SCOPE:

This policy applies to all directors, officers, employees, including full-time, part-time and contract employees of The Photographic Society of Singapore (“PSS”).

 

PURPOSE:

The Society is committed to the highest possible standards of ethical, moral and legal business conduct.  In line with this commitment and the Society’s commitment to open communication and good corporate governance, this policy aims to provide a framework by which employees and external parties may raise concerns in confidence about wrongdoing, malpractice or possible irregularity within the Society and offer reassurance that they will be protected from reprisals or victimisation for whistle blowing in good faith and without malice.

 

POLICY:

This policy is intended to cover concerns over wrongdoing or malpractice within or by the Society (“Alleged Wrongful Act”), including, without limitation, actions that:-

  • may lead to incorrect financial reporting;
  • may be questionable accounting or auditing matters
  • are unlawful;
  • are in breach of a legal obligation or contrary to any Society policy;
  • may pose dangers to the health and safety of any individual;
  • may amount to professional or ethical malpractices;
  • conceals wrongdoings or malpractices;
  • may pose breach of fundamental internal control;
  • misappropriates assets or funds of the Society;
  • constitute violations of this policy;
  • otherwise amount to improper conduct; or
  • are intended to conceal any of the above.
  • Abuse of power and authority

 

SAFEGUARDS:

Harassment or Victimisation

 Harassment, or victimisation of the complainant in retaliation for raising concerns over any Alleged Wrongful Act will not be tolerated and appropriate steps will be taken to ensure the complainant suffers no detriment or retaliation as a result of raising concerns over Alleged Wrongful Act.

Victimisation includes termination of employment; demotion; suspension; written reprimand; retaliatory investigation; decision not to promote; receipt of an unwarranted performance rating; withholding of appropriate salary adjustments; elimination of the employees’ position, absent an overall reduction in work force, reorganisation, or a decrease in or lack of sufficient funding, monies, or work load; or denial of awards, grants, leaves or benefits for which the employee is then eligible, or discrimination or threats of any form.

Confidentiality

 Every effort will be made to protect the complainant’s identity, if so requested, so long as is compatible with a proper investigation. However, it is important to be aware that it may be necessary to reveal the identity of the complainant, to assist in investigation under certain circumstances such as:-

(a) Where the Society is under a legal obligation to disclose information provided.

(b) Where the information is already in public domain.

(c) Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice

(d) Where the information is given to the Police or other authorities for criminal investigation

In the event we are faced with a circumstance not covered by the above, and where the complainant’s identity is to be revealed, we will endeavour to discuss this with the complainant first.

Anonymous Allegations

 The policy encourages employees to put their names to allegations because appropriate follow-up questions and investigations may not be possible unless the source of the information is identified.  Concerns expressed anonymously will be investigated, but consideration will be given to:

  • the seriousness of the issue raised;
  • the credibility of the concern; and
  • the likelihood of confirming the allegation from attributable sources.

Malicious Allegations

 Employees who raise a concern in good faith, which is shown to be unsubstantiated by subsequent investigation, will not have action taken against them. However, an employee who makes an allegation maliciously, in bad faith or knowing it to be untrue or unfounded, may be subject to disciplinary action.

 

REPORTING PROCEDURES:

Reporting

 (a) Any employee shall report promptly to the Chairman of Audit Committee of any unethical or improper practices regarding any item within the scope of this Policy, who shall promptly thereafter provide notice to such other senior management as appropriate.

(b) The Audit Committee Chairman shall notify the sender and acknowledge receipt of the complaint promptly.

(c) All such questions, concerns, suggestions or complaints shall be sent in writing to the Audit Committee Chairman of PSS as follows:

Chairman, Audit Committee

The Photographic Society of Singapore

Email address: pss.auditchairman@pss1950.org

Timing

 All complaints should be made as soon as practicable to enable the Society to take action.

Evidence

 The report should be sufficiently detailed, setting out the background and history of events and reasons for the concern so as to provide the necessary information to Chairman of the Audit Committee as to the nature of the Alleged Wrongful Act.  Although the employee is not expected to prove the truth of an allegation, the employee is encouraged to provide such evidence so as to demonstrate that there are sufficient grounds for concern. If the complainant is not comfortable about writing in, the complainant can telephone or meet the appropriate officer in confidence at a time and location to be determined together.

The Society also recognises that the complainant may wish to seek advice and be represented by the complainant’s legal advisor, if any.

How the Complaint will be Handled

The action taken will depend on the nature of the concern, initial inquiries will be made to determine whether an investigation is appropriate, and the form that it should take.  Some concerns may be resolved without the need for investigation.

The Society assures you that any concern raised on information provided will be investigated, but consideration will be given to these factors:

  • Severity of the issue raised
  • Credibility of the concern or information
  • Likelihood of confirming the concern or information from attributable sources

Report to Complainant

 Subject to legal constraints, the complainant will be given the opportunity to receive follow-up notification on his/her concern within 2 weeks of the complaint:

  • acknowledging that the concern was received;
  • indicating how the matter will be dealt with;
  • giving an estimate of the time that it will take for a final response;
  • telling them whether initial inquiries have been made;
  • notifying them of reason(s) should it be decided that no action is to be taken.

Further Information

 The amount of contact between the complainant and the body investigating the concern will depend on the nature of the issue and the clarity of information provided. Further information may be sought from the complainant.

Information

 Subject to legal constraints the complainant will receive information about the outcome of any investigations.

Monitoring

The Audit Committee will maintain a record of concerns raised under this policy and the outcomes (but in a form which does not endanger confidentiality and where applicable, protect identity of the complainant) and will report as necessary to the Board of Directors.

Disseminating of Policy

A copy of this policy and any subsequent amendments or modification thereof, shall be made available by the Hon. Secretary to all directors, officers, employees, including full-time, part-time and contract employees of the Society, through publication at the notice board/website of the Society or such other means as may be approved by Audit Committee.

Maintenance of the Policy

The Audit Committee has the responsibility for ensuring the maintenance, regular review and updating of this policy. Revisions, amendments and alterations to this policy can only be implemented upon approval by the Audit Committee and the PSS Council and must be notified in writing to the employees when they occur.