1. Church of Singapore (COS) is committed to maintaining high standard of integrity in her business conduct.  At COS, we expect our Church Board and employees to conduct themselves with a high standard of professionalism and ethics in the conduct of church business, activities and events.  
  2. Whistle blowing is defined as a deliberate, voluntary disclosure of individual or organizational inappropriate, unethical or unlawful behavior or malpractice by a person or a group of persons who has or has had privileged access to data, events, or information about any actual, suspected or anticipated wrongdoing within or by COS that is within her ability to control. 
  3. As part of good corporate governance and in line with Christian doctrines and COS principles and practices as well as COS “zero tolerance” stance to fraud, bribery, corruption and other unethical behavior or conduct, COS have established a Whistle Blowing Policy (hereinafter called “This Policy”).  
  4. This Policy sets out the trusted avenues for employees, vendors, suppliers, service providers, church members and all other external parties who have business relationships with COS to raise legitimate concerns on the irregularities or malpractices and report serious wrongdoing, particularly in relation to fraud, controls or ethics, to be objectively investigated and addressed without fear of reprisals or adverse consequences.
  5. This Policy is also intended to encourage staff and church stakeholders to report unethical or illegal conduct, as well as provide assurance to the whistle blower that their concerns will be taken seriously and investigated thoroughly.
  1. The following are a list of examples (though not exhaustive) of reportable incidents covered by This Policy:
    1. Concerns about COS accounting, internal controls or auditing matters; manifestation of intention to mislead, deceive, coerce, or fraudulently influence any internal or external accountant or auditor in connection with the preparation, examination, audit or review of any financial statements or records of COS.
    2. Impropriety, corruption, blackmail, misappropriation and or acts of fraud, theft and/or misuse of COS properties, assets, or resources for personal gain.
    3. Conduct which is an offence or breach of law, or any criminal offence or failure to comply with a legal or regulatory obligation
    4. Serious conflict of interest without disclosure
    5. Breach of COS principles and practices
    6. Immoral and improper conduct of any COS staff or Board member, such as sexual misconduct, cheating, lying, misappropriation of church funds or acts of fraud or theft
    7. Any other serious improper conduct that may cause financial or non-financial loss to COS or damage COS reputation
    8. Fraud against members or making fraudulent statements that can cause physical danger or harm to another person, public and government or state authorities, or can give rise to risk of damage to properties or assets
    9. Forgery or alteration of any document belonging to COS, vendors, members, financial institution, or agents of COS
    10. Endangerment of the health and safety of an individual
  2. Expression of personal opinion, unhappiness, complaints and grievances concerning church operational matters and service quality, HR policy, staff discipline and conduct, or private unhappiness and disputes with fellow church members are not matters for whistle-blowing.  These concerns should be taken up with any one of these COS church leaders: LG Leader, Area Leader, Service-in-Charge, Ministry Head, Ex-Co Chair or an Elder.
  1. When raising concern or providing information about an actual, suspected, or anticipated wrongdoing, done in good faith, the individual, be it an employee or anyone else, he/she shall be protected against any reprisal such as employment termination, acts of harassment, retaliation, victimization and recrimination arising from making the disclosure in good faith.
  2. All reports are handled confidentially, except as necessary or appropriate to conduct investigation by an Investigating Committee to be appointed by COS Audit Committee or COS Elder Board, and to take remedial action, in accordance with the applicable laws and regulations of Singapore. In this regard:
    1. The identity of the person (hereafter called “Whistleblower”) making the allegation will be kept strictly confidential and confined to the Investigating Committee which may comprise any or all of the persons mentioned in below Para E3, so long as it does not hinder or frustrate any investigation.
    2. The investigation process may reveal the source of the information to persons involved in the investigation or resolution of the investigation report. All personnel, directly or indirectly working relative to a whistle blowing case, shall strictly protect the identity of the whistleblower and witnesses from unauthorized disclosure before, during and after an investigation.
    3. The Whistleblower making the report may need to provide a statement as part of the gathering of evidence required.  
    4. In the event where the identity of the whistleblower may need to be revealed on a need-to-know basis (e.g. requirement to testify in Court should such a situation arises), COS shall discuss and seek prior consent of the whistleblower before proceeding with the case. 
    5. COS will not tolerate the harassment or victimization of anyone reporting a genuine concern.  Furthermore, no person should suffer reprisal as a result of reporting a genuine concern, even if they turn out to be mistaken. 
    6. While This Policy is meant to protect the Whistleblower from any unfair treatment as a result of their report, it strictly prohibits frivolous and untrue complaints.
  1. The Whistleblower should report his/her concern to the Chairman of the Audit Committee, who will handle all reported cases and ensure that issues raised are properly resolved by COS Church Board or such parties as appropriate.  In the absence of the Chairman, one of the Audit Committee members will be appointed to take charge of the matter.
  2. All concerns raised will be independently assessed to ensure that they are fairly and properly considered.  As it is essential to have all critical information in order to be able to effectively evaluate and investigate a compliant, the report made should provide as much information and be as specific as possible, such as:
    1. Brief description of the misconduct;
    2. The date and location of the incidence;
    3. The identity of the wrongdoer;
    4. Particulars of witnesses, if any;
    5. Supporting evidence and or documents;
    6. Other details deemed to be useful to facilitate screening and action to be carried out
  3. Where possible, the Whistleblower is encouraged to disclose his personal details (name, contact details: email address and or telephone/handphone number) to enable the relevant parties conducting the investigation to contact the Whistleblower for further information.
  4. Concerns expressed anonymously are difficult to act upon effectively.  However, they may be considered, taking into account the severity and credibility of the issues raised and the likelihood of confirming the concern or information from the attributable sources on the information provided.
  5. The Whistleblower is encouraged to provide their contact information so that clarifications could be sought during the course of investigation.  If a Whistleblower chooses to make such reports anonymously, he shall not be entitled to the investigation outcome of the case reported by him.
  1. The channels of reporting are to be made in writing under Confidential Cover, either in the form of a letter or email addressed to:
    Chairman of the Audit Committee
    c/o Church of Singapore 
    145 Marine Parade Road 
    Singapore 449274Email: ac_chair@cos.org.sg
  2. The report is to set out in detail the background and history of events as well as the reason(s) for concern.  
  3. Depending on the nature of the concern raised or information provided from the attributable source, one or more of the following individuals or entities may be involved:
    1. COS Audit Committee
    2. COS External Auditor
    3. COS Internal Auditor
    4. COS Elder Board
    5. COS Human Resource Head
    6. COS External Legal Counsel
    7. The Police or Commercial Affairs Department

    In the event an investigation of a whistle blowing case requires the assistance of other individual(s) or entity/entitles that are not mentioned in the above list, such other individuals or entities may be involved too. 

  1. Whistleblower makes the disclosure in good faith.
  2. Whistleblower reasonably believes that the information and allegations are substantially true.
  3. Whistleblower is not acting for personal gain.  If the case involves the complainant’s personal interests, it must be informed at the outset.
  1. 1st September 2022
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