Introduction

Rainbow Centre (RC) is committed to high standards of corporate governance and compliance with all laws and regulatory requirements. RC does not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing by employees in the course of their work.  

This policy is intended to provide a framework to promote responsible and secure whistleblowing without fear of adverse consequences and sets forth the procedures for how RC will conduct any necessary investigation(s).

Definition

Whistle blowing is defined as a deliberate, voluntary disclosure of individual or organisational malpractice by a person who has or has had privileged access to data, events, or information about an actual, suspected, or anticipated wrongdoing within or by RC that is within its ability to control.

Purpose and Scope

This policy applies to all employees as well as to all external parties who have business relationships with RC. These parties include customers, suppliers, contractors, applicants for employment, and the general public.

The policy serves to:

• deter wrongdoing and promote standards of good practices within RC;
• develop a culture of openness, accountability, and integrity;
• allow employees or members of the public to report perceived incidents of malpractice, without fear of reprisal, discrimination or adverse consequence; and
• permit RC to address complaints by taking appropriate action and make room for continuous organisational improvement.  

Reportable Incidents

The issues which may be raised covers such following wrongdoings, although not limited to these:

1. Fraud

This generally relates to the use of deception or misrepresentation to obtain an unjust advantage.  It can also involve the theft or misappropriation of RC’s property and/or assets.

2. Corrupt Conduct

Corrupt conduct can take many forms including seeking, obtaining or offering secret commissions, theft, embezzlement, forgery, misuse of information, documents or materials acquired in the course of employment and dishonest performance of functions.

3. Questionable Accounting and Auditing Practices

Broadly, this refers to practices that do not comply with accounting or auditing standards, or are fraudulent, dishonest or deceptive.

4. Adverse Behaviour

This can involve illegal behaviour, such as violence or threatened violence, criminal damage against property, and serious breaches against RC’s code of conduct.

Reporting Channel

Complaints may be raised in writing to the Receiving Investigation Officer. 

The contact details of the Receiving Investigation Officer are as follows:

Private & Confidential

Receiving Investigation Officer 

Planning and Organisational Excellence

Rainbow Centre, Singapore

501 Margaret Drive Singapore 149306

Or email: ReceivingInvestigationOfficer@rainbowcentre.org.sg

As it is essential for the Receiving Investigation Officer to have all critical information 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 following details where relevant should be included:

• the alleged act or behaviour or incident that occurred;
• details of the parties involved;
• dates or period of time during which the alleged act / behaviour or incident occurred;
• evidence substantiating the complaint, where possible, and 
• contact details, in the event further information is required.

RC encourages employees and members of the public to identify themselves and provide their contact details when reporting a complaint. 

Nonetheless, anonymous complaints will be considered, taking into account the seriousness and credibility of the issues raised, and the likelihood of confirming the allegation through sources and information provided. 

Management of Complaints

All reports received will be acknowledged and reviewed by the Receiving Investigation Officer within a reasonable timeframe. The Receiving Officer shall convey all complaints received to the Executive Director.

Depending on the nature and severity of the complaint, RC will undertake varying levels of inquiry either through 

• the relevant RC department; or 
• through an independent Inquiry Panel appointed by the Executive Director, Chairman of Audit Committee, or President of the Board of Governance.

In the event that it is deemed necessary, the Receiving Investigation Officer will escalate the complaint to both the Chairman of the Audit Committee and President of the Board of Governance.

Management of Confidential Information

All complaints received will be treated with confidence and every effort will be made to ensure that confidentiality is maintained throughout the investigation process.

However, RC may be required to disclose confidential information to third parties in exceptional cases. These include:

• where RC is under a legal obligation to disclose the information provided;
• where the information is public knowledge, or is already available in the public domain;
• where the information is given on a strictly confidential basis to legal or auditing professionals for the purposes of obtaining professional advice; or
• where the information is given to the Police or other authorities as part of investigations into criminal activity.

Disclosure of Information by RC

RC reserves the right to determine the amount of information deemed relevant to disclose to the following:

1. Person(s) implicated in the incident or complaint
2. The whistleblower(s)
3. All other parties involved in the incident or complaint
4. Employees
5. Stakeholders, including clients

Safeguards

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.