To facilitate the attainment of the highest possible standards of corporate governance, SAL has, on the advice of PricewaterhouseCoopers, its external auditor, put in place a policy on whistle-blowing (the Policy). The Policy seeks to ensure that staff of SAL can bring unethical or fraudulent practices or wrongdoings at the work-place to light so that damage control or remedial action can be taken promptly.
The Policy sets out procedures for staff of SAL to report to an independent Whistle-blowing Investigation Officer (WBIO) matters relating to breaches of:
- workplace policies ensuring effective and efficient operations;
- measures safeguarding assets and resources of SAL;
- reliable and truthful financial reporting;
- applicable laws and regulations; or
- fair treatment of all staff, especially with regard to health and safety issues;
which result in either financial or reputational loss, both actual and potential, to SAL. The Policy provides procedures to enable wrongdoings at all levels to be reported and such reports to be properly followed up on. It also provides safeguards to minimise the likelihood of abuse of the Policy. Thus, while the procedures would apply to unethical or fraudulent practices or wrongdoings within SAL, they would not apply to any such issues outside of the SAL. Unless expressly stated herein, for the sake of clarity, these procedures would also not be applicable to persons who are not staff of SAL.
Staff of SAL are notified of the Policy. They are briefed, in particular, on the procedure for the making of reports, the process which their report will set in motion, the rights and responsibilities of the WBIO, how their identities are kept confidential, and how their rights are protected after they report the wrongdoing(s).
The WBIO has clearly-defined responsibilities and sufficient powers to make effective and adequate investigations. If necessary, the officer being investigated could be suspended from duty pending investigation. All findings of the WBIO are conveyed to the Audit Committee (chaired by a High Court Judge), which will then inform the President of SAL (the President) and the senior-level Executive Board of SAL. The President and the Executive Board will then decide on the appropriate action(s) to be taken.
Law firms and other external parties dealing with SAL may also direct complaints (on matters pertaining to SAL only), to the WBIO (Mr David Lee, Assistant Registrar of the Supreme Court), who may be contacted at email: [email protected] or tel: 6332 1024.
 “Staff” refers to SAL’s employees and consultants engaged by SAL.