Singapore FinTech Association WhistleBlowing Policy and Procedure

1 Oct  2020

1          Policy Purpose

1.1       The Singapore Fintech Association (“SFA”) aims to maintain the highest standards of openness, decency, integrity and accountability to its work.  Everyone who works with or for SFA must be vigilant for signs of wrongdoing or criminal activity by individuals or organisations working with or for SFA and are encouraged to report such behaviour using the policy without fear of adverse consequences

1.2       The Policy is intended to encourage employees and other relevant stakeholders to report unethical or illegal conduct.  Policy objectives include:

1.2.1     Encourage timely reporting of alleged malpractices/misconduct;

1.2.2     Provide a confidential channel for escalation of concerns without fear of reprisal;

1.2.3     Ensure consistent and timely response to reported improprieties and awareness by whistle blowers of their options/rights;

1.2.4     Ensure appropriate oversight by the SFA Executive Committee;

1.2.5     Serve as a means of preventing and deterring misconduct that may be contemplated;

1.2.6     Protect the rights of SFA; and

1.2.7     Promote a culture of openness, accountability and integrity.

2          Application

2.1       This process applies to employees (including part-time staff and interns), partner organisations, suppliers, agents, contractors or sub-contractors of SFA or any person associated with SFA.

2.2       Reportable incidents for whistle blowing include:

2.2.1     All forms of financial or non-financial malpractices or impropriety such as fraud, corruption, bribery or theft, money laundering, supporting or involving terrorism;

2.2.2     Harassment and abuse and misrepresentation of power and authority;

2.2.3     Failure to comply with laws and regulations;

2.2.4     Actions detrimental to health and safety or the environment;

2.2.5     Discrimination on the basis of age, gender, religion, race, sexual orientation or disabilities;

2.2.6     Serious conflict of interest without disclosure;

2.2.7     Breach of SFA’s policies; and

2.2.8     Concealing information about any of the above malpractice or misconduct.

3            Reporting Mechanisms

3.1         Concerns should be raised as early as possible.  Concerns are to be raised by email, giving any background and history, including relevant dates and any witnesses.  As it is essential for SFA to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible. 

3.2          Individuals are required to put their name and contact details to any whistleblowing disclosures they make.  Concerns expressed anonymously will Not be considered.

3.3       The email for SFA whistleblowing is:   [email protected].

3.4       The recipients of SFA whistleblowing email are the SFA Audit and Compliance Committee and SFA Head of Governance, collectively known as “Receiving Parties”.   The Receiving Parties are responsible for the investigation, handling and escalation of reportable concerns.

3.5          An investigation will then be carried out.  The whistle-blower is not encouraged to investigate on his own as this could result in either the destruction or contamination of evidence or put his or her own safety at risk.

3.6          Following the investigation, the whistle-blower will be informed of the outcome and what action will be taken, which may be to do nothing or to follow the full disciplinary procedure.  However, the need for confidentiality may mean that the whistle-blower would not be given much detail.

3.7        If the whistle-blower should believe that his or her concern has not been dealt with properly or the wrongdoing is still going on, the whistle-blower should raise his or her concerns with the Chair of the SFA Audit and Compliance Committee.      

4          Confidentiality

SFA will treat all such disclosures in a confidential and sensitive manner.  The identity of the individual making the allegation may be kept confidential so long as it does not hinder or frustrate any investigation.  However, the investigation process may reveal the source of the information and the individual making the disclosure may need to provide a statement as part of the evidence required.

5          Reporting externally

If, on conclusion of the procedure in section 3, the whistle-blower reasonably believes that the appropriate action has not been taken, he or she should report the matter to one of the following bodies:

  • Monetary Authority of Singapore
  • Registrar of Societies

6          Safeguards

At the appropriate time, the party making the report/complaint may need to come forward as a witness.  If the allegation has been made in good faith but it is not confirmed by the investigation, no action will be taken against him or her.  However, individuals who make accusations which are frivolous, malicious or for personal gain, SFA will take appropriate actions which may include disciplinary action for employees and reporting the matter to the police.

7          Contact

For any query, please contact SFA at  [email protected]

The Executive Committee

Singapore Fintech Association