Whistleblowing Policy & Procedure
1. Purpose & Scope
1.1 Kampong Kapor Methodist Church (KKMC) is committed to achieving and maintaining the highest standard of openness, probity and accountability in line with the Methodist Book of Discipline issued by the Methodist Church in Singapore. Employees and Volunteers (Church member) at all levels are expected to conduct themselves with integrity, impartiality and honesty. It is every employee’s and volunteer’s responsibility and in all the interest of the Methodist Church to ensure that any inappropriate behaviour that compromises KKMC and the wider public does not occur. It is also critical to maintain a good corporate image and raise the standard of corporate governance of KKMC.
1.2 This Whistleblowing Policy (the “Policy”) is intended to provide a framework to promote responsible and secure whistleblowing without fear of adverse consequences. The term “Whistleblowing” refers to a situation where an employee or volunteer decides to report serious concerns about any suspected misconduct, malpractice or irregularity which he or she has become aware of or genuinely suspects that KKMC has been or may become involved in. The Policy is designed to encourage employees and volunteers to raise serious concerns internally, in a responsible and constructive manner, rather than overlooking the problem or blowing the whistle outside.
1.3 The Policy is intended to assist employees or outside parties to disclose relevant information of suspected misconduct, malpractice or irregularity through confidential channels without fear of reprisal, discrimination or adverse consequences, and also permits KKMC to address such reports by taking appropriate action, including, but not limited to, disciplining or terminating the employment and/or services of those responsible.
1.4. The Policy is meant to protect genuine whistleblowers from any unfair treatment as a result of their report. Frivolous and bogus complaints will be disregarded. The Policy is also not a route for taking up personal grievances, question financial or business decisions of the LCEC or HR matters by the PPRSC. These should continue to be taken up directly with respective supervisors or heads.
2. Reporting Procedure
2.1. We encourage employees and outside 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. All concerns or irregularities raised will be treated with confidence and every effort will be made to ensure that confidentiality is maintained throughout the process.
2.2. Areas for whistleblowing can include;
a) Malpractice, impropriety or fraud relating to internal controls, accounting, auditing and financial matters,
b) Theft or Misappropriation of funds and classified documents, software programs,
c) Abuse and misrepresentation of power and authority as reflected by improper conduct or unethical behaviour likely to prejudice the standing of KKMC,
d) Breach of legal and regulatory requirements
e) Corruption and bribery
f) Undeclared conflict of interest
g) Discrimination on the basis of gender, race, disabilities
2.3. Concerns may be raised verbally or in writing. As it is essential for KKMC to have all critical information and /or supporting documents, emails and videos in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible. The complaint should include details of the parties involved, dates or period of time, the type of concern, evidence substantiating the complaint, where possible, and contact details, in case further information is required. The whistleblowing report should be directed to the Chairman of the Governance Committee (GC) herein known as the Receiving Officer. The contact of the Receiving Officer is set out at the end of the Policy.
2.4 The Receiving Officer will review the report and decide how the investigation should proceed. Depending on the circumstances, the GC may consider nominating an appropriate investigating officer or set up a special committee to investigate the matter independently.
2.5. Chairman of the GC or the person designated to investigate the complaint will write to the complainant whenever reasonably practicable of the concern being received:
i) acknowledging that the concern has been received
ii) advising whether or not the matter is to be investigated and if so what the nature of the investigation will be
iii) giving an estimate of how long the investigation will take to provide a final response, telling the complainant whether any initial inquiries have been made and whether any further investigation will take place and if not why not
2.6 If, at the conclusion of an investigation, Chairman of the GC determines that a violation has occurred or the allegations are substantiated, he will submit a report to the LCEC and/or PPRSC with a recommendation for effective remedial action commensurate with the severity of the offence will be taken.
3.1. KKMC prohibits discrimination, retaliation or harassment of any kind against a whistleblower who submits a complaint or report in good faith. If a whistleblower believes that he or she is being subjected to discrimination, retaliation or harassment for having made a report under this Policy, he or she should immediately report those facts to the Chairman of the GC. Reporting should be done promptly to facilitate investigation and the taking of appropriate action.
3.2. At the appropriate time, the party making the report/complaint may need to come forward as a witness. If an employee or outside party makes an allegation in good faith but it is not confirmed by the investigation, no action will be taken against him or her. If, however, an employee has made an allegation frivolously, maliciously or for personal gain, disciplinary action may be taken against him or her. Likewise, if investigations reveal that the outside party making the complaint had done so maliciously or for personal gain, appropriate action, including reporting the matter to the police, may be taken.
3.3 KKMC 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. Employees who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.
Receiving Officer: “Chairman of the Governance Committee”
(1) Letter to be addressed to:
Chairman of the Governance Committee
Kampong Kapor Methodist Church
1 Kampong Kapor Road
(2) Email: email@example.com
To ensure confidentiality, the letter / email should be titled:
“Strictly Private and Confidential – To be opened by Addressee Only”