Objectives

The whistleblowing policy outlines the framework to promote responsible and secure reporting of any possible fraud or wrongful practice within the University of the Arts Singapore Ltd (UAS) for appropriate investigation and action, in confidence and without fear of reprisal.

This policy applies to all staff members of the University, including part-time and temporary appointments.

Reporting of suspected fraud and wrongdoing

A whistleblower is someone who discloses wrongful practices under this policy. A whistleblower can be a UAS Ltd staff member or an external party.

Wrongful practices that can be reported include the mismanagement or misuse of resources, as well as inappropriate conduct and behaviour which are not in line with the UAS Ltd Code of Conduct policy. Examples include, but are not limited to, the following:

1. Financial and non-financial administrative malpractice;
2. Fraud or deliberately including false or incorrect information in the preparation, evaluation, review, audit of financial accounts and records;
3. Impropriety, corruption, bribery or blackmail, theft and/or abuse of the University’s properties or resources for personal benefits;
4. Criminal offences or conduct in breach of laws and regulations;
5. Conflict of interest without disclosure;
6. Intentional provision of incorrect information to the public;
7. Wilful suppression or concealment of any relevant information relating to wrongful practices;
8. Breach of or failure to comply with the University’s Code of Conduct policy; and
9. Any other serious improper matters which may cause financial or non-financial loss to the University or damage the University’s reputation.

Human Resources (HR) (e.g. appeal against HR performance appraisals, promotions, salary adjustments), student management or academic issues (academic grades, academic progression, student discipline matters, etc) will not be within the scope of this policy. Such complaints will be redirected to the respective division(s) for follow-up as needed.

UAS maintains a zero-tolerance policy towards fraud and misconduct. When a Whistleblower learns of any act of fraud or misconduct, or has reason to believe that one may have been committed, the Whistleblower shall report this in writing to the Audit Committee (AC) at the earliest opportunity, via the designated email channel: [email protected], using the attached Whistleblowing Report Form.

The University encourages whistleblowers to put their names and contact details to the allegations wherever possible. Anonymous reports are more difficult to act upon effectively but may still be considered based on the seriousness and credibility of the issues raised, and the likelihood of confirming the allegation from attributable sources and information provided.

Investigation process

All Whistleblowing reports will be evaluated to determine whether further investigation is needed, taking into consideration the quality/ reliability of information, level of sensitivity and severity of the concern etc.

To ensure independence, the investigation panel with at least three members shall be appointed by the AC, as applicable. The composition of the panel will consist of members from Senior Management and/or other relevant divisions, depending on the nature of the complaint raised. It will not involve any member who is involved or implicated in the whistleblowing report.

Where there is a sufficient basis after investigation to show that a staff member has committed fraud or engaged in misconduct, disciplinary proceedings may be initiated against him. This may lead to disciplinary actions being taken against him, which may include dismissal.

Confidentiality and protection of whistleblower

All reports will be treated with the utmost confidence. Every effort will be made not to reveal the identity of Whistleblower(s) who make reports or give evidence in respect of any wrongful practice, to the extent feasible and permissible under the law.

If a report is made in good faith, but a case of wrongful practice cannot be established after investigation, no action will be taken against the Whistleblower if the Whistleblower has acted genuinely and has reasons to believe that there were grounds for the allegations. However, if an allegation is made frivolously, maliciously or for personal gain, disciplinary action may be taken against the Whistleblower.

If a Whistleblower has sufficient grounds to believe that he is being unfairly treated as a result of having made such a report or given such evidence, he may submit, in writing, a complaint to the Audit Committee via the same email channel. The complaint should include details of the unfair treatment, as well as reference to the report and/or evidence that resulted in the unfair treatment.