Governance

Whistle Blowing Policy

The Asia Pacific Hospice Palliative Care Network (APHN) is committed to the highest standards of honesty, transparency, ethical and legal conduct and accountability. In this regard, APHN is committed to a high standard of compliance with accounting, financial reporting, internal controls, corporate governance and auditing requirements and any legislation relating thereto.

In line with this commitment, we provide this avenue for employees and external parties to raise concerns regarding malpractice, statutory noncompliance, actual or suspected improprieties in financial transactions and any other wrongdoing.

Scope
The issues which may be raised cover such following wrongdoings, although not limited to these:

• Fraudulent activities/transactions
• Personal and professional misconduct
• Unauthorised access to and/or disclosure of information
• Embezzlement, misappropriation, theft, or criminal misuse of the organisation’s monies and resources
• Corruption, bribery, cheating
• Aiding and abetting illegal activities
• Harassment or discrimination

Application
This Policy applies to both staff and/or external parties. Staff shall include anyone who is on the payroll of APHN. External parties shall include registered members and volunteers of the Council, individual and corporate donors, beneficiaries, individuals or organisations with a business dealing with the APHN.

Misuse of the Process
The Policy is not meant as a channel for personal or normal HR grievances, which can be taken up through the APHN grievance handling procedure. Frivolous, unsubstantiated, or unsubstantial claims/complaints will not be considered. The APHN does not condone abuse of the Policy for personal gains, or with malicious intent.

Procedure
The whistle blower can raise their concern through the following channels:

Chairman, Finance and Administration Committee, Asia Pacific Hospice Palliative Care Network

Email: whistleblowing@aphn.org

Mailing address:
c/o Division of Supportive & Palliative Care
National Cancer Centre Singapore
11 Hospital Crescent
Singapore 169610

To ensure confidentiality, the email should be titled “Strictly Private and Confidential – To be opened by Addressee Only”

Such reports are preferably made in writing, either in the form of a letter or email, and in detail setting out the background and history of events as well as the reason(s) for concern.

Protection against Reprisal and Confidentiality
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, they shall be protected against any reprisal such as employment termination, retribution, or harassment.

Concern or information about an actual, suspected or anticipated wrongdoing as well as its source shall be treated with the strictest confidence.

Exceptions to above include:

• When APHN is under legal obligation to disclose such information provided;
• When the information is already in the public domain;
• When the information is given in strict confidence to legal or auditing Professionals for the purpose of obtaining professional advice; and
• When the information is given to the Police for criminal investigation.

Concerns or information provided anonymously will still be given due consideration by APHN but will be investigated on their own merits.

Procedures
Assessment of the concern or information shall be made with due consideration given to the following factors:

• Seriousness of the issue raised;
• Credibility of the concern or information; and
• Likelihood of confirming the concern or information from the attributable sources

Depending on the nature of the concern raised or information provided, the investigation will be conducted, involving one or more of the following individuals or entities:

• The Finance and Administration Committee,
• An appointed representative from the Council, and/or
• An internal auditor

The amount of contact between the whistle blower 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 whistle blower during the course of the investigation. When the investigation is completed, the investigating officer(s) will report the findings to the Finance and Administration Committee for its necessary action.