SAVH Whistle Blowing Policy
The Association is committed to maintaining high standards of transparency, integrity, compliance, and accountability. This Whistleblowing Policy provides a structured framework for employees and external parties to raise concerns about non‑personal matters that may affect the Association, its employees, stakeholders, suppliers, beneficiaries, or the public at large.
Whistleblowing applies to concerns involving actual or suspected wrongdoing, including but not limited to:
- Failure to comply with legal, regulatory, or governance obligations
- Suspected wrongdoing such as fraud, corruption, misrepresentation, bribery, kickbacks, or embezzlement
- Abuse or misuse of authority or power
- Deliberate attempts to conceal or cover up any of the above
Employees are encouraged, where practicable, to raise whistleblowing concerns through the Association’s formal reporting channel to enable timely review and appropriate action. Whistleblowers (employees or external parties) who wish to raise whistleblowing concerns may submit their reports in writing, either by letter or email (whistleblow@savh.org.sg), to the Audit and Risk Sub‑Committee (ARSC) Chairperson.
Such reports should include, where available, sufficient detail to facilitate proper assessment and investigation, including the background and history of events, reasons for concern, parties involved, relevant dates, description of the incident(s), how the matter came to the whistleblower’s attention, duration of the suspected wrongdoing, any estimated value involved, and supporting evidence.
Whistleblowers are not required to provide conclusive proof of wrongdoing. However, concerns must be raised honestly and in good faith, and must be based on factual information, direct observations, or circumstances that the whistleblower reasonably believes to be true at the time of reporting.
To support effective investigation and follow-up, whistleblower(s) are strongly encouraged to provide their name and contact details. The Association will take all reasonable steps to ensure confidentiality and protect the identity of the whistleblower(s) in accordance with this policy.
Whistleblowing reports must not be based solely on personal assumptions, speculation, rumours, or conjecture, nor should subjective interpretations or opinions be presented as facts. Whistleblowers are expected, where possible, to clearly distinguish between factual information and personal views or interpretations when making a disclosure.
Whistleblowing must not be used as a means to pursue personal grievances, make knowingly false allegations, or cause reputational harm without reasonable basis. Any report found to be knowingly false, malicious, frivolous, or made in bad faith, including those raised with intent to mislead or without reasonable grounds, may result in disciplinary action in accordance with the Association’s disciplinary procedures.
Anonymous reports may still be considered at the discretion of the of the ARSC Chairperson. However, such reports may be subject to limitations due to practical difficulties in verifying information or obtaining further details, which may affect the extent to which a full and effective investigation can be conducted. Whistleblower(s) are therefore encouraged to be contactable to support a thorough review of the matter.
Employees who raise concerns in good faith*, or who participate in investigations arising from whistleblowing reports, shall be protected from retaliation in accordance with this policy.
*For the purposes of this policy, “good faith” means that the individual honestly believes the information disclosed to be true at the time of reporting, based on reasonable grounds, and raises the concern without malice, intent to mislead, or personal or improper motives.
Upon receipt of a whistleblowing report, the matter shall be evaluated to determine whether an investigation is warranted. Where an investigation is required, the Executive Committee (Exco) shall appoint a three (3) members investigation team to examine the matter, substantiate the findings, and make recommendations on the appropriate course of action.
All whistleblowing matters shall be reported to, and appropriately updated by, the Exco, which retains final decision‑making authority to ensure proper resolution and closure of the matter.