1. Introduction

This Whistle Blowing Policy (the “Policy”) aims to provide a framework for employees and external parties to report any concerns or complaints regarding any form of malpractice, wrongdoing or statutory non-compliance, including but not limited to questionable accounting or auditing matters, internal controls, disclosure matters, conflict of interest, collusion with competitors, unsafe work practices or any other matters involving fraud, corruption and employee misconduct.

The Policy allows for reporting by employees or external parties without fear of reprisal, discrimination or adverse consequences and it also permits POLWEL Co-operative Society Limited (“POLWEL”) to address such reports by taking the appropriate action, including, but not limited to, disciplining or terminating the employment and / or services of those responsible.

2. Scope

Any employee, contract staff, vendor, contractor, external party, applicant for employment, or member of the general public who notices, is aware of, or has any concerns about any actual or suspected wrongdoings committed by any POLWEL management staff, employee or contractor, can lodge a complaint.

Reportable incidents include, but are not limited to, the following improper or unethical activities, actual or suspected:

a. Corruption or bribery
b. Embezzlement, cheating or theft
c. Non-compliance with laws and regulations
d. Irregularities in financial reporting, questionable accounting or audit matters
e. Falsification or fraudulent alteration of documents (mandatory submissions to relevant authorities [e.g. IRAS, MCCY etc.], contractual agreements, invoices, purchase orders, etc.)
f. Misuse or misappropriation of funds and resources
g. Abuse or misrepresentation of power or authority
h. Conflict of interest without due disclosure
i. Breach or circumvention of internal policies
j. Unauthorised access or disclosure of information
k. Concealment or willful suppression of any malpractice or misconduct
l. Acts to mislead, deceive, manipulate, coerce or fraudulently influence the preparation, examination, audit or review of any assets and records
m. Unsafe work practices that endanger the health or safety of persons or environment
n. Acts of harassment
o. Professional malpractice, e.g. Violation of intellectual property rights
p. Acts of retaliation, intimidation or harassment, discrimination or unfair treatment against staff who have made an allegation or assisted in the investigation of an allegation
q. Any other conduct that may cause financial, non-financial loss or damage of POLWEL’s reputation
r. Aiding and abetting illegal activities or any of the above misconduct

3. Confidentiality

POLWEL strongly encourages the whistleblower to leave his / her name in the complaint so that POLWEL can get more information, seek clarifications and investigate the matter effectively. Concerns or complaints 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.

To the extent practicable and / or permitted by law, POLWEL will keep the identity of the whistleblower confidential. All concerns or irregularities raised will be treated with confidence and every effort will be made to keep the whole process confidential.

Exceptions where the identity of the whistleblower may need to be revealed include:

a. It is required by law to reveal the whistleblower’s identity,
b.It is necessary as part of the investigation process to reveal the whistleblower’s identity,
c. The whistleblower’s identity is disclosed on a strictly confidential basis to professional service providers for the purpose of obtaining professional advice; or
d. The whistleblower is required to testify as a witness in a civil or criminal trial.

4. Protection Against Retaliation

The Policy is meant to protect genuine whistleblowers who report any concerns in good faith against retaliation. POLWEL will take reasonable and appropriate action to protect all genuine whistleblowers who file a complaint in good faith. Retaliation includes but is not limited to termination, demotion, harassment, or any adverse action taken against an employee for making a report or participating in an investigation.

Any employee who believes he/she is being retaliated for whistleblowing in good faith can report the matter to Corporate Governance and Audit Sub-Committee with the available information on the suspected retaliation.

Conversely, if an allegation is made maliciously or for personal gain, appropriate action may be taken against the whistleblower. This may include disciplinary action (for employee) or reporting the matter to the police (for a third party).

The Policy is also not a route for taking up personal grievances. These should continue to be taken up directly with the supervisors concerned or the HR Department.

5. Procedures

Complaints may be raised with or information provided to:

By Post
Please mark the letter “Private & Confidential” and attention it to:

Chairman, Corporate Governance & Audit Committee
POLWEL Co-Operative Society Limited
175A Bencoolen Street, #12-08 Burlington Square, Singapore 189650

By Email
Email Address: AuditCom@polwel.org.sg

Please mark the subject header of the email “[Private & Confidential] Attention: Chairman, Corporate Governance & Audit Committee, POLWEL Co-operative Society Limited”

To the extent feasible, the whistleblower should provide the following information and details so that the matter can be assessed and investigated effectively:

a. Background and history of events (i.e. date, time and location of incident)
b. Name(s) of person(s) / company(ies) involved
c. How was the impropriety discovered
d. Value of any money or assets involved
e. Evidence (if any)
f. Any other information that may substantiate the concern

The whistleblower may refer to Annex A for a sample form to report a concern.

Assessment of the concern or information shall be made with due consideration given to the following factors:

a. Seriousness of the issue raised;
b. Credibility of the concern or information; and
c. Likelihood of confirming the concern or information from the attributable sources.

The Corporate Governance & Audit Committee will have overall oversight of this Policy and may at its absolute discretion delegate the investigation to such person (internal or external) as it deems fit, and / or may refer the matter to the authorities or regulators as it deems appropriate.

Further information may be sought from the whistleblower during the course of investigation. When the investigation is completed, the investigating officer(s) will report the findings to the Corporate Governance & Audit Committee for its necessary action.

POLWEL reserves the right to modify this Policy to maintain compliance with any applicable laws and regulations and / or in light of any restructuring of the organisation.

Annex A