Whistleblowing Policy

Principles

HCSA Community Services is committed to the highest possible standards of ethical, moral and legal conduct.

In line with this commitment and HCSA’s commitment to open communication, this policy aims to provide an avenue for employees and any other persons to raise genuine concerns about possible improprieties in matters of financial reporting and other malpractices at the earliest opportunity, and in an appropriate way.

The policy permits HCSA to address such reports by taking appropriate action, including, but not limited to, disciplining or terminating the employment and/or services of those responsible.

This policy not only covers possible improprieties in matters of financial reporting, but also:

• Professional malpractice, e.g. violation of intellectual property rights;
• Fraud or deliberately providing false or incorrect information in the preparation, evaluation, review, audit of financial accounts and records;
• Financial and non-financial malpractice, e.g. not observing proper procedures for tendering, funding or fund-raising;
• Ethical violations, e.g. conflict of interest;
• Inappropriate conduct which includes but is not limited to sexual and workplace harassment;
• Corruption, bribery or blackmail;
• Criminal offences;
• Failure to comply with a legal or regulatory obligation;
• Miscarriage of justice;
• Concealment of any of the above.

All concerns raised will be treated fairly and properly.

The policy provides that the Reporting Person will be treated in strict confidence and to the extent possible, be protected from any reprisal or victimisation, even if they are mistaken. HCSA does not however, extend this assurance to someone who malicious raises a matter they know to be untrue.

Whistleblowing Process

Reports and queries relating to whistleblowing complaints may be made through the following:

• Email: whistleblowing@hcsa.org.sg
• Post: Attention: Chair, HCSA Audit & Risk Committee, 1 Lorong 23 Geylang Singapore 388352
• In the event that no response/acknowledgement is received within 5 working days, the whistleblower is advised to send feedback via
  • HCSA Staff Feedback Form available on HCSA Staff Intranet, Hotspot, for HCSA Staff (https://forms.office.com/r/rsz2uehNUv); or
  • Email to enquiry@hcsa.org.sg for external parties,

and advise the Board Secretariat that a report has been sent to the Board President and/or Audit and Risk Committee Chair and/or Board Secretariat with the (i) email date, (ii) email subject and (iii) sender name or email address for reference.

In making a report, please provide the following information where possible: Name(s) of person(s)/organisation(s) involved;

• Description of the incident, including where, when and how the incident occurred;
• Frequency of occurrence of the incident;
• Details of any witnesses and evidence you are aware of;
• Value of any money or assets involved;
• Any other information that may substantiate the concern.

HCSA encourages employees and external parties to put their names to their allegations whenever possible. Concerns or irregularities expressed anonymously are more difficult to act upon effectively but they will be considered, taking into account the seriousness and credibility of the issues raised, and the likelihood of confirming the allegation from attributable sources and information provided.

The action taken will depend on the nature of the concern. HCSA’s Board will receive reports on each complaint and follow-up reports on actions taken.

Initial inquiries will be made to determine whether an investigation is appropriate, and the form that it should take. Some concerns may be resolved by agreed action without the need for investigation.

The named complainant will be given the opportunity to receive follow-up on their concerns with two weeks:

• Acknowledging that the concern was received;
• Indicating how the matter will be dealt with;
• Giving an estimate of the time that it will take for a final response;
• Telling them whether initial enquiries have been made;
• Telling them whether further investigations will follow, and if not, why not

Subject to legal constraints, the complainant will receive information about the outcome of any investigations. Details may or may not be provided depending on the sensitivity of the information.

Employees’ and any other persons’ identities will not be disclosed without prior consent (except where disclosure obligations are required under law and regulations). Where concerns are unable to be resolved without revealing the identity of the employee and nay other persons raising the concern, (e.g. if their evidence is required in court), HCSA will enter into a dialogue with the employee and any other persons concerned as to whether and how it can proceed.

Safeguards

HCSA prohibits discrimination, retaliation or harassment of any kind against a Reporting Person who submits a complaint or report in good faith.

If a Reporting Person believes that he/she is being subjected to discrimination, retaliation or harassment for having made a report under this Policy, he/she should immediately report those facts to the CEO. Reporting should be done promptly to facilitate investigation and the taking of appropriate action.

Handling of Complaints

HCSA reserves the right to refer any concerns or complaints to appropriate external regulatory authorities. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations.

If, at the conclusion of an investigation, HCSA determines that a violation has occurred, or the allegations are substantiated, effective remedial action commensurate with the severity of the offence will be taken.