Whistle-blowing Policy

Integrity, honesty and fairness are basic principles embedded in Catholic Welfare Services (CWS) governance framework. This is aligned with our aim to build up a culture of openness, accountability and integrity.

Whilst CWS internal controls and procedures are designed to deter, prevent or detect improper activities, we recognize that even the best of internal control systems cannot provide absolute safeguards against all irregularities. CWS provides an avenue for Whistle-blowers, both employees and external parties, who have cause to believe that either fraud or suspected fraudulent practice is being perpetrated in our organization, to come forward and disclose the concerns in good faith without fear of punishment or unfair treatment.

Fraud is defined as the intentional act, false representation or concealment of a material fact which (a) results in a benefit to the perpetrator which he/she would not be entitled to receive in the normal course of employment/business with CWS, or (b) is purportedly for the benefit of CWS but consequently compromises the interest of CWS or its beneficiaries or places CWS in a legally vulnerable position.

For purposes of the whistle-blowing policy, fraud or irregularities would include:

  • Criminal or civil offences (fraud, corruption or theft);
  • Fraud in preparing, evaluating or reviewing any financial statement, recording and maintenance of the financial statements;
  • Actual or suspected deficiencies in or non-compliance with internal controls and procedures;
  • Misrepresentation by an officer or auditors regarding a matter contained or required to be contained in the organisation's financial records, reports or audit reports, and
  • Any conflict of interest in any activity that is or appears to be opposed to the best interest of the CWS.

Reports of irregularities will be channeled to the Chairman of the Audit Committee or Chairman of the CWS Board. All reports will be treated in strictest confidence and promptly investigated.

How to report suspected fraud

Reports should be made in writing with the following information:

  • Section and/or location of the suspected irregularity
  • Key person(s) involved
  • Nature of the suspected irregularity
  • Time period over which the suspected irregularity has occurred
  • Known or estimated value of suspected irregularity
  • Reports should be sent in via email, marked "Confidential" and addressed to the Chairman of the Audit Committee or the Chairman of the Board at the email addresses:

Handling of Whistle-blowing cases

  • An acknowledgement will be sent to the Whistle-blower within 10 working days of receipt of the report.
  • The Chairman of the Board in consultation with Chairman of the Audit Committee may at his discretion delegate the investigation to persons of an investigation committee made up of persons not affected by the issues raised in the Whistle-blower's report.
  • Anonymous complaints will be considered at the discretion of the Chairman of the Board/Audit Committee. Factors to be taken into consideration include:
    - Seriousness of the issues raised
    - Credibility of the concern; and
    - Likelihood of confirming the allegation from attributable sources
  • CWS requires any party directed to provide support in the investigation to provide full support and accord appropriate priority to the investigation.
  • A written report on the results of a fraud investigation shall be submitted to the Audit Committee at the next scheduled meeting of the Audit Committee immediately following the completion of the investigation or at a meeting of the Audit Committee convened at the discretion of the Chairman of the Audit Committee for the purpose of considering the results of the investigation.
  • The Audit Committee may at its discretion table the results of a fraud investigation at a scheduled Board of Directors meeting or request the Chairman of the Board to convene a special Board meeting to consider the investigation results.
  • Where necessary, the Board may refer the fraud investigation results to the appropriate law enforcement and/or regulatory agencies for further action.