Beautiful People is committed to upholding high standards of corporate governance and work practices. As an enhancement to the internal control system, a whistle blowing policy is in place for the reporting of any malpractice, illegal act or omission by management, staff, Mentors, Mentees, Board of Directors, both internal and external stakeholders that contribute to or have a vested interest in Beautiful People’s operations, programmes and fundraising activities.
The whistleblowing policy enables Beautiful People and its management to be informed of any acts of misdeed at an early stage and to take appropriate actions on the concerns reported, so as to avoid or minimize negative consequences. It also serves as a strong deterrent for fraud and other uBeautiful Peopleceptable conduct or practices.
The policy aims to:
a. Provide channels for reporting alleged or suspected fraudulent activities.
b. Provide guidelines and a process flow for conducting whistleblowing investigations.
c. Assure whistleblowers that they will be protected from reprisals or victimisation for whistleblowing in good faith.
This policy applies to all Beautiful People’s management, staff, Mentors, Mentees, Board of Directors, both internal and external stakeholders that contribute to or have a vested interest in Beautiful People’s operations, programmes and fundraising activities.
Rationale for Implementing Policy
All levels of management have the responsibility for establishing and maintaining effective internal controls to prevent, deter and detect fraud. They are expected to stay alert, recognise the risks and exposures inherent in their areas of responsibility, and be aware of the indicators of fraudulent acts.
All Beautiful People staff and internal stakeholders have a duty to report concerns which they may have, or where they have been provided with reliable information, about possible misdeeds or improprieties committed by any staff and internal stakeholders of all levels in Beautiful People.
Scope of Policy
Whistleblowers can report on the following misdeeds or improprieties (not exhaustive):
a) Unethical and improper practices or alleged wrongful conduct or non-compliance in matters of financial reporting, internal control, code of conduct or other related matters.
b) Fraud or suspected fraud, thefts and dishonest acts or making fraudulent statements to stakeholders and regulatory authorities.
c) Corruption (accepting or giving bribes), theft and misuse of Beautiful People’s properties, assets or resources.
d) Misappropriation of funds.
e) Preferential treatment to partner organizations, donors, sponsors, grant recipients and intermediaries (such as venue operators and suppliers, etc).
f) Conflict of interest without disclosure.
g) Disclosure of confidential information to external parties, defined as external stakeholders that contribute to or have a vested interest in Beautiful People’s operations, programmes and fundraising activities.
h) Concealment of information about any malpractice, misconduct or prohibited activities.
i) Intimidation, discrimination or harassment of staff and other persons during the course of work or in the capacity as a Beautiful People employee.
j) Destruction, removal or inappropriate use of records and assets of Beautiful People
k) Sabotage of Beautiful People’s IT system.
l) Actions causing injury to a person or loss or damage to Beautiful People’s property.
m) Abuse of power and authority
The whistleblowing policy does not apply to staff grievances or complaints relating to job performance and terms and conditions of employment, of which are administered by the People Committee.
Reporting Structure and Responsibilities
All reports must be made formally in writing (letter or email) with full details on the history of the event and reasons for concern and an officer must identify himself/ herself when making the report. In the case of whistleblowers who are members of staff, staff are expected to report wrongdoing if he/she has sufficient grounds to believe that a wrongdoing has been committed, even if he has been instructed by his supervisor not to make a report. Any Staff member who condones wrongdoing through willful suppression or concealment of relevant information shall be disciplined
Whistleblowers can choose to raise their concern or make any reports via the following channels:
Attn to: The Audit Committee – firstname.lastname@example.org
Mail Attn to: The Audit Committee
183 Jalan Pelikat #B2-02 The Promenade@Pelikat,
Confidentiality and Protection for Whistleblower
A whistle-blower is encouraged to include his or her name as well as relevant contact details in case further clarification or information is required.The identity of the whistleblower will be kept confidential, unless required by the court or other regulatory authorities to disclose the identity. Where the whistleblower’s identity is to be revealed, the Audit Committee and Management will endeavor to discuss with the whistleblower first.
However, there are exceptional circumstances under which information could/would not be treated with strictest confidentiality such as when:
- Beautiful People is under a legal obligation to disclose the information provided
- Information is already in the public domain
- Information is given on a strictly confidential basis to legal/ auditing or other professionals
- Information is given to the Police or any other Authorities
The number of staff involved in the investigation will be kept to a minimum so as to ensure confidentiality. This will also prevent leakage of information.
To enable an investigation of the concern, the individual should provide details such as the parties involved, date and time of incident, description of incident and evidence or any other information to substantiate the concern.
For whistleblowers who are Beautiful People staff, assurance will be made for their protection under employment even if the report turns out to be unfounded but made in good faith. Staff who has sufficient grounds to believe that he/she is being unfairly treated as a result of having made such a report or given evidence as a witness in respect of the wrongdoing may submit a complaint via the channels listed in paragraph 11 by filling up the reporting form found in Annex B. Whistle-blowers shall be the subject of disciplinary or other legal action if the reports or allegations are malicious or simply to cause anger, irritation or distress.
Retention of Records
The Audit Committee will maintain a log of all reported incidents or concerns, tracking their receipt, investigation and resolution.
The Audit Committee will also maintain a record of all steps taken in connection with any investigation conducted of a reported incident, including investigations which are subsequently found to be unsubstantiated or cases dropped because of insufficient information.
How will Beautiful People Respond
Any legitimate concern raised or information provided will be reviewed and investigated if deemed necessary, taking into the consideration the following:
- Severity of the issue raised
- Credibility of the concern or information; and
- Likelihood of confirming the concern or information from attributable sources
Depending on the nature of the concern raised or information provided, the investigation may be conducted or referred to the relevant persons or entities:
- The Audit Committee
- The Investigative Team (scope will be defined according to the case)
- The External or Internal Auditor
- Forensic Professionals
- The Police or Commercial Affairs Department; and/or
- The Corrupt Practices Investigation Bureau
Investigations and follow-up actions for all cases will be reported to the Audit Committee.
The Audit Committee is responsible for the assessment of all the concerns raised, including those which are anonymous in nature.
The Audit Committee will examine whether the reported concerns raised are appropriate (i.e. they are not grievances), information provided is adequate to facilitate in the assessment and the nature of concerns (e.g. threats to health and safety, breach of laws, ethical code and fraud) to establish their severity and implication to the charity. Based on the severity of alleged wrongdoing, Beautiful People reserves the right to not pursue further action/investigations. Likewise if the alleged offender is not named, Beautiful People may not pursue further action.
When the alleged person’s identity is not known (anonymous), attention should be made in relation to the likelihood of substantiating the allegation from the information provided and any relevant sources. Except for anonymous reports, the whistle-blowers may be contacted for clarification or further details on the information provided in the “Form to Report a Whistle-Blowing Concern”.
Where the identity of the alleged person is known, the guidance should include reasonable timeframes for: (a) the escalation of alleged concern to the Whistle-blowing Governance Officer (or any designated person) (e.g. within 24 hours); (b) the formal acknowledgement of receipt (e.g. within two weeks); (c) any updates; and (d) the closure of the inquiry.