligation to disclose such information to authorities and where such information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice.
GDS encourages Whistleblowers to provide their names and contact numbers to facilitate investigations. GDS respects a Whistleblower’s desire for anonymity; however, if a Whistleblower chooses to remain anonymous when raising a concern, GDS may not be able to facilitate an appropriate follow-up to properly investigate the allegations. Accordingly, concerns expressed or information provided anonymously will be investigated on the basis of their merits.
Reports lodged by Whistleblowers should be specific and as detailed as possible, setting out the background, history, description, grounds and reasons for their concerns. The reports can be sent to GDS via the following channels:
Any whistleblowing report not involving the Chairman may be reported directly to the Chairman using the following channel:
Attention: Wong Hon Tym
Any whistleblowing report involving the Chairman may be reported directly to the General Manager using the following channel:
Attention: Vanessa Loh
The Whistle Blowing Investigation Panel comprising Dr Wong Hon Tym (Chairman), Ms Shirley Patricia Sutton, Lee (Deputy Chairwoman & Secretary) and Mr John Shum (Director). The “Panel” will ensure that the allegations raised in a whistleblowing report are investigated independently and fairly. Based on the nature of the allegations raised and/or information provided, the allegations may be investigated internally, referred to external auditor, referred to appropriate law enforcement agencies and/or investigated by an independent inquiry. All findings and recommendations shall be reported to the Investigation Panel, who will report its decisions on action(s) to be taken to the Board of Directors.
Where appropriate, and subject to any legal and confidentiality constraints, the relevant Whistleblower may be notified of the outcome of the investigation.
GDS may modify this Policy to maintain compliance with applicable laws, regulations, corporate governance standards or accommodate organisational changes within the organisation.