Whistle Blowing Policy

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HCIS Whistle Blowing Policy

1.0 Introduction

Hwa Chong International School (hereinafter referred to as “HCIS” or the School) establishes this whistleblowing policy (the “Whistleblow Policy”) as a demonstration of its commitment to the highest possible standards of implementing good corporate governance practices and promoting an open and transparent culture, where stakeholders are provided a channel and set of tools to express concerns on any serious wrongdoing/malpractice in particular in relation to fraud, controls and ethics.

2.0 Objective

The School does not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing. This Whistle Blowing Policy (the “Policy”) is intended to provide a framework to promote responsible and secure whistleblowing without fear of reprisal, discrimination or adverse consequences.

Stakeholders of HCIS may use the procedures set out in the Policy to report, in good- faith, an actual or suspected malpractice and misconduct.

This Policy is not to be used as a channel for taking up personal grievances. Personal grievances should continue to be taken up and resolved through the appropriate administrative channels.

3.0 Scope

This policy applies to stakeholders belonging to any of the following categories:
- Board and School Management Committee members,
- Staff, including those who work part-time, Students and Parents,
- Vendors, including service providers, suppliers, consultants and agencies,
- Any other person with a direct association or working relationship with HCIS.
Malpractice and misconduct include but are not limited to:
- Corruption or bribery,
- Embezzlement, cheating or theft,
- Violation of laws and regulations,
- Irregularities in financial reporting, misstatements arising from reporting,
- Improper or unauthorised expenditure,
- Misuse of funds and resources,
- Abuse of power or authority,
- Conflict of interest without due disclosure,
- Aiding and abetting illegal activities,
- Unauthorised access and/or disclosure of information,
- Concealment or wilful 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 School,
- Any form of grievance,
- Any other conduct that may cause financial or non-financial loss or damage of reputation to the School.

4.0 Confidentiality and Protection

The School views whistle blowing seriously and will not allow the whistle-blower to be harassed or victimized and is committed to protect those who raise a concern in good faith. All such reports will be treated with strict confidence.
Anyone who has reported a suspicion of fraudulent practices in good faith and in compliance with the provisions of this policy shall not be prejudiced in his/her position in any way as a result of the reporting.
Every effort will be made to keep the identity of whistle-blowers confidential. However, the identity of a whistle-blower may be disclosed in appropriate circumstances such as where required to be revealed by law, where the whistle-blower has waived his or her right to confidentiality, where the identity has to be disclosed on a strictly confidential basis for the purpose of obtaining professional advice, it would be in the best interests of the School to reveal the identity of the whistle-blower.
In any case, if necessary or lawful circumstances dictate the disclosure of whistle-
blower’s identity the School must seek the whistle-blower’s consent.
If a whistle-blower is found to have made a report maliciously, that is intentionally false or untrue, or for personal gain, the School reserves the right to take disciplinary action against the whistle-blower.

5.0 Reporting

A stakeholder, or anyone, who suspects a wrongdoing in HCIS may write to the email address whistleblow@hcis.edu.sg, which will be managed by the Head of HR (or any other persons designated by the Board or Principal), providing the following information or using the standard form (Appendix A):
- The location of the alleged wrongdoing (i.e. which department);
- The key person(s) involved;
- The nature of the alleged wrongdoing;
- The details and evidence of the alleged wrongdoing, including but not limited to date or time period over which the suspected wrongdoing has occurred, photographs, documents, statements, and/or records;
- (Optional) The whistle-blower’s name, address (postal or email) and telephone number.
Concerns raised or information provided that is vague or insufficient can impede the investigation process and allegations may therefore not be pursued. To facilitate the School’s independent investigation, the whistle-blower must provide information to his/her best of knowledge.
Staff can raise their concerns to their immediate supervisor(s) or escalate their concerns to their next-level supervisor(s), or whoever is appropriate and accessible safely, based on the internal organisation structure.
For external parties, they can also raise their concerns directly to the Principal and/or Chairman of the School Management Committee and/or Chairman of Board of HCIS.

6.0 Handling Procedure

If the whistle-blower provides his/her identity and contact details, an acknowledgement will be sent to the whistle-blower within 5 working days.
Upon receiving the whistle-blowing report, the Head of HR will conduct an initial assessment and channel the report to the appropriate member(s) of the school management or Board who shall initiate an investigation to establish the facts.
The School may contact the whistle-blower and any party for further information during the course of the investigation.
The matters raised may be
- Investigated internally;
- Referred to the external auditors;
- Referred to appropriate law enforcement agencies;
- Investigated by an independent inquiry
Cases of very significant wrongdoing would be referred to the Board Chairman, who may appoint an Inquiry Committee to establish the validity of the complaint and recommend follow up actions (of a corrective, remedial, preventive, or regulatory enforcement nature).
In the case of an anonymous report, the complaint will be addressed taking into account the severity of the issues or matters raised, credibility of the complaint as may be determined from the tone of the report and any corroborative evidence presented. Having considered all information provided, the school management or Board may choose not to pursue the matter further if there is insufficient information available or where it is felt or determined that there is no merit to the complaint.
Investigation results will be kept confidential and will not be disclosed or discussed with anyone other than those with a legitimate need to know.

Form:

1. To view Whistle Blowing Standard Form Appendix A, please click here