Whistleblowing Policy

WHISTLEBLOWING POLICY

This Whistleblowing Policy forms an important aspect of accountability and transparency in our operations by providing an avenue for interested parties to responsibly raise concerns, in confidence, about possible wrong-doing or improprieties in Prison Fellowship Singapore Ltd (PFS) or its IPC Fund, Seventy Times Seven (70x7) with the assurance that they will be protected from victimisation for whistleblowing in good faith.

WHISTLEBLOWING COMMITTEE ("COMMITTEE")

  • The Committee will be chaired by the Audit and Governance Committee (AGC) Chairperson and its members will be appointed by the Board subject to the issue(s) raised.

  • If there is a risk of any Committee member having a conflict of interest, whether real or perceived, the Board Chairperson will determine whether that member is to be excluded from the Committee.

  • The Committee can co-opt any party with the relevant subject matter expertise to assist in the investigation.

  • The Committee will evaluate the complaint and recommend the appropriate response to the Board.

 

GENERAL GUIDELINES FOR WHISTLEBLOWING

This policy covers, and is directed at matters such as but are not limited to:

  • Concerns about PFS’ or 70x7’s accounting, internal controls or auditing matters;

  • Impropriety, corruption, acts of fraud and theft;

  • Conduct that is a criminal offence or breach of law;

  • Serious conflict of interest without disclosure;

  • Any other serious improper matters that may cause financial or non-financial losses to PFS or 70x7, or damage to PFS’ or 70x7’s reputation;

  • Fraud or the making of fraudulent statements to anyone that affects PFS or 70x7 as a whole;

  • Distinct effort to mislead, deceive, manipulate, coerce, or fraudulently influence any internal or external accountant or auditor in connection with the preparation, examination, audit or review of any financial statements or records of PFS or 70x7; or

  • Concealing information about any of the above malpractice or misconduct.

General complaints and grievances over service quality, ministry deficiency, operational matters and policies are not subject matters for whistleblowing. These concerns should be taken up with the Executive Director or the respective Team Lead(s).

CONFIDENTIALY & DISCLOSURES

PFS encourages a whistleblower to include his/her contact details in the report to facilitate investigation. Concerns expressed anonymously are more difficult to act upon effectively, but may still be considered, after considering the seriousness and credibility of the issue raised and the likelihood of confirming the allegation from attributable sources and information provided. All concerns will be treated with strict confidentiality.

Exceptional circumstances under which information provided by a whistleblower may not be treated with strict confidentiality include:

  • Where PFS or 70x7 is under a legal obligation to disclose the information;

  • Where the information is already in the public domain;

  • Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice; or

  • Where the information is given to the Police or any relevant authorities for investigation.

In the event PFS or 70x7 is faced with a circumstance not covered by the above, and where the whistleblower’s identity is to be disclosed, PFS will endeavour to seek prior written consent.

WHISTLEBLOWING CHANNELS

Email to whistleblow@pfs.org.sg OR submit a sealed report to:

[Private & Confidential]

Attention to: Whistleblowing Committee Chairperson

Prison Fellowship Singapore, 1 Dorset Road, S219486,

Level 3, Reverend Canon Samuel Baboo Block.

All emails and reports will be channelled directly to the Whistleblowing Committee’s Chairperson.