Whistleblowing Policy Introduction

1. Singapore Anti-Narcotics Association (“SANA”) is fully committed to conducting its operations with integrity and consistent with the highest ethical standards, and in compliance with all applicable laws and regulatory requirements. SANA strongly believes that the actions and conduct of all employees, as well as all other persons acting on behalf of SANA and it partners are essential to maintaining these standards. Its Board of Management (“Board”) has approved and adopted this Whistle Blowing Policy to ensure necessary arrangements are available where whistleblowers may raise concerns about possible improprieties without fear of reprisals in any form.
2. The Audit Committee of the Board shall have the overall authority and oversight of this Policy from time to time. The Audit Committee may in its absolute discretion delegate the investigation of the whistleblowing reports and implementation of this Policy to such person as it deems fit.
3. It is the responsibility of all officers and employees of SANA to report any possible improprieties. Such persons can report to Chairman Audit Committee whose contact particulars are listed below.

Whistleblowing Reporting and/or Communication Channels

4. This Policy applies to any suspected improprieties involving employees as well as, volunteers, suppliers, service users, beneficiaries and any other parties with a business relationship with SANA.
5. In line with this commitment, dedicated communication channels have been established and whistleblowers may choose to use any of these communication channels. The communication channels are to the Chairperson of the Audit Committee as follows:
   
   Email – kaka@rsmsingapore.sg
   Phone – 6594 7868Address – RSM Chio Lim LLP
   8 Wilkie Road, Wilkie Edge #03-08,
   Singapore 228095 
   
   
6. All of the above communication channels are secure and available to all employees and any parties having business relationship with SANA and its partners. Information received will be treated with the utmost confidentiality and will be attended to by appropriate personnel appointed by the Audit Committee.
7. Any whistleblowing report involving any Board member or member of the Senior Management of SANA may be reported directly to the Chairman of the Audit Committee using the following email communication channels:Chairman of Audit Committee:
   
   Mr Kaka Singh
   <kaka@rsmsingapore.sg>
   
   
8. Any whistleblowing report involving the Executive Director may be reported directly to the Chairman of the Audit Committee.
9. Any whistleblowing report involving the Chairman of the Audit Committee may be reported directly to the President of SANA, while any whistleblowing report involving the President of SANA may be reported directly to the Chairman of the Audit Committee.

How to Make a Report

10. Reports on any improprieties can be made in the form of emails, phone calls, voicemails, letters or reports using the available communication channels mentioned in the above section. These reports should be made as soon as practicable. All reports shall be treated by SANA with an appropriate level of confidentiality. When making a report, the whistleblower should as far as practicable include the following information:
    
    1. Date, time and place of the actions/transactions;
    2. Identity and particulars of the parties involved;
    3. Circumstances leading to the improprieties; and
    4. Any other relevant information or documentation that would assist in the evaluation of the report/incident.
11. Whistleblowers making any such reports should ensure that they do so in good faith and in the best interest of SANA and not with any malicious intent. Whistleblowers may be the subject of disciplinary or other legal action if the reports or allegations are malicious, frivolous or simply to cause anger, irritation, or distress.

How SANA will respond

12. All whistleblowing reports, other than reports involving any Board Member, shall be received by the Chairman of the Audit Committee who will cause them to be logged into a register. The Chairman of the Audit Committee shall conduct an initial review of the report received and the action taken by SANA will depend on the nature of the concern. All investigations shall be reported to the Audit Committee for their attention and further action as necessary. The matters raised may be investigated internally; be referred to external auditor; be referred to appropriate law enforcement agencies; and be investigated by an independent inquiry.
13. In the event that the whistleblowing reports involve any Board Member, the reports shall be escalated to the President and/or Chairman of the Audit Committee as appropriate, for their attention and further action as necessary.
14. Harassment or Retaliation: SANA recognizes 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 malpractice or improprieties. SANA will not tolerate harassment or victimization and will take reasonable and appropriate action to protect you when you raise a concern in good faith.
15. Confidentiality: SANA will do its best to protect your identity when you raise a concern and do not want your identity to be disclosed. It must be appreciated though that the investigation process may need to reveal the source of information and the report made by you may be required as part of evidence.
16. Anonymous Report: SANA strongly encourages you to put your name to your report. SANA is committed to protecting whistleblowers who make reports under this policy, so there should be no reason to report anonymously. Subsequent investigation may be hindered if contact cannot be made with the whistleblower to obtain clarification or further information. SANA is committed to respect the rights of all of its employees/whistleblowers, which include the right of an accused person, in due course, to know the identity of his or her accuser. The identity would, however, not be disclosed unless it is absolutely necessary for the purpose of the investigation and/or subsequent action, and never disclosed without prior discussion with the whistleblower making the report. SANA may choose not to proceed with an investigation if the report is anonymous.

Scope of Improprieties

17. Possible improprieties which should be reported pursuant to this Policy may include but are not limited to the following:
    -Any fraudulent act or forgery;
    -Misappropriation of funds or assets;
    -Profiteering as result of insider knowledge of SANA’s activities/information;
    -Disclosing confidential or proprietary information to external parties;
    -Accepting or seeking anything of material value from employees, volunteers, suppliers, service users, beneficiaries and any other parties with a business relationship with SANA;
    -Destruction/removal/inappropriate use of SANA’s records/assets/ facilities;
    -Violation of rules and regulations applicable to SANA relating to its accounting, financial reporting, internal controls and policies;-Improper actions or omissions which are likely to endanger SANA’s employees, or others; and-Distinct effort to mislead, deceive, manipulate, coerce or fraudulently influence any internal or external auditor/accountant in connection with the preparation, audit or review of any financial statements or records of SANA.
18. This Policy does not and cannot reasonably detail or cover every situation that should be reported pursuant to this Policy. If you are in any doubt as to how you should apply any provisions of this Policy, at any point in time, you are strongly encouraged to seek guidance from your immediate supervisors, SANA’s Senior Management or the Audit Committee.

Communications with the Media and/or any External Parties

19. Employees of SANA are prohibited to communicate and disclose the details of any complaints or investigations with any external parties including media. This is to protect the interests of SANA as well as the Whistleblower and the person being investigated. All media queries should be directed to the Executive Director, the Chairman of the Audit Committee and/or President of SANA as appropriate. If you report your concern to the media, in most cases you may lose your whistleblowing law rights.
20. Implementation of the Policy
21. A copy of the Policy shall be made available on SANA’s intranet and website for transparency and ease of access by all employees and any parties who have business relationship with SANA.
22. All new employees shall be briefed on the Policy as part of their orientation program.
23. Regular communications shall be made to stress to all employees the importance of this Policy as well as to maintain awareness of the Board’s continued commitment to this Policy.
24. The Board shall collate any feedback received and report to the Board on a periodic basis.
25. The Audit Committee shall be responsible for maintaining, reviewing and updating this Policy. Any proposed revisions shall require the Board’s approval.

Dated : 14 March 2019