举报政策 WHISTLE BLOWING POLICY

长老会恩泽堂

PROVIDENCE PRESBYTERIAN CHURCH

WHISTLE BLOWING POLICY

Whistle blowing policy is part of the best practices of the Providence Presbyterian Church (PPC) to develop, promote and maintain high standards of corporate governance and risk management within the Church. The policy aims to provide an avenue for employees to raise concerns about possible improprieties within PPC which they become aware of and to provide reassurance that they will be protected from reprisals or victimization for whistle-blowing in good faith and without malice.

Whistle blowing is the reporting by an employee or third parties dealing with the church to the management of the PPC, of anyone within the workplace, who is suspected of carrying on any actions, activity, breach of conduct and ethics or omission or of any concerns regarding accounting or auditing matters, internal controls or internal accounting controls and other questionable Church matters or possible improprieties including but not limited to:

1. A criminal offence
2. Failure to fulfill a legal obligation
3. Abuse of power and authority
4. Deliberate non-compliance of corporate governance policy.
5. Corruption and bribery
6. Misappropriation of fund
7. Unlawful possession of classified documents
8. Actions that may lead to incorrect financial reporting
9. Actions that may pose dangers to the health and safety of any individual

All whistle blowing cases are treated seriously. However, cases which are anonymous may be more difficult to investigate and prove. Therefore, we encourage all whistleblowers to furnish their names and contact details so that their concerns and allegations can be verified and/or clarified expeditiously. Please see Whistleblowing Report Form under SCHEDULE 1.

REPORTING PROCEDURE

Before adopting the whistle blowing procedure, the staff should consider the reasonableness of his/her suspicion and the nature of the evidence (if any) in his/her possession.

For administrative staff, he/she should consider whether to discuss the matter with the church manager or the Chairman of the HR committee. For pastoral staff, he/she should consider whether to discuss the matter with the congregation Associate Senior Minister/Chairman of EDC.

Whistle blowing procedure is adopted if the above are deemed unsuitable as it may adversely affect the reporting staff.

For suspected wrongdoing within a congregation the whistle blower should contact the Associate Senior Minister/Chairman EDC or the secretary of EDC. The Associate Minister Senior Minister/Chairman EDC and the EDC secretary are to discuss and decide on the investigation process. The investigation report has to be submitted to the Session as soon as it is completed. Should the decision is not to investigate; the Chairman of the Session, the Session Clerk and the Audit Committee must be informed.

In the event that the concern of the whistle blowing is related to the Chairman or secretary of EDC, the whistle blower is to address the concern to PPC Senior Minister or the Session clerk. They will discuss and decide on the most appropriate investigation process. An internal investigation committee may be formed. If the matter may involve legal or criminal wrong doing, the audit committee must be informed as soon as possible so as to engage internal auditor to conduct the investigation.

If the concern is related to the Senior Minister/Session Chairman or the Session Clerk, the whistle blower should address the concern to the Audit Committee. The Audit Committee will look into the nature of the reporting and if necessary to engage internal auditor to conduct the investigation.

Church members do not fully understand the church management systems and processes, unlike full time employees. Church members are encouraged to raise any matters of concern to any of the deacons, elders, pastoral staff to clarify and understand better such matters of concern. If need be, the informed elders, deacons and pastoral staff can take up the matter through management process (via EDC or Session meetings) or, if necessary and warranted, whistle blow. Please see reporting flowchart under SCHEDULE 2.

Related Considerations

Confidentiality is essential to ensure confidence in the fairness and neutrality of the process, so as not to alert any potential wrong doer to the suspicion, as this may lead to him/her concealing evidence. Confidentiality may be lifted to rectify the situation and to put in place processes to minimize the risk of it recurring. Every effort will be made to protect the whistle blower’s identity, except that:

(a) the identity of the whistle blower, in the opinion of the investigation committee or Session or Audit Committee (as the case may be), is material to any investigation or is in the best interest of the Church;
(b) is required by law, or by the order or directive of a court of law, regulatory body to require such identity to be revealed;
(c) the identity is already public knowledge.

This Whistle blowing policy shall be incorporated into the Church’s Human Resource Manual and made available to all employees of the Church.

Any person who files a complaint which is frivolous, in bad faith, in abuse of these policies and procedures, with malicious or mischievous intent will not be protected by this Whistle blowing policy and may be subject to administrative and/or disciplinary action including but not limited to the termination of employment.

This Whistle blowing policy shall be read in conjunction with the Singapore Companies Act, Charities Act, and/or Code of Governance for Charities and IPCs and any relevant laws, regulations, rules, directives or guidelines ("Laws and Regulations"). In the event that any policy or procedure in this Whistle Blowing policy is inconsistent or in conflict with such Laws and Regulations, the latter shall prevail to the extent of such inconsistency or conflict.

The Audit Committee has the responsibility for ensuring the maintenance, regular review and updating of this policy. Revisions, amendments and alterations to this policy can only be implemented via approval by the Audit Committee and the Session. Changes will be notified in writing to Church employees when they occur.

SCHEDULE 1 – Whistleblowing Report Form View | Download >>
SCHEDULE 2 – Whistleblowing Reporting Flowchart View