Headed by the Audit and Risk Committee Chairman, the Whistle-Blowing Committee is responsible for ensuring that the Trust has an independent channel and appropriate procedures for the receipt, retention and handling of complaints about possible improprieties of the Trust’s affairs. The Whistle-Blowing Committee will consist of Independent directors, who are also members of the Audit and Risk Committee.
All employees of the Trust and any other persons (such as vendors, customers, business partners and other external parties) are encouraged to raise genuine concerns regarding possible improprieties in the conduct of business activities, financial reporting and other malpractices at the earliest opportunity, and in an appropriate way.
This policy is designed to:
- Support the Trust’s values; and
- Ensure that employees and any other persons can raise concerns without fear of reprisal; and
- Provide a transparent and confidential process for dealing with concerns.
This policy not only covers possible improprieties in matters of financial reporting, but also:
- Fraud; and
- Corruption, bribery or blackmail; and
- Criminal offences; and
- Failure to comply with a legal or regulatory obligation; and
- Miscarriage of justice; and
- Deliberate failure to follow/operate systems and procedures, which may put the assets or Trust’s reputation at risk; and
- Endangering the health and safety of an individual; and
- Concealment of any of the above.
- All concerns raised will be treated fairly and properly; and
- We will not tolerate the harassment or victimisation of anyone raising a genuine concern; and
- Any individual making a disclosure will retain their anonymity unless they agree otherwise; and
- We will ensure that any individual raising a concern is aware of who is handling the matter; and
- We will ensure that no one will be atrisk of suffering reprisal as a result of raising a concern even if they are mistaken. We do not however extend this assurance to someone who maliciously raises a matter they know to be untrue.
Procedures for Reporting of Concerns:
If any employee believes reasonably and in good faith that malpractice exists in the work place, then he or she should report this immediately to the CEO. However, if for any reason, they are reluctant to do so, then they should report their concerns to:
- An independent third party by calling the whistle-blowing hotline on 6828 9185. This is provided through the independent party who provides the employee care counselling and legal advice service. The concerns will be reported to the Trust without revealing the identity of the whistle-blower.
The Chairman of the Audit and Risk Committee, currently Michael Gray, particularly if employees and any other persons still have concerns. If they feel that the matter is so serious that it cannot be discussed with any of the above, they can also report suspected wrongdoings via:
- Regular mail or other means of delivery, addressed to the corporate address of the Trust, by which complaints may be submitted in a sealed envelope marked “Attention of the: Chairman, Whistle-Blowing Committee, FSL Trust Management Pte. Ltd. – Private and Confidential to be opened by addressee only”. The envelope will be forwarded, unopened, to the Audit and Risk Committee Chairman in his capacity as Chairman of the Whistle-Blowing Committee; and
- Email sent directly to the Chairman of the Whistle- Blowing Committee at email@example.com; and
- Telephone call to the mobile number of the Chairman of the Whistle-Blowing Committee at 9855 0055.
Handling of Concerns
Employees and any other persons, who have raised concerns internally, will be informed of who is handling the matter, how they can make contact with them and if there is any further assistance required. We will give as much feedback as we can without any infringement on a duty of confidence owed by us to someone else.
- 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 cannot be resolved without revealing the identity of the employee and any other persons raising the concern, (e.g., if their evidence is required in court), we will enter in to a dialogue with the all who are concerned to discuss how we can proceed.
In all cases, upon receipt of the concern, the Whistle-Blowing Committee shall:
- Acknowledge the receipt to the person reporting the concern (where the identity has been disclosed); and
- Make an initial assessment as to the prima facie merits; and
- Investigate the concerns raised expeditiously, without sacrificing thoroughness; and
- Inform the person reporting the concern (where the identity has been disclosed) in writing of the outcome of the investigations; and
- Ensure that the principles of due process and natural justice.
- If the Whistle-Blowing Committee deems it appropriate, they may engage, at the Trust’s expense, independent advisors such as lawyers and accountants who are unaffiliated with the Trust’s lawyers or external auditors to assist in its deliberations.
- Following the investigation and evaluation of the concern, the Whistle-Blowing Committee will prepare a written report on its finding, recommended disciplinary, remedial or other actions, if any.
Right of Appeal:
If someone who has reported a concern remains dissatisfied with the outcome of the investigation, they have a right of appeal on the following grounds:
- They believe the procedures have not been followed properly or; and
- They are convinced that the decision is one which no reasonable person could have reached.
The Chairman of the Board (or the Chairman of the Audit and Risk Committee, if the Whistle-Blowing allegation involves the Chairman) will appoint a person to hear the appeal. This will be an external lawyer or qualified accountant not involved with the Trust and who has experience with such matters.