REPORT A CONCERN, POSSIBLE WRONGDOING, OR IRREGULARITIES

The Whistleblowing Policy at Singapore Recreation Club (SRC) establishes a framework for reporting suspected wrongdoing, unethical behavior, or violations of law within the organization. It ensures protection for whistleblowers while promoting transparency, accountability, and compliance with internal controls and governance standards.

OBJECTIVE

The policy aims to maintain high standards in financial reporting, internal controls, and corporate governance. It provides a secure, confidential channel for contractors, stakeholders, and external parties to report concerns without fear of retaliation, supporting SRC’s core values.

DEFINITION

Whistleblower: An individual who reports misconduct or unethical behavior affecting the Singapore Recreation Club.

REPORTABLE INCIDENTS

Below is a list of examples (though not exhaustive) of reportable incidents covered by this policy:

• Impropriety, corruption, acts of fraud, theft, and misuse of SRC’s properties, assets or resources.
• Serious conflict of interest without disclosure.
• Concerns about the Club’s accounting, internal controls, or auditing matters.
• Breach of SRC policies or code of conduct.
• Any serious improper or illegal conduct that may cause financial or nonfinancial loss to SRC or damage its reputation.
• Participation in or condoning a reportable wrongdoing through wilful suppression or concealment of any information relating to a wrongdoing.
• Harassment, abuse, and misrepresentation of power and authority.

HOW TO RAISE A CONCERN

• Reporters are encouraged to provide their name and contact details to facilitate follow-up and investigation.
• Anonymous reports will be considered at SRC’s discretion based on seriousness, credibility, and verifiability.
• All concerns will be handled sensitively and confidentially, though legal obligations may require disclosure in some cases.
• SRC will acknowledge receipt of concerns but may not provide updates on investigation outcomes.

CHANNEL OF REPORTING

All valid concerns or irregularities raised will be acknowledged and remain confidential throughout and beyond the investigation. The Rules and Membership Committee (RMSC) will review and recommend the appropriate course of action to be taken to the Management Committee.

ROLE OF RMSC IN WHISTLEBLOWING

• Upon receiving a complaint, the RMSC Chairman conducts a preliminary inquiry.
• If warranted, a formal investigation is initiated by appointing an investigator or team, preferably from within the RMSC.
• The independence of investigators is ensured regardless of their affiliation.
• The RMSC can proceed without Management Committee approval, but may inform them if no conflict exists.
• The RMSC recommends appropriate actions to the Management Committee based on findings.

CONFIDENTIALITY AND FAIR TREATMENT

SRC shall protect whistleblowers from victimisation and endeavour to maintain confidentiality throughout the process.