Whistle Blowing Policy
This policy applies to all employees and beneficiaries (mainly our Home residents and our clients under the Safe and Strong Families Reunification (“SSFR”) and Childcare programmes, and their families) as well as to external stakeholders of Chen Su Lan Methodist Children’s Home (“Home”), such as suppliers, volunteers, donors, contractors and the general public.
The Whistleblowing policy serves to achieve the following objectives:
- To encourage employees and other stakeholders to feel confident in raising serious concerns regarding any aspect of the Home’s operations.
- To provide an avenue for employees and other stakeholders to raise these concerns in confidence.
- To protect employees and other stakeholders from possible reprisals or victimization if they have a reasonable belief that they had made any disclosure in good faith.
- To provide a formal process to raise and handle whistle blowing concerns.
This policy is intended to cover whistleblowing concerns, i.e., misconduct, malpractice or wrongdoing that may be detrimental to the Home or public interest. It could be something which adversely affects our beneficiaries, their families, staff, volunteers, the public, or the Home itself. The policy does not cover grievances which are personal complaints against an individual’s own employment situation.
Examples of whistleblowing concerns may include the following but are not limited to:
- Health and safety risks to our residents, employees and stakeholders
- Unsafe (risk of harm) resident care
- Unsafe (risk of harm) SSFR client care
- Possible fraud or corruption
- Misappropriation of assets or funds
- Conduct which is an offence or a breach of the law
- Criminal activities
- Sexual, physical or emotional abuse
- Concealing information about any malpractice or misconduct
- Failure to comply with the Home’s policies or code of conduct
- Intentional provision of incorrect information to public bodies
All concerns will be treated with strict confidentiality and every effort will be made not to reveal the identity of the whistleblower if requested. At the appropriate time, however, the whistleblower may be required to come forward as a witness.
The informant’s identity will be treated with strict confidentiality, with the exception of the following situations:
- When required by law to reveal the identity of the whistleblower
- When the whistleblower waives the right to confidentiality
- When the identity of the whistleblower is already publicly known
- When information is given on a strictly confidential basis for obtaining professional advice
Safeguards are in place to preserve confidentiality by keeping the report and case information secure and accessible only to designated persons.
This policy encourages the whistleblower to put his/her name to allegations. The concerns expressed anonymously will be considered on the basis of its merits and at the discretion of the recipient of the whistleblower’s report, which can either be the line manager or main point of contact (if a vendor, supplier, donor, partner or volunteer), Head of Home, or Chairman of the Audit Committee (“Report Recipient”).
In exercising this discretion, the factors to be taken into consideration would be:
- Seriousness of the allegation
- Credibility of the complaint
- Likelihood of confirming the allegation from attributable sources
Vague or insufficient information will impede the investigation process and its outcome. Whistle- blowers are encouraged to provide as much details as possible.
The informant who highlights concerns or provides information regarding actual, suspected, or anticipated wrongdoing done in good faith shall receive protection from any reprisal such as employment termination, retribution or harassment.
However, where allegations have been made frivolously, maliciously or for personal gain, appropriate action will be taken against the informant.
Monitoring of the Whistleblowing process
The Audit Committee will regularly review the whistleblowing policy and process.