Whistleblowing Policy

Objective

Tanah Merah is committed to a high standard of compliance and this Policy aims to provide an avenue for employees or any other persons to raise valid concerns or provide information on improprieties in matters of financial reporting, misconduct, or malpractices without fear of reprisals.

Definition

Whistleblowing is a deliberate voluntary disclosure of an organisation’s malpractice by a person who has or has had privileged access to data, events, or information not publicly known about an actual, suspected, or anticipated wrongdoing within Tanah Merah Country Club (TMCC) or by TMCC that is within its ability to control.

Reportable Events

Listed below are examples of reportable incidents covered by this Policy, but are not limited to:

Concerns about TMCC’s banking and treasury, procurement, accounting, business sensitive information, internal controls, or auditing matters.
Breach of or failure to implement or comply with the Policy or Code of Conduct.
Impropriety, corruption, acts of fraud, theft and/or misuse of TMCC’s properties, assets, or resources.
Conduct which is an offence or breach of law.
Abuse of power or authority.
Conflict of Interest without disclosure.
Intentional provision of incorrect information to press media and/or public bodies.
Making fraudulent statements to regulatory authorities.
Acts to mislead, deceive, manipulate, coerce, or fraudulently influence any internal or external accountant or auditor in connection with preparation, examination, audit or review of any financial statements and records of operations at TMCC.
Concealing information about any malpractice or misconduct.
Any other improper matters which may cause financial or non-financial loss to TMCC or damage TMCC’s reputation.

Reporting Channel

To facilitate investigations, Whistleblowers should provide their names and contact numbers with full details of alleged and valid concerns as the ability to investigate depends on the quality and adequacy of the information provided.

Such Concerns are preferably in writing either by letter or email, setting out the background and reason(s) are to be submitted to:

Chairman, Audit Committee
Email address: [email protected] OR

By Post to:

Chairman, Audit Committee
Tanah Merah Country Club
1 Tanah Merah Coast Road
Singapore 498722

All valid concerns or irregularities raised will be acknowledged and remain confidential throughout and beyond the investigation. The Audit Committee will review and recommend the appropriate course of action to be taken to the General Committee and Management.

TMCC assures that valid concerns raised, or information provided will be investigated, but consideration will be given on the severity and credibility of the concern or information provided and likelihood of confirming the concern or information with an attributable source.

Depending on the nature of the concern raised or information provided, the investigation may be conducted by one or more of these persons or entities:

Audit Committee.
External or Internal Auditor, and/or
Police or Commercial Affairs Department.
The Investigating Officer contacting the Whistleblower to provide additional information or clarification during the investigation.

Findings by the Investigation Officer will be reported to the Chairman of the Audit Committee.

Communication of Whistleblowing Policy

Management must ensure that the Whistleblowing Policy and procedures are communicated to, and understood by, all staff including new employees. In addition, a review of staff awareness of the Policy and procedures and a Manager’s understanding of how to act when a concern is raised must be conducted annually.

Confidentiality & Fair Treatment

Management must assure confidentiality and fair treatment when a concern is raised and take steps to prevent the victimisation of genuine Whistleblowers. Exceptional circumstances under which information is provided by the Whistleblower could or would not be treated with strictest confidentiality include:

Where TMCC is under a legal obligation to disclose the information provided.
Where the information is already in the public domain.
Where the information is given on a strictly confidential basis to legal or auditing professionals for the purposes of obtaining professional advice.
Where the information is given to the Police or other authorities for criminal investigation.

In the event where TMCC is faced with circumstances not covered under the above, and where the identity of the Whistleblower must be revealed, TMCC endeavours to discuss with the Whistleblower first.

Legal Implications of Whistleblowing Complaints

The Chairman of the Audit Committee must assess the legal implications (if any) of a whistleblowing complaint and communicate these to the General Committee and Club Chairman as there may be a legal requirement to report or hand over the matter to the regulatory or other authorities.