Whistle Blowing Policy

1. Purpose


1.1. Wealth Management Institute (“WMI”), as a company limited by guarantee and an Institution of a Public Character, is committed to a high standard of corporate governance and integrity. It takes a serious view of any breach of the Code of Conduct, irregularity, malpractice, impropriety, fraud or other inappropriate activity by all employees in the course of their work.


1.2. In keeping with this commitment and stance, this Whistle-Blowing Policy (the “Policy”) aims to

i. Provide a framework for responsible, confidential and secure whistle-blowing, through which employees, stakeholders and external
parties could:

a) Raise concerns on misconduct, irregularities or malpractices, without fear of reprisal, discrimination or adverse consequences; and

b) Be assured that their concerns will be taken seriously and investigated, and the outcome duly communicated

ii. Deter wrong-doing as well as promote standards of ethical behaviour and a culture of accountability, transparency and integrity in WMI.

2. Definition


2.1. “Whistle-Blowing” refers to a voluntary disclosure of individual or organisational malpractice by a person who has privileged access to data, events, or information about an actual, suspected, or anticipated wrong-doing or malpractice within or by WMI.

2.2. There are two categories of whistle blowers namely:

i. “Internal Whistle-Blowers” refers to employees who report incidents of misconduct involving peer, supervisor or top management staff; and

ii. “External Whistle-Blowers” refers to consultants (e.g. adjunct faculty etc.), customers, service providers, students and other members of the public who report wrong doings of employees.

3. Scope


3.1. This Policy covers concerns about actual or suspected improprieties on the part of Management or employees of WMI reported in good faith, without malice or personal benefit, by either employees or external parties.


3.2. Examples of reportable concerns covered by this Policy include:


i. Breach of or failure to comply with WMI’s policies or code of conduct;

ii. A criminal offence (e.g. fraud, criminal breach of trust, corruption, cheating, forgery, criminal misappropriation and theft);

iii. Unauthorised destruction, removal or inappropriate use of WMI’s records, assets or facilities;

iv. Abuse or misuse of authority;

v. Harassment or intimidation;

vi. Acts to mislead, deceive, manipulate, and coerce or fraudulently influence the preparation, examination, audit or review of any assets
and records of WMI;

vii. Undeclared conflict of interests in any activity or decision made that is not, or appears not to be, in the best interest of WMI; and

viii. Any other serious improper and unprofessional matters which may cause financial or non-financial loss to the WMI, or damage to the
WMI’s reputation


3.3. The above list is intended to give an indication of the kind of conduct which might be considered as “wrong-doing” and is not meant to be exhaustive. Work performance related issues are not regarded as “reportable” concerns and should be handled by the respective Director/Head and/or Head of HR separately.

4. Whistle-blowing Reporting Channels


4.1. Anyone who suspects a wrong-doing in WMI may submit a whistle-blower report form found here to the email address whistleblowing@wmi.edu.sg. The following information should be provided:


i. The location of the alleged wrong-doing;
ii. The key person(s) involved;
iii. The nature of the alleged wrong-doing; and
iv. The details and evidence of the alleged wrong-doing, including but not limited to date or time period over which the suspected wrong-doing
has occurred, photographs, documents, statements, and/or records

4.2. The report will directly reach the Chairman of the Audit and Risk Committee (ARC). An initial review will be conducted to determine whether an investigation is required, following which an investigation panel is being convened.

4.3. The whistle-blower is encouraged to identify himself/herself when raising a concern or when providing information. This is to enable the clarification of information to ascertain the facts of the case, as well as to provide a reply to the whistle-blower upon conclusion of the investigation.

4.4. Concerns expressed or information provided anonymously will be given due consideration and investigated on the basis on its own merits. However, vague or insufficient information may impede the investigation process and the ARC Chairman may decide not to pursue the matter further if there is insufficient information available or where it is determined that there is no merit to the complaint.

5. Safeguards and Confidentiality


5.1. The Policy is designed to enable management and staff to raise concerns with safeguards put in place to facilitate the process, by ensuring protection against reprisals for the whistle-blower and maintaining confidentiality of the whistle-blower and the concerns raised.

i. Protection: When raising concern or providing information about an actual, suspected, or anticipated wrong-doing, done in good faith; the
individual, be it an employee or anyone else, shall be protected against any reprisal.

ii. Confidentiality: Concern or information about an actual, suspected or anticipated wrong-doing as well as its source shall be treated with
strictest confidence.
iii. Propriety: WMI shall not condone any frivolous, mischievous or malicious allegations.

5.2. Exceptions to the above include:

i. When WMI is under legal obligation to disclose such information provided;
ii. When the information is already in the public domain;
iii. When the information is given in strict confidence to legal or audit;
iv. When the information is given to professionals (e.g. lawyers, forensic experts etc.) for the purpose of obtaining professional advice in relation to the case; or
v. When the information is given to the Police for criminal investigation


5.3. Due care will be taken to ensure that evidence and information received will not be withheld, destroyed, or tampered with.

5.4. After making a report, the whistle-blower should refrain from further investigation of the incident, confrontation of the accused or further discussion of the incident.

6. Handling of Reports


6.1. WMI assures whistle-blowers that the ARC will consider and investigate any legitimate concern or incident raised, or information in connection with it.

6.2. Where the whistle-blower has identified himself/herself and provided his/her contact details, he/she will be kept informed of the progress of the investigations and if appropriate, of the final outcome.