Financial Industry Disputes Resolution Centre (FIDReC) Whistleblowing Policy

Introduction

This whistle-blowing policy aims to provide a framework for employees and external parties to report any concerns or complaints regarding any form of malpractice, wrongdoing or statutory non-compliance, including but not limited to questionable accounting or auditing matters, internal controls, disclosure matters, conflict of interest, collusion with competitors, unsafe work practices or any other matters involving fraud, corruption, Board member or employee misconduct.

The Policy allows for reporting by employees or external parties without fear of reprisal, discrimination or adverse consequences and also permits FIDReC to address such reports by taking the appropriate action, including, but not limited to, disciplining or terminating the employment and/or services of those responsible.

Scope

Any Board member, employee, vendor, contractor, third party, applicant for employment, or member of the general public who notices, is aware of, or has any concerns about any actual or suspected wrongdoings committed by any FIDReC Board member, employee, staff, management, or contractor, can lodge a complaint.

Reportable incidents include, but are not limited to the following improper or unethical activities, actual or suspected:
  • Corruption, embezzlement, cheating, theft or bribery
  • Misuse/misappropriation of funds and resources
  • Irregularities in financial reporting, questionable accounting or audit matters
  • Non-compliance with laws and regulations
  • Falsification or fraudulent alteration of documents (mandatory submissions to relevant authorities, contractual agreements, invoices, purchase orders etc.)
  • Abuse or misrepresentation of power or authority
  • Conflict of interest without due disclosure
  • Breach or circumvention of internal policies
  • Unauthorised access or disclosure of information
  • Concealment or wilful suppression of any malpractice or misconduct
  • Acts to mislead, deceive, manipulate, coerce or fraudulently influence the preparation, examination, audit or review of any assets and records
  • Unsafe work practices that endanger the health or safety of persons or environment
  • Acts of harassment
  • Professional malpractice, e.g. violation of intellectual property rights,
  • Acts of retaliation, intimidation or harassment, discrimination or unfair treatment against staff who have made an allegation or assisted in the investigation of an allegation
  • Any other conduct that may cause financial, non-financial loss or damage of FIDReC's reputation
  • Aiding and abetting illegal activities or any of the above misconduct
  • Breach of confidentiality in FIDReC's or members' information
FIDReC encourages the whistle-blower to leave his/her name in his/her complaint so that the organisation can get more information, seek clarifications and investigate the matter effectively. Anonymous complaints will nevertheless still be investigated, taking into account the seriousness and credibility of the issues raised, and the likelihood that the allegations can be confirmed by attributable sources and the information provided.

To the extent practicable and permitted by law, FIDReC will keep the identity of the whistle-blower confidential. All concerns or irregularities raised will be treated with confidence and every effort will be made to keep the whole process confidential.

Exceptions where the identity of the whistle-blower may need to be revealed include:
  • It is required by law to reveal the whistle-blower's identity;
  • It is necessary as part of the investigation process to reveal the identity of the whistle-blower;
  • The whistle-blower's identity is disclosed on a strictly confidential basis to professional service providers for the purpose of obtaining professional advice; or
  • The whistle-blower is required to testify as a witness in a civil or criminal trial.

Protection

The Policy is meant to protect genuine whistle-blowers from any unfair treatment as a result of their report. A genuine whistle-blower who files a complaint in good faith shall not be discriminated, intimated or harassed, and FIDReC will take reasonable and appropriate action to protect all genuine whistle-blowers who file a complaint in good faith.

If an allegation is made maliciously or for personal gain, appropriate action may be taken against the whistle-blower. This may include disciplinary action (for employee), or reporting the matter to the police (for a third party).

The Policy is also not a route for taking up personal grievances. These should continue to be taken up directly with department supervisors or the HR Department in accordance with the grievance procedure set out in FIDReC's Employee Handbook.

Procedures

  • Complaints may be raised with or information provided to:

    • By Post

      Please mark the letter as follows:

      Private & Confidential
      For the attention of the Chairperson, Audit and Risk Committee
      Financial Industry Disputes Resolution Centre (FIDReC)
      36 Robinson Road #15-01 City House
      Singapore 068877

    • By Email

      Email Address: AuditRiskCom@fidrec.com.sg

      Please mark the subject header of the email: "Private & Confidential for the attention of the Chairperson, Audit and Risk Committee, FIDReC"

  • To the extent feasible, the whistle-blower should provide the following information and details so that the matter can be assessed and investigated effectively. Details should include the following:
    • Background and history of events
    • Parties involved
    • How the impropriety was discovered
    • Value involved
    • Evidence (if any)

  • All information received will be treated with confidentiality.

  • Assessment of the concern or information shall be made with due consideration given to the following factors:
    • Seriousness of the issue raised;
    • Credibility of the concern or information; and
    • Likelihood of confirming the concern or information from the attributable sources.

  • The Audit and Risk Committee will have overall oversight of this Policy and may at its absolute discretion delegate the investigation to such person (internal or external) as it deems fit, and/or may refer the matter to the authorities or regulators as it deems appropriate.

  • 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 and Risk Committee for its necessary action.

FIDReC reserves the right to modify this Policy to maintain compliance with any applicable laws and regulations or in light of any restructuring of FIDReC.