REACH Community Services Whistleblowing Policy

AIM

REACH Community Services Ltd.’s (REACH) Whistleblowing Policy (“the Policy”) aims to set out the framework for whistleblowers to raise concerns on irregularities within the organization.  The Policy allows for reporting to appropriate persons with the power to investigate and follow up any genuine issues raised without fear of unfair treatment, retaliation or any adverse consequences.

Whistleblowers can be anyone that has interaction with REACH. The person can be a staff of REACH, volunteer, donor, stakeholder, vendor, client, beneficiary, partner, a member of the public, etc.

SCOPE

This policy sets out the avenues for whistleblowers to report improper or inappropriate practices that they observe to have occurred in the organization.

Such improper or inappropriate practices may include:

• Theft and/or misuse of REACH Community Services’ properties, assets or resources (including confidential information)
• Breach or circumvention of internal controls or policies
• Irregularities in financial reporting
• Unlawful offence being committed
• Any form of harassment
• Discrimination on the basis of gender, race and disabilities
• Abuse of power and authority
• Corruption and bribery
• Concealment or wilful suppression of any wrongdoing
• Endangerment to health or safety of persons

Out of scope complaints:

Incidents or complaints that fall outside the scope mentioned above, which are related to service quality or performance issue, should be reported to the relevant internal response channels like the Head of department or the Chief Executive Officer. Similarly, normal human resource grievances should be taken up with the REACH Human Resource Department.

REPORTING PROTOCOL

Whistleblowers may report by email to [email protected]

The email will be received by the Board Chairman and the Chairman of the audit committee of REACH.

The Chairman of the Board and the Chairman of the audit committee sit on the Board of Directors that governs REACH, which the management team led by the Chief Executive Officer reports to.

Reports made will be screened and reviewed for the appropriate follow up action to address the concern raised.

The follow up action may include further clarification of facts, closure of case with satisfactory explanations provided, and commencement of internal investigation or where appropriate; it will be referred to external parties such as the external auditors, or regulatory authorities. The follow up action listed above is not meant to be exhaustive.

While the purpose of this Policy is to enable REACH to investigate possible wrongdoing and take appropriate steps to address it, REACH may not be able to disclose the precise remedial action that has been undertaken.

INFORMATION TO PROVIDE WHEN WHISTLE-BLOWING

To assist in assessing and investigating the reported incidents or concerns effectively and efficiently, whistleblowers should specify as much specific and factual information as possible so as to allow for proper evaluation of the nature, extent, validity and urgency of the matter reported.

The following key information should be provided (where applicable):

• The alleged event or matter that is the subject of concern;
• The name(s) of the person(s) and/or parties involved;
• The date and place in which the event has taken place; and
• Any additional information, documentation or evidence available to support the matter, event or issue reported.
• Contact details of the whistleblower.

A distinction will be made between anonymous and non-anonymous complaints as more weight will be placed on the latter. Whistleblowers are encouraged to identify themselves (for transparency and to give more legitimacy to a complaint).

Anonymity deprives the investigative services of the possibility of asking the source for clarification or more information and enhances the risk of frivolous, malicious or unreliable information.

SAFEGUARDS & CONFIDENTIALITY OF WHISTLEBLOWER

REACH will not tolerate harassment or victimization against a whistleblower that raises a concern in good faith.

The whistleblower who believes that he/she is being unfairly treated as a result of having made a report or given evidence as a witness in respect of the wrongdoing may raise a complaint to REACH Board Chairman or the Chairman of the Audit Committee. Any form of retaliation undertaken against the whistleblower for raising a concern in good faith is prohibited. In such cases, disciplinary measures will be taken against the person undertaking the retaliation.

All information (including the identity of the whistleblower) disclosed during the course of the investigation will remain confidential, except as necessary to conduct the investigation or to take any remedial action, in accordance with applicable laws and regulations.

Where the whistleblower is a staff of REACH:

In reporting a concern, staff should exercise due care to ensure the accuracy of the information. If, however, an allegation is made frivolously, maliciously, or for personal gain, disciplinary action may be taken to deter any abuse of the Policy.

If a staff member reports a concern in good faith, which is not confirmed by subsequent investigations, no action will be taken against that staff member.

Particular care will be taken during staff appraisal and promotion procedures to ensure that the whistleblower suffers no adverse consequences in this context.