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Whistleblowing Policy

Whistleblowing Policy

Introduction

1.   Singapore Association for Mental Health (“SAMH”) is committed to maintain a high standard of compliance with accounting, financial reporting, internal controls, corporate governance and auditing requirements, and any legislation relating thereto.

2.   The Whistleblowing Policy (“Policy”) aims to provide an avenue for you to raise concerns and offer reassurance that you will be protected against reprisals or victimization or other adverse repercussions for whistleblowing in good faith.

Definitions

3.   Whistleblower:   A whistleblower is an individual who submits in good faith a complaint or concern to SAMH regarding any improper or illegal conduct with SAMH. The whistleblower’s role is as a reporting party, not an investigator or a finder of facts and does not determine the appropriate corrective or remedial action that may be warranted.

4.   Good faith:   Good faith is evident when the report is made without malice or consideration of personal benefit and you have a reasonable basis to believe that the report is true. However, a report does not have to be proven to be true to be made in good faith. Good faith is lacking when the disclosure is known to be malicious or false.

Who is covered by this Policy

5.   This Policy applies to all SAMH permanent and contract employees, partners, volunteers, clients, any other stakeholders (as and when they may arise and are not hereinbefore specifically set out in this clause) and the general public.

Objectives

6.   The intended objectives of this Policy are to:

a) deter wrongdoing and to promote standards of good governance practices
b) provide a proper framework for any and all interested parties to raise concerns about actual or suspected improprieties in matters of financial reporting, irregularities or other matters and receive feedback on any action taken
c) reassure employees or external parties that they will be protected from reprisals or victimization for whistleblowing in good faith.
d) assist to develop a culture of openness, accountability and integrity.

Reportable Incidents

7.   Some examples of concerns covered by this Policy include, but are not limited to:

a) Impropriety, corruption, acts of fraud, theft and/misuse of SAMH’s properties, assets or resources;
b) An individual abusing his official SAMH position in connection with unauthorised activity for financial or non-financial gain;
c) A failure to comply with a legal obligation (eg breach of a contractual or other common law obligation, statutory duty or requirement, malpractice or breach of a code of conduct);
d) Concerns about SAMH’s accounting or internal controls matters;
e) Breach of or failure to implement or comply with SAMH’s policies or code of conduct;
f) Serious conflict of interest without disclosure;
g) Intentional provision of incorrect information to public bodies;
h) Concealing information about any of the above malpractice or misconduct;
i) Any other serious improper matters which may cause financial or non-financial loss to SAMH or damage to SAMH’s reputation

8.   The above list is intended to give an indication of the kind of conduct which might be considered as “reportable”. In cases of doubt, you should seek to speak to your immediate supervisor or follow the procedure for reporting under this Policy.

Confidentiality

9.   The whistle-blower is encouraged to identify himself/herself when raising a concern or providing information. All concerns will be treated with strict confidentiality.

10.   Exceptional circumstances under which information provided by you could or would not be treated with strictest confidentiality include:

a) where SAMH is under a legal obligation to disclose the information provided;
b) where the information is already in the public domain;
c) where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice; or
d) where the information is given to the Police or other authorities for criminal investigation.

Whistleblowing Procedure

11.   Concerns or information should be provided in writing to the Executive Director or Audit Committee Chairman of Singapore Association for Mental Health at:

Email:
samh_whistleblow@samhealth.org.sg

Email to:
Executive Director/Audit Committee Chairman
Singapore Association for Mental Health
Blk 139, Potong Pasir Avenue 3, #01-132/136
Singapore 350139

12.   For external parties: you may raise your concerns directly to Executive Director or Audit Committee Chairman.

13.   If the whistleblower had provided his/her identity in the process of the complaint, then he/she will receive an acknowledgement of the complaint made.

14.   All whistle-blowing reports shall be investigated and resolved as soon as possible. Investigation should be completed and reported to the SAMH EXCO within 1 month.

15.   In the event that the complaint is against one particular Board Member or Executive Director, the President of the SAMH Board will make a recommendation to the Board on the action(s) to be taken. Those who the complaint was lodged against should not be directly or indirectly involved in the investigations, nor be present at any and all the meetings where the complaint is discussed and/or deliberated.

16.   Proper records regarding the case will be maintained at all stages.

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