WhistleBlowing Policy
Child at Street 11 Whistleblowing Policy and Procedure
Overview
Child at Street 11 (the “Centre”) is committed to strong corporate governance and promotes an open and transparent culture. Employees, vendors, parents, children under the care of the Centre and other stakeholders are provided an avenue to express concerns on any serious wrongdoing/ malpractice in particular in relation to fraud, controls and ethics.
This Whistleblowing Policy and Procedures (the “Policy”) is intended to provide a framework to promote responsible and secure whistleblowing without fear of adverse consequences. Whistleblower may use the procedures set out in the Policy to report any concern or complaint regarding questionable accounting or auditing matters, internal controls, inappropriate behavior of teachers and staff in handling the children under the care of the Centre, conflict of interest, or any other matters involving fraud, corruption and employee misconduct.
Reporting Procedure
Concerns have to be raised in writing or in-person to the Chairman of the Audit Committee (the “AC”). Emails can be sent to risk@street11.org.sg or audit@street11.org.sg. For in person reporting, the Chairman of AC is to follow up with a written report of the issue raised and have the concurrence of the whistleblower before a case is logged.
To effectively evaluate and investigate the issue raised, all critical information relating to the issue have to be provided and be as specific as possible. Key information includes details of the parties involved, dates or period of time, the type of concern, evidence substantiating the complaint, where possible, and contact details, in case further information is required.
Management of Whistleblowing Incidents
All instances of whistleblowing will be logged including anonymous with factual concerns or complaints and independently reviewed by the Chairman of AC. Where necessary, the issue is to be investigated by an Investigative Committee, which is led by a member of the AC appointed by its Chairman. Results of investigation will also be reported to the AC.
The whistleblower’s identity and the concerns raised will be kept confidential, unless as required by the law to reveal to parties such as lawyers, the police or investigators.
Chairman of AC is to report any whistleblowing incident to the Board at the conclusion of the investigation. Any follow-up action is to be discussed and decided by the Board.