Purpose and Objective

To facilitate the attainment of the highest possible standards of lawful/ethical behaviour and corporate governance at all levels, Singapore Swimming Club (the Club) has put in place a whistleblowing policy (the Policy). The Policy seeks to ensure that any member or staff of the Club or any other external party or persons (dealing with matters pertaining to the Club only) can bring any unethical or fraudulent practices or wrongdoings at the Club and its workplace to light so that appropriate actions can be taken for damage control and to ensure appropriate remedial action be implemented promptly.

Scope

The Policy applies to the following:
1. All Management Committee (MC) and Sub-Committee members;
2. Employees of the Club at all levels including part-time, temporary and contract employees; and
3. All members of the Club not mentioned or included in the above paragraphs 1 and 2.

The Policy

The Policy sets out procedures for members and staff of the Club at all levels to report to the Audit Committee (AC) for investigation into matters relating to breaches of the following:
– Workplace policies at the Club;
– Measures of effective and efficient operations;
– Measures safeguarding assets and resources of the Club;
– Misappropriation of the Club’s assets or funds without proper authorisation;
– Reliable and truthful financial reporting;
– Applicable laws and regulations and the Club’s Code of Conduct;
– Fair treatment of all members and staff, especially with regard to health and safety issues; and
– Any acts which may result in either actual or potential financial or reputational loss to the Club.

Procedures

Members and staff of the Club will be duly notified of the Policy and briefed, in particular, on the procedures for the making of written reports, which shall be addressed to the AC either by dropping such written complaints at the secure “Audit Committee Box” located at the Club’s Front Desk or by email to whistleblower@sswimclub.org.sg.

Such reports must be supported as far as possible with:
1. Reasons and background for the complainant’s concern about the situation; and
2. As much factual evidence as possible, providing, where possible, names, dates, places and where available documents, supporting the eventual follow-up investigations.

Handling of Complaints

The Policy provides that all complaints will be reviewed by the AC which will determine if such complaints are credible and warrant an investigation to be carried out.

The Policy encourages all whistleblowers to provide their names and contact information as far as possible so as to enable and facilitate appropriate follow-up investigations. The identities of all whistleblowers and all follow-up investigations are strictly confidential.

Anonymous complaints will be given due consideration by the AC subject to the seriousness and veracity of the issue(s) raised and the possibility of confirming such allegations from attributable sources.

When the AC deems any complaints to be sufficiently serious and warrant an investigation to be undertaken, the AC shall appoint such person(s) as Investigating Officer(s) or form a Commission of Inquiry to conduct and oversee such investigations. The AC shall keep the Management Committee duly informed of the progress of such investigations.

The Investigating Officer(s) or Commission of Inquiry has clearly defined responsibilities and sufficient powers to make effective and adequate investigations. If necessary, the member(s) being investigated could be suspended from using the Club’s facilities or staff member(s) being investigated could be suspended from duty pending investigations.

All findings of such investigations shall be submitted to the AC which shall recommend the necessary and appropriate actions to be taken by the MC. Prior to presenting such investigation reports to the MC, the AC may consult the Club’s legal advisers on the contents of such reports.

In the event the MC rejects the recommendations of the AC without any compelling reasons, the MC will then convene an Extra-Ordinary General Meeting within the stipulated time or table this matter at the Annual General Meeting according to the Club Rules.