1. SOS’ vision is to be the premier organisation in suicide prevention, with the mission of being an available lifeline to anyone in crisis. SOS’ core values are respect, accountability, confidentiality and collaboration.
2. As such, SOS is committed to strong corporate governance and to promote an open and transparent organisational culture, where members, employees, clients, vendors and other stakeholders are provided with an avenue to express concerns on any serious wrongdoing or malpractice related to fraud, controls, ethics and any other matter within the organisation.
3. In line with this commitment, and the Code of Governance For Charities and Institutions of a Public Character, the Board approved and adopted this Whistle-blowing Policy to ensure that arrangements are in place for whistle-blowers who may raise concerns about actual or possible improprieties without fear of reprisals in any form.
4. The Audit & Risk Committee (hereafter known as “The A&R Committee”) of the SOS shall have the overall authority and oversight of this Policy. The A&R Committee may in its absolute discretion delegate the investigation of the whistle-blowing reports and implementation of this Policy to such person as it deems fit.
5. It is the responsibility of all Board Members, officers, employees and members of SOS to report any actual or possible improprieties.
PURPOSE AND SCOPE
6. This Policy aims to achieve the following:
a. Establish a trusted avenue for members, employees, clients, vendors and other stakeholders to report serious wrongdoings or concerns without fear of reprisals when whistleblowing in good faith.
b. Ensure arrangements are in place to facilitate independent investigation of the reported concern and that appropriate follow-up actions will be taken.
c. Encourage members and employees to raise concerns at an early stage to an internal authority so that actions can be taken immediately to resolve them.
7. Improprieties may include, but are not limited to, the following:
a. General malpractice such as immoral, illegal or unethical conduct;
b. Actual or potential infractions of SOS’ policy or Code of Conduct;
c. Wrongdoings, corruption, acts of fraud, theft and/or misuse of SOS’ properties;
d. Act or conduct which is a criminal offence or breach of law;
e. Conflict of interest without disclosure;
f. An individual abusing his/her official SOS position in connection with unauthorised activity for financial or non-financial gain;
g. Concerns about SOS’ accounting or internal control matters;
h. Concealing information about any of the above improprieties;
i. Any other matters which may cause financial or non-financial loss to SOS or damage SOS’ reputation.
8. This Policy does not and cannot reasonably detail or cover every situation that should be reported. If you are in any doubt as to how you should apply any provisions of this Policy, you are strongly encouraged to seek guidance from your immediate supervisor, Senior Management or the A&R Committee.
WHISTLE BLOWING REPORTING AND CHANNELS TO RAISE CONCERN
9. Whistle-blowers can email or write a letter regarding their concerns to:
Private & Confidential The Audit and Risk Committee Samaritans of Singapore Limited 10 Cantonment Close, #01-01 Singapore 080010
10. A whistle-blower is encouraged to include his or her name as well as relevant contact details in case further clarification or information is required. To enable an investigation of the concern, the individual should provide details such as the parties involved, date and time of incident, description of incident and evidence or any other information to substantiate the concern.
11. All concerns raised will be independently reviewed by the A&R Committee. All information provided will be kept strictly confidential.
12. Whistle-blowers making any such reports should ensure that they do so in good faith and in the best interest of SOS and not with any malicious intent. Whistle-blowers may be the subject of disciplinary or other legal action if the reports or allegations are malicious or simply to cause anger, irritation or distress.
PROTECTION AGAINST REPRISALS AND CONFIDENTIALITY
Harassment or Retaliation
13. SOS recognizes that the decision to report a concern can be difficult, not least because of the fear of reprisal from those responsible for the improprieties. SOS will not tolerate harassment or victimization and will take reasonable and appropriate action to protect whistle-blowers when they raise concerns in good faith.
14. SOS will do its best to protect a whistle-blower’s identity when the whistle-blower indicates that he or she does not want his or her identity to be disclosed. It must be appreciated though that the investigation process may require the A&R Committee to reveal their source of information and the whistle-blower’s report may be used as evidence.
15. SOS strongly encourages whistle-blowers to put their names to their reports. SOS is committed to protecting whistle-blowers who make reports under this policy, so there should be no need to report anonymously. Subsequent investigations may be hindered if contact cannot be made with the whistle-blower to obtain clarification or further information.
16. SOS is committed to respecting the rights of its employees/whistle-blowers, which includes the right of an accused person, if absolutely necessary, to know the identity of his or her accuser. The identity of the whistle-blower would not be disclosed unless it is absolutely necessary for the purpose of the investigation and/or subsequent action, and never disclosed without prior discussion with the whistle-blower making the report.
HANDLING OF COMPLAINTS
17. Any concern raised, or information provided, will be thoroughly investigated, but consideration will be given to the nature and quality of information provided. Upon receipt of a whistle-blower’s report, the A&R Committee will acknowledge that the concern raised has been received.
18. The A&R Committee will conduct the initial investigation into the concerns received. Subsequently, the matters raised may be:
a. investigated internally; b. referred to an external party; c. referred to appropriate law enforcement agencies; and/or d. investigated by an independent external party.
19. All findings of the investigations shall be reported to the A&R Committee for their attention and necessary action.
20. SOS may modify this Policy to maintain compliance with applicable laws and regulations or accommodate organizational changes within SOS.