Whistleblowing

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Cyber Youth Singapore

Whistle-blowing External Policy
OVERVIEW
To whistle-blow is to report concerns by volunteers or other stakeholders in CYS in good faith on misconduct or malpractice that may be detrimental to CYS and/ or public interest. Whistle-blowing is an essential part of sound governance.
The policy addresses the ARC Board’s commitment to proper ethical behaviour where volunteers and other stakeholders are encouraged to report concerns without fear of reprisal or unfair treatment.
PURPOSE
The purpose of the policy are to:
  • Provide guidelines and a process flow for conducting whistle-blowing investigations 
  • Provide proper channels for reporting any whistle-blowing concerns 
  • Encourage all individuals within the organization to report improper, unethical and inappropriate behaviour 
  • Provide assurance that all reports will be properly addressed, treated with confidentiality and there are adequate whistle-blower safeguards from reprisal in any form 
  • Promote and develop a culture of accountability, integrity and transparency
SCOPE

This policy is designed to enable volunteers and other relevant stakeholders to report any alleged concerns in good faith on misconduct or malpractice. 

A whistle-blowing concern pertains to any matters including CYS, volunteers of CYS, suppliers, event participants and the public at large. 

Whistleblowers can report on the following misdeeds or improprieties (not exhaustive)”

  1. Unethical and improper practices or alleged wrongful conduct or non-compliance in matters of financial reporting, internal control, code of conduct or other related matters. 
  2. Fraud or suspected fraud, thefts and dishonest acts or making fraudulent statements to stakeholders and regulatory authorities. 
  3. Corruption (accepting or giving bribes), theft and misuse of CYS’ properties, assets or resources.
  4. Misappropriation of funds. 
  5. Conflict of interest without disclosure.
  6. Disclosure of confidential information to external parties. 
  7. Concealment of information about any malpractice, misconduct or prohibited activities.
  8. Intimidation, discrimination or harassment of staff and other persons during the course of work or in the capacity as an CYS employee.
  9. Destruction, removal or inappropriate use of records and assets of CYS
  10. Sabotage of CYS’ IT system.
  11. Actions causing injury to person or loss or damage to CYS’ property.
  12. Abuse of power and authority
  13. Bullying and harassment 
  14. Disagreements among employees; and between employees and management 
PREREQUISITES

The ambit of reporting covers whistle-blowing concerns made in good faith either internally or externally. DIsciplinary action will be taken against employees for any false report made for personal gain or malicious motive. 

The report may be made in writing and sent via email using the standard “Form to Report a Whistle-Blowing Concern” (attached in Additional Materials) which contains information on what to report.

Whistle-blowers may email to speakup@cyberyouth.sg.  

For all reports, including those raised anonymously, CYS will maintain a proper register of all concerns received. CYS will send an acknowledgement of receipt to the whistle-blower, if the identity is provided, and all reported concerns will be assessed. The whistle-blower will also be provided with subsequent information on the follow-up processes (e.g. assessment, investigation and action) as appropriate.

Where the identity of the alleged person is known, timeframes for: 

  1. the escalation of alleged concern to the Whistle-blowing Governance Officer (or any designated person) would be within 5 working days of the receival of the report; 
  2. the formal acknowledgement of receipt would be provided within 3 weeks;
  3. any updates; and
  4. the closure of the inquiry would be provided within a reasonable timeframe following the investigation.
More specifically, (a) and (d) are considered in relation to anonymous alleged concern.
RESPONSIBILITIES

The ARC Board oversees whistle-blowing practices in CYS. The ARC Board would be assisted by a volunteer in charge (or Whistle-blowing Governance Officer) of the whistleblowing process who ensures that the procedures are carried out in accordance with the policy.

The primary stakeholders in the whistle-blowing policy include the ARC Board, whistle-blower, alleged party, volunteer receiving the report, investigator, Whistle-blowing Governance Officer and Head of Internal Audit.

CONFIDENTIALITY & PROTECTION

CYS respects the confidentiality of the whistle-blower and is committed to preserving confidentiality by keeping the report and case information secure and accessible only to designated persons. Aligned with the spirit of confidentiality, CYS allows anonymous reporting.

Confidentiality has two sides. Concurrently, the Whistle-blowing Governance Officer should ensure proper confidentiality safeguards of the report, while maintaining the confidentiality of those involved in the case.

If necessary or lawful circumstances dictate the disclosure of the whistle-blower’s identity, CYS must seek the whistle-blower’s consent.

CYS does not condone any reprisal, discrimination or harassment against whistle-blowers who report in good faith. It is committed to protecting whistle-blowers from threats to employment and any other threats of retaliatory action. Disciplinary actions will be taken against those who retaliate, harass or discriminate against whistle-blowers.

Internal Audit will maintain a log of all reported incidents or concerns, tracking their receipt, investigation and resolution.

Internal Audit will also maintain a record of all steps taken in connection with any investigation conducted of a reported incident, including investigations which are subsequently found to be unsubstantiated or cases dropped because of insufficient information.

MAINTENANCE AND IMPLEMENTATION

Any immediate feedback on this SOP can be provided to the Group Operations and Plans Office via email at grp.ops@cyberyouth.sg. The feedback email template can be found on page 3 of SOP-CEOO-02-01.

Besides the <Insert SOP Owner>, the <Insert other relevant responsible parties> will be responsible for the implementation of this SOP.

ADDITIONAL MATERIALS

Sample form to report a whistle-blowing concern

Whistle-blower’s details (It may be left blank if you wish to remain anonymous) 
Name, Designation, Department, Contact number and E-mail Address
Can you be contacted for more information? 
Alleged Party’s details 
Name, Designation, Department, Contact number and E-mail Address
Witness’ details (if any)
Name, Designation, Department, Contact number and E-mail Address
Concern/ Complaint
What misconduct occurred? 
Who committed the misconduct? 
When did it happen and when did you notice it?
Where did it happen?
Have you approached the person? If yes, what did he say?
Is there any evidence that you could provide us? 
Were other people involved? If yes, who are they? 
Do you have any other details or information which would assist us in the investigation?
Have you reported the incident internally or through any other channels? If yes, to whom have you made the report?