Whistleblowing Policy

SIAS is committed to the highest standards of honesty, transparency, ethical and legal conduct and accountability. The whistleblowing policy aims to provide an avenue for employees and external parties to raise genuine concerns relating to any aspect of SIAS’ operations, including serious breaches of the code of conduct by employees. The aim of the policy is to:

  1. Promote standards for good financial and corporate practices and to deter wrongdoing.
  2. Provide proper avenues for employees and external parties to raise concerns about suspected improprieties and receive feedback on any action taken.
  3. Give employees and external parties the assurance that they will be protected from reprisals or victimisation for whistleblowing in good faith.
  4. Reportable incidents

Some examples of concerns covered (though not exhaustive) by this policy include:

  1. Impropriety, corruption, theft/misuse of SIAS’ properties/assets/resources.
  2. Conduct which is an offence or breach of law.
  3. Breach of or failure to implement or comply with SIAS’ policies.
  4. Concerns about SIAS’ accounting, internal controls or auditing matters.
  5. Serious conflict of interest without disclosure, resulting in material gain.
  6. Acts which mislead, deceive, manipulate, coerce or fraudulently influence any internal or external accountant or auditor in connection with the preparation, examination, audit or review of any finanial statements or records of SIAS.
  7. Abuse of power or authority, for example, CEO asking Finance Manager to make false declarations on company’s accounts.
  8. Physical and emotional bullying by colleague.
  9. Sexual harassment:
    • Physical harassment (sexual gestures, inappropriate touching etc.).
    • Verbal harassment (sexual comments/jokes, asking for sexual favours etc.).
    • Visual harassment (showing derogatory or pornographic materials etc.).
    • Any other serious improper matters which may cause financial or non-financial loss to SIAS or damage to SIAS’ reputation.
  1. Fraud or the making of fraudulent statements to members of the public and regulatory authorities.
  2. Concealing information about any malpractice or misconduct.
  3. Intentional provision of incorrect information to public bodies.

Protection against reprisal

SIAS recognises that the decision to report a concern can be a difficult one to make, not least, because of the fear of reprisal from those responsible for the alleged malpractice. SIAS will not tolerate harassment or victimisation and will take all possible action to protect anyone who raises a concern in good faith.

However, SIAS does not condone frivolous, mischievous or malicious allegations and anyone making such allegations may face disciplinary action.

Confidentiality

SIAS requires the whistleblower to identify himself/herself when raising a concern or providing information. All concerns will be treated with the strictest confidentiality.

Exceptional circumstances under which information provided by the whistleblower could or would not be treated with confidentiality include:

  1. Where SIAS is under a legal obligation to disclose information provided.
  2. Where the information is already in the public domain.
  3. Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice.
  4. Where the information is given to the police or other authorities for criminal investigation.

Procedures

Concerns may be raised with or information provided to:

Private & Confidential
For the Attention of Audit Committee Chairman
Securities Investors Association (Singapore)
7 Maxwell Road #05-03
MND Building Annexe B
Singapore 069111
Email Address: audit_committee@sias.org.sg

Such reports are preferably made in writing, either in the form of a letter or email, and in detail setting out the background and history of events as well as the reason(s) for concern.

Assessment of the concern or information shall be made with due consideration given to the following factors:

  1. Seriousness of the issue raised;
  2. Credibility of the concern or information; and
  3. Likelihood of confirming the concern or information from the attributable sources

Depending on the nature of the concern raised or information provided, the investigation will be conducted, involving one or more of the following individuals or entities:

  1. The Audit Committee
  2. The External Auditor, and/or
  3. The Police or Commercial Affairs Department.

The amount of contact between the whistle blower and the person(s) investigating the concern raised or information provided will be determined by the nature and clarity of the matter reported. Further information may be sought from the whistle blower during the course of the investigation. When the investigation is completed, the investigating officer(s) will report the findings to the Audit Committee for its necessary action.

If the whistleblower identifies himself/herself, the Audit Committee will look into the matter and will reply the person within 2 weeks. If the message is anonymous there is no obligation for the Audit Committee to respond. The Audit Committee will decided if the report is deem as whistleblowing based on the policy as stated above.