Whistle Blowing Policy
1. Introduction
The Singapore Cancer Society (SCS) is committed to a high standard of compliance with accounting, financial reporting, internal controls and auditing requirements and any legislation relating thereto. In line with this commitment, this policy aims to provide an avenue for employees and external parties to raise concerns relating to actual or suspected wrongdoing and offer them reassurance that they will be protected from reprisals or victimisation for whistle blowing undertaken in good faith.
2. Scope
This policy applies to all SCS employees as well as to all external parties who have business relationships with SCS. These include clients/ beneficiaries, suppliers, contractors, service providers, applicants for employment, volunteers, donors and members of the general public.
3. Definition
Whistle blowing is defined as a deliberate, voluntary disclosure of individual or organisational malpractice by a person who has/ has had privileged access to information about an actual, suspected or anticipated wrongdoing within or by SCS, that is within SCS’s ability to control.
This policy is not intended for personal grievances regarding terms of employment, performance evaluations, or interpersonal conflicts. Such matters should be raised through the People & Culture (P&C) Department’s Grievances Procedures (ref: PM701).
4. Reportable Incidents
Below is a list of examples (though not exhaustive) of reportable incidents covered by this policy:
- Concerns about SCS’s accounting, internal controls or auditing matters;
- Impropriety, corruption, acts of fraud, theft and/misuse of the SCS’s properties, assets, or resources;
- Conduct which is an offence or breach of law;
- Conflicts of interest that have not been disclosed;
- Breach of SCS’s policies or Code of Conduct;
- Concealing information relating to any malpractice or misconduct;
- Fraud against members and/or donors, or making fraudulent statements to the Council, members of the public and government or state authorities;
5. Protection Against Reprisal And Confidentiality
Any individual who raises a concern or provides information in good faith relating to any actual, suspected or anticipated wrongdoing, shall be protected against retaliation, victimisation, dismissal, harassment, or any form of reprisal. Disciplinary action will be taken against staff who retaliate.
However, SCS shall not condone any frivolous, mischievous or malicious allegations. Employees, found making such allegations, shall be subject to disciplinary action in accordance with the SCS Human Resource policy on Code of Conduct.
Concerns or information about an actual, suspected or anticipated wrongdoing as well as the identity of the whistle‑blower shall be treated with strict confidentiality.
Exceptions to confidentiality include events where: –
- SCS is required by law to disclose such information;
- The information is already in the public domain;
- Information is given in strict confidence to legal or auditing professionals for the purpose of obtaining professional advice; and
- Information is given to the Police or relevant authorities for criminal investigation.
Feedback or information provided anonymously will be given due consideration by SCS but will be assessed and investigated based on their own merits.
6. Procedures
Feedback or reports are preferably to be made in writing, either in the form of a letter or email, and in detail, with supporting documents, setting out the background and history of events as well as the reason(s) for concern to:-
- Private & Confidential
- For the Attention of Audit and Risk Committee Chairman
- Singapore Cancer Society
- 30 Hospital Boulevard, #16-02,
- Singapore 168583
- Email Address: [email protected]
In the event that a report involves a member of the Audit and Risk Committee or the Board, the whistleblower may direct the report to an Alternative Officer, such as the Board Chairman (Email Address: [email protected]) or an external Independent Auditor.
SCS aims to acknowledge receipt of non-anonymous reports within 5 working days. For anonymous reports, acknowledgement will be subject to the availability of contact information provided.
7. Assessment and Investigation
All feedback will be assessed with due consideration given to the following:-
- Seriousness of the issue raised;
- Credibility of the concern or information; and
- Likelihood of substantiation.
If the matter is determined to be a personal employment grievance rather than a whistleblowing concern, it will be referred to the People & Culture (P&C) Department to be handled under the P&C Grievances Procedures (ref: PM701).
Depending on the nature of the concern raised or information provided, the investigation may involve one or more of the following individuals or entities:-
- The Audit and Risk Committee
- An independent Internal/ External Auditor, and/or
- External authorities (eg: The Police or Commercial Affairs Department) if criminal activity is suspected.
The amount of contact between the whistleblower and the investigating officer(s) will depend on the nature and clarity of the matter reported. To facilitate the investigation, reports should include, where possible: Date/time of incident, names of involved parties, specific evidence or witnesses, and any relevant documents. Further information may be sought from the whistleblower during the course of the investigation.
For non-anonymous reports, SCS aims to provide a status update on the investigation to the whistleblower within 30 working days of the initial acknowledgement, provided that such updates do not jeopardize the integrity of the investigation or violate any legal confidentiality requirements. The specific details of actions taken, if any, will remain confidential due to privacy laws (PDPA) and the whistleblower will be informed generally that the matter is being looked into.
8. Outcome of investigations
When the investigation is completed, the investigating officer(s) will report the findings to the Audit and Risk Committee (or Board Chairman) for its consideration and appropriate action.
9. Records Retention
All whistle‑blowing reports, investigation records, and outcomes shall be securely retained in accordance with SCS’s record retention and data protection policies (ref Para 11 PDPA and Data Protection Considerations).
10. Policy Review
This Policy shall be reviewed periodically to ensure ongoing relevance, effectiveness, and alignment with governance best practices and regulatory requirements.
11. PDPA and Data Protection Considerations
Whistle‑blowing reports and investigation materials may contain personal data (eg: names, contact details, employment information, and allegations). SCS will handle such information in a manner consistent with the Personal Data Protection Act 2012 (“PDPA”) and SCS’s data protection policies.
- Access controls: Limit access to reports and investigation files to authorised persons only (need‑to‑know basis).
- Data minimisation: Collect and use only information reasonably necessary to assess and investigate the report.
- Confidential storage: Store records securely (physical and electronic) with appropriate security measures.
- Controlled disclosure: Disclose information only where necessary for investigation, professional advice, or legal/regulatory obligations.
- Data retention and disposal: Retain records in accordance with the applicable retention schedule and dispose of them securely when no longer required.
- Data breach management: Escalate suspected data incidents promptly in accordance with SCS’s data incident management process, where necessary.
12. Record of Policy Changes:
| Version | Date | Remarks |
|---|---|---|
| 01 | 1 April 2010 | Set up a policy on Whistle Blowing |
| 02 | 6 March 2014 | Refinement to the scope and inclusion of seeking material gains/advantage from service providers and external parties. |
| 03 | 18 March 2026 | Overall update to the Policy and inclusion of PDPA and Data Protection Considerations. |