Whistle Blowing Policy
The Whistle Blowing Policy provides a platform for partners, suppliers and the members of public to report on observed improprieties that involve Singapore Turf Club (STC) staff and/or its partner(s)/supplier(s). STC treats all feedback/complaints seriously and will investigate when there is a need to do so. The STC Audit and Risk Sub-Committee will review all investigation reports and take necessary actions.
The whistle blower may send the whistle blowing report to: firstname.lastname@example.org.
All whistleblowing reports will be directed to STC President & Chief Executive, Chief Human Resources Officer, Tote Board Senior Director (Group Internal Audit, Tote Board) and STC Chairman (Audit and Risk Sub-Committee) who will be responsible for ensuring that all whistleblowing reports are properly followed up on.
Information to be provided
In reporting any unethical, fraudulent, or corrupt activity, the Whistleblower shall, to the best of his/her ability, ensure that the information he/she provides is accurate. The report should include details of:
- Description of the wrongful practice, including dates or period of times of the occurrences;
- the staff involved and place (name & location);
- value of any money or assets involved;
- any external parties involved (name, description and address);
- how the suspected activity was discovered;
- any potential sources of additional information about the matter in question; and
- any other information that would assist with the investigation.
Types of Impropriety
The types of impropriety include but are not limited to the following:
- Failure to observe a legal obligation
- Miscarriage of justice
- Concerns about STC’s accounting, internal controls or auditing matters
- Breach of or failure to implement or comply with the STC’s policies
- Corruption, malpractice, acts of fraud, theft and mismanagement or misuse of the STC’s properties, assets or resources
- Conduct which is improper, unethical or in breach of the law
- Abuse of power or authority
- Serious conflict of interest without disclosure
- Participation in or condoning a reportable wrongdoing through wilful suppression or concealment of any information relating to a wrongdoing
Whistleblowers are strongly encouraged to provide their names and contact numbers to facilitate investigations. Further clarifications are often needed and helpful in investigations into the feedback/complaints. The ability to investigate depends on the quality and adequacy of the information provided by the Whistleblower. Subject to applicable laws and regulations, STC will protect the confidentiality of the Whistleblower.
Protection of Whistleblower
Except for malicious whistleblowing, a Whistleblower who makes a feedback/complaint shall be protected by STC against any reprisal.
If the results of an investigation show that the Whistleblower acted maliciously or did not act in good faith or submitted a feedback/complaint which he knew to be false, or without a reasonable belief in the truth and accuracy of the information, STC shall consider taking appropriate actions against the Whistleblower.