Introduction

Man Fut Tong Nursing Home (MFTNH) is committed to a high standard of compliance with accounting, financial reporting, internal controls and auditing requirements and any legislation relating thereto. In line with this commitment, this policy aims to provide an avenue for employees and external parties to raise concerns and offer them assurance that they will be protected from reprisals or victimization for whistle blowing in good faith. The policy shall be posted on our website and made known to employees through internal communication.

Scope

This policy applies to all employees as well as all external parties who have business relationships with MFTNH. These parties include clients of MFTNH, suppliers, contractors, applicants for employment and the general public.

Definition

Whistle blowing is defined as a deliberate, voluntary disclosure of individual or organizational malpractice by a person who has or has had privileged access to data, events, or information about an actual, suspected, or anticipated wrongdoing within or by MFTNH that is within its ability to control.

Reportable Incidents

Below is a list of examples (though not exhaustive) of reportable incidents covered by this policy:

• Concerns about MFTNH’s accounting, internal controls, or auditing matters;
• Impropriety, corruption, acts of fraud, theft and/misuse of MFTNH’s properties, assets,
  or resources;
• Conduct which is an offence or breach of law;
• Serious conflict of interest without disclosure;
• Breach of MFTNH’s policies or code of conduct;
• Concealing information about any of the above malpractice or misconduct;
• Any other serious improper conduct that may cause financial or non-financial loss to MFTNH or damage to its reputation;
• Fraud against members or making fraudulent statements to the Management Committee, members of the public and government or state authorities;
• 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 MFTNH.

Protection against Reprisal and Confidentiality

When raising concern or providing 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, retribution, or harassment. The Management Committee of MFTNH shall appoint a representative to liaise with the whistle-blower and ensure his/her protection and confidentiality.

However, MFTNH shall not condone any frivolous, mischievous or malicious allegations. Employees, found making such allegation, shall be subject to disciplinary action, including dismissal, in accordance to the Human Resource policy on Code of Conduct. Concern or information about an actual, suspected or anticipated wrongdoing as well as its source shall be treated with strictest confidence.

Exceptions to the above include:

• When MFTNH is under legal obligation to disclose such information provided;
• When the information is already in 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
MFTNH but will be investigated on their own merits.

Procedures

Concerns may be raised with or information provided to:

Private & Confidential
For the attention of The President
Man Fut Tong Nursing Home
20 Woodlands Street 82
Singapore 738507
Email address: report@mft.org.sg

Such reports are preferably 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. An acknowledgement of receipt shall be given in each case, and we encourage the whistle-blower to disclose his/her identity.

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 MFTNH Management Committee shall determine the party to conduct the investigation, involving one or more of the following individuals or entities:

• The Finance Sub-Committee, and/or
• The HR Sub-Committee, and/or
• Management staff.

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 Management Committee for its necessary action. The whistle-blower shall be updated on the progress and outcome of the investigation, subject to legal constraints.