1. Purpose

This Policy aims to describe and provide an avenue or course of action an employee, customer or third parties, can take to escalate any misconduct or wrongdoing as described in paragraph 2.2.

The Policy is meant to protect genuine whistleblowers from any unfair treatment as a result of their report. The whistleblower’s role is as a reporting party. They are not, investigators or finders of fact, nor do they determine the appropriate corrective or remedial action that may be warranted.

The Policy is also not a route for taking up personal grievances. These should continue to be taken up directly with the respective Department Heads.

This is to ensure that NTUC First Campus Limited and its Subsidiaries (NFC) conducts its business with the highest standard of integrity and honesty.

2. Scope

1. Any employee, contract staff, student, parent, vendor, contractor, third parties, applicants for employment, or member of the public who notices, is aware of, or has any concerns about any actual or suspected wrongdoings committed by any NFC employee, staff, management, or contractor, can lodge a report.
2. Reportable incidents include, but are not limited to the following improper or unethical activities, actual or suspected:
   • Corruption or bribery
   • Embezzlement, cheating or theft
   • Non-compliance with laws and regulations
   • Irregularities in financial reporting, questionable accounting or audit matters
   • Falsification or fraudulent alteration of documents (contractual agreements, invoices, purchase orders etc.)
   • Misuse/misappropriation of funds and resources
   • Abuse or misrepresentation of power or authority
   • Conflict of interest without due disclosure
   • Breach or circumvention of internal policies
   • Intentional unauthorized access or disclosure of information
   • Concealment or willful suppression of any malpractice or misconduct
   • Acts to mislead, deceive, manipulate, coerce or fraudulently influence the preparation, examination, audit or review of any assets and records
   • Unsafe work practices that endanger the health or safety of persons or environment
   • Acts of harassment
   • Academic or professional malpractice, e.g., Violation of intellectual property rights, malpractice in research
   • Acts of retaliation, intimidation or harassment, discrimination or unfair treatment against staff who have made an allegation or assisted in the investigation of an allegation
   • Any other conduct that may cause financial, non-financial loss or damage of NFC’s reputation
   • Aiding and abetting illegal activities or any of the above misconducts

3. Confidentiality

1. NFC strongly encourages the whistleblower to leave his name in his complaint so that the organization can get more information, seek clarifications and investigate the matter effectively.
2. NFC will keep the identity of the whistle-blower confidential. All concerns or irregularities raised will be treated with confidence and every effort will be made to keep the whole process confidential.
   
   Exceptions:
   • it is required by law to reveal,
   • The investigation process requires the reveal of the source of information.
   • the information is already in the public domain,
   • the information is given on a strictly confidential basis for the purpose of obtaining professional advice

4. PROTECTION

1. A genuine whistleblower who files a complaint in good faith shall not be discriminated, intimated or harassed. The whistleblower is protected even if the allegations prove to be incorrect or unsubstantiated.
2. However, if an allegation is made frivolously, maliciously or for personal gain, appropriate action may be taken against the whistleblower. This may include disciplinary action (for employee) or reporting the matter to the police (for a 3rd party).

5. REPORTING MODES

1. Complaints are encouraged to be raised in writing.
2. The whistleblower shall provide all critical information and details so that the matter could be assessed and investigated effectively. Details should include the parties involved, dates, description of the incident or concern, how was the impropriety discovered, how long has it been happening, value involved, evidence if any.
3. The whistleblower is encouraged to provide his name and contact details to facilitate investigation. Anonymous complaints with insufficient information may be disregarded due to practical difficulties in conducting a full and effective investigation.
4. All complaints / concerns shall be submitted to:

Contact Mode	Group Corporate Secretariat
Email	[email protected]
Phone	66368656 (9am – 6pm, Monday to Friday)

6. HANDLING OF REPORTS

1. Depending on the nature of the allegation,
   • Senior management may be involved to provide direction and leadership in the investigation process.
   • The matter may be referred to the external regulatory authorities.
   • The perpetrator may be informed to give him the opportunity to respond or explain the matter.
2. The possible outcomes after filing a report are:
   • Disciplinary action, including dismissal, against the wrongdoing employee.
   • Disciplinary action, including dismissal, against the whistleblower employee if the claim is found to be malicious.
   • Warning or termination of services of 3rd-party wrongdoer.
   • Warning or filing a police report against a 3rd party whistleblower if the claim is found to be malicious.
   • No action if the allegation is proved to be unfounded.