Safeguarding Integrity: Our Whistle-Blowing Policy
Introduction
United Ceres College (UCC) is committed to conducting business consistent with high standards of corporate governance and in compliance with all laws and regulatory requirements. Therefore, we welcome information and feedback that may protect the interests of the College and its stakeholders while maintaining our commitment. The whistle-blowing policy (“policy”) was first established to provide employees and external parties a confidential, neutral, and independent channel to report or provide feedback on their concerns related to the College.
When Should You Whistle-blow?
- Generally, the best way to communicate is by direct contact with Management; however, there may be occasions when you wish to discuss important issues but do not want your name or identity known by Management.
- You should raise your concern at an early stage when you have a genuine concern rather than wait for proof.
Who Can Whistle-blow And What Can You Whistle-blow?
- Employees and external parties, such as students, parents, suppliers, contractors, and other stakeholders, may use this policy to report or provide feedback on any of the following:
- Corruption or bribery;
- Embezzlement or cheating or theft;
- Violation of laws and regulations;
- Irregularities in financial reporting, misstatements arising from misappropriation of assets;
- Improper or unauthorized expenditures;
- Misuse of funds and resources;
- Abuse of power or authority;
- Conflict of interest without due disclosure;
- Breach or circumvention of internal policies;
- Aiding and abetting illegal activities;
- Unauthorized access and/or disclosure of information;
- Concealment or willful suppression of any malpractice or misconduct;
- Acts to mislead, deceive, manipulate, coerce or fraudulently influence the preparation, examination, audit or review of any assets and records of the College;
- Endangerment to health or safety of persons or environment;
- Any form of harassment;
- Academic or professional malpractice e.g. violation of intellectual property rights or failure of integrity in research;
- Any other conduct that may cause financial, non-financial loss or damage of reputation to UCC.
- This policy will not address an issue covered by any trade union agreement or that should be dealt with by applicable law.
- This policy does not absolve you from your duty of confidentiality and care in the course of your work, nor is it a route for taking up a grievance about a personal situation.
How Will Your Report And Information Be Maintained?
- All reports raised will be treated with confidence, and every effort will be made to ensure that confidentiality is maintained throughout the process.
- Your personal data (if provided by you) will be protected in accordance with the Personal Data Protection Act of Singapore and will not be disclosed without your consent unless disclosure is compelled by a court of law or there appears to be imminent risk of serious harm if not disclosed.
Can You Make An Anonymous Report?
- We recognize that you may want to raise a concern in confidence under this policy, and we will consider, as far as is reasonably practicable, reports raised anonymously. If you do not reveal who you are, we will be unable to respond to you, and it will also make the task of investigating your report or feedback more difficult and less effective.
- A whistleblower has the option to identify himself/herself or remain anonymous. However, concerns expressed or information provided anonymously will be investigated on the basis of their merits. Vague or insufficient information can impede the investigation process and consequently allegations may not be pursued.
- The outcome of the investigation hinges on your report. Therefore, if you choose to remain anonymous and do not provide any evidence that we can independently verify, your report may or may not be investigated at the discretion of the Audit & Risk Committee.
- Your report may eventually lead to the protection of the College’s reputation and/or the prevention/recovery of any financial loss for which we may consider a commendation provided you reveal your identity.
What Happens After You Make A Report?
- All reports will be evaluated within a reasonable timeframe, and after due consideration, a decision will be made whether to proceed with a formal investigation. The formal investigation may be conducted by the Internal Audit Department or directed to a department/business unit best placed to address it. Guidance may be sought from the Audit & Risk Committee, Principal, and/or other appropriate parties depending on the matters reported.
- Your report will be acknowledged in writing, and you will be informed as to:
- Who is handling your report; and
- How you can contact the person handling the report.
- You may be contacted if further assistance/information is required from you.
- The person handling the report may write to you summarizing your concerns and setting out what is likely to happen next.
- Once the investigation is completed, you will be advised of the outcome in writing. Please note that it may not be possible to tell you the precise action taken.
- All whistle-blowing cases will be reported to the Audit & Risk Committee.
- We have zero tolerance for unethical conduct and acts which are non-compliant with regulatory requirements or internal policies. Any employee found guilty of such conduct and acts will be dealt with swiftly, and appropriate cases will be reported to the relevant authorities.
How Long Will It Take To Address Your Report?
Less complicated issues are processed within 10 to 20 working days. However, to process more complex issues, Management may need additional time. In those cases, the person handling the report will notify you.
How Will You Be Protected After Making A Report?
- This policy provides assurance to you that you will not be victimized nor taken to task if you have acted in good faith and made the report with no malicious intent.
- We do not tolerate retaliatory action (i.e., harassment, intimidation, or victimization) against anyone raising a genuine concern. Employees found to have engaged in retaliatory conduct will be subject to disciplinary action, i.e., written warnings up to and including termination of employment.
- Please inform the investigating officer if you have been subjected to any retaliatory action.
- No person should be intimidated or restrained from reporting any impropriety.
- The identity of the complainant/informant will be kept confidential, with the exception of the following:
- By law required to reveal;
- The whistleblower has waived his/her rights to confidentiality;
- The identity of the complainant/informant is already publicly known;
- Information is given on a strictly confidential basis for the purpose of obtaining professional advice;
- A whistleblower who acts and makes disclosures in good faith will be protected against reprisals. Victimization of the whistleblower is viewed seriously and will not be tolerated and anyone found guilty of this will be disciplined. In the event that a whistleblower is treated unfairly, he or she may raise a complaint to the Principal, in which an investigation may be conducted. The investigation team will consist of members who are not part of the initial Committee of Inquiry, and will be decided by the Principal.The Board of Trustees opined that it would be in the best interest of the College to disclose the identity.
- If, however, an allegation is made frivolously, mischievously, maliciously, or for personal gain, disciplinary action may be taken against the complainant to deter any abuse of the Policy. Similarly, anyone who condones wrongdoing through willful suppression or concealment of relevant information or interferes with the investigation may be disciplined.
Why You Should Not Make A False Or Frivolous Report?
- Disciplinary action, i.e., written warnings up to and including termination of employment, will be taken against anyone who maliciously or frivolously raises a report that is known to be untrue.
- We may refer malicious or frivolous reports raised by external parties which are known to be untrue to the relevant authorities.
What Information Should You Provide When Contacting Us?
- Please declare at the onset if you have any personal interest in the report.
- Please provide specific details of your concern such as:
- What misconduct/improper activity occurred?
- Who is/are involved in the misconduct/improper activity?
- When did it happen and is it still happening?
- When did you notice it?
- Where did it happen?
- How did it happen?
How To Contact Us?
Please raise your concern either by: Writing to us at: United Ceres College [Address] Attention: Head, Internal Audit (Private and Confidential) Sending an e-mail to: [email protected]
Amendment To The Policy
We reserve the right to update this policy as and when it is deemed necessary.
Effective Date: 1 July 2020
Last Updated: 15 March 2024
