NuLife Care & Counselling is committed to the highest standards of honesty, transparency, ethical and legal conduct and accountability. We strive to ensure a high standard of compliance with accounting, financial reporting, internal controls, corporate governance, auditing requirements and any legislation relating thereto.
In line with this commitment, this policy aims to provide an avenue for employees and external parties to raise concerns regarding malpractice, statutory non-compliance, actual or suspected improprieties in financial transactions and any other wrongdoing.
This policy applies to all employees as well as to all external parties who have interactions with NuLife. These parties include volunteers, donors, service providers, clients, partners, members of public, etc.
This policy sets out the avenues for whistle-blowers to report improper or inappropriate practices that they observe to have occurred in the organisation.
Such improper or inappropriate practices may include:
– Theft and/or misuse of NuLife 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
– Serious conflict of interest without disclosure
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 HR personnel or the Chief Executive Officer. Similarly, normal human resource grievances should be taken up with the HR personnel.
C) REPORTING PROTOCOL
Whistleblowers may report by email to firstname.lastname@example.org, addressing it to the Board Chairperson and the Chairperson of the Audit Committee.
The Board Chairperson and the Chairperson of the Audit Committee sit on the Management Committee that governs NuLife, which the Chief Executive reports to.
Reports made will be screened and reviews 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 NuLife to investigate possible wrongdoing and take appropriate steps to address it, NuLife may not be able to disclose the precise remedial action that has been undertaken.
D) INFORMATION TO PROVIDE WHEN WHISTLE-BLOWING
To assist in assessing and investigating the reported incidents or concerns effectively and efficiently, whistle-blowers 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;
– Any additional information, documentation or evidence available to support the matter, event or issue reported;
– Contact details of the whistle-blower
To encourage transparency and accountability, the Policy encourages the whistleblower to identify himself/herself. NuLife will handle confidentially the whistleblower’s identity and the information he/she provides.
The whistleblower is required under this Policy to put in writing (or to sign against) the information that he/she is providing for the case. 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.
The amount of contact between the whistleblower and the person(s) investigating the concern raised or information provided will be determined by the nature and clarity of the matter reported. Further information may be sought from the whistleblower during the course of the investigation.
When the investigation is completed, the investigating officer(s) will report the findings to the Audit Committee for its necessary action.
The whistleblower will be kept informed of the progress of the investigations and, if appropriate, of the final outcome.
E) SAFEGUARDS & CONFIDENTIALITY OF WHISTLEBLOWER
NuLife will not tolerate harassment or victimisation against a whistle-blower that raises a concern in good faith.
The whistle-blower 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 the Board Chairperson or the Chairperson of the Audit Committee. Any form of retaliation undertaken against the whistle-blower 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 whistle-blower) 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 whistle-blower is a staff of NuLife:
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 whistle-blower suffers no adverse consequences in this context.