Whistle-blowing Policy

Whistle-blowing Policy for NorthLight School

INTRODUCTION

1 .  NorthLight School (NLS) is committed to a high standard of compliance with accounting , financial reporting, internal controls and auditing requirements and any legislation relating thereto. All Directors and Staff are expected to maintain high standards of business and personal ethics, honesty and integrity in carrying out their duties and responsibilities and to conduct themselves in a professional manner at all times to bring credit to and enhance the image of the company.

2 .   Whistle-blowing is the act of reporting misconduct within an organization and this policy provides an avenue for directors, employees and external parties to bring to the attention of the Board any misdeed or impropriety committed by the directors, management and staff of the company. The policy also offers them reassurance that they will be protected from reprisals or victimisation for whistle-blowing in good faith.

SCOPE

3 .  The whistle-blowing policy shall surface and address concerns over any action or omission within the company relating to unlawful conduct, financial malpractice and fraud, criminal violation of prevailing laws, rules and regulations, conflicts of interest, non-compliance of company’s internal controls and procedures, unauthorised disclosure of information, abuse of authority for personal gain and discrimination and intimidation of staff in the course of work.

RESPONSIBILITY

4 .  The Board Chairman, Chairman of the Audit & Risk Committee, and the School Principal shall be the team authorised to investigate all concerns raised.

5 .  Where the concern raised is against one of the team members, the other members may appoint additional directors or school management members to assist in the investigation.

6 .  The Vice-Principal (Administration) and Manager (Finance & Procurement) are responsible to keep the policy updated and communicate the information to stakeholders including via the school website and other appropriate platforms e.g. staff contact time, school intranet.

REPORTABLE INCIDENTS

7 .  Below is a non-exhaustive list of examples of reportable incidents covered by this policy:

• Concerns about NLS’s accounting, internal controls, or auditing matters;

• Impropriety, corruption, acts of fraud, theft and/misuse of NLS’s properties, assets, or resources;

• Conduct which is an offence or breach of law;

• Serious conflict of interest without disclosure;

• Breach of NLS’ policies or code of conduct;

• Concealing information about any of the above malpractice or misconduct;

• Any other serious improper conduct that may cause financial or nonfinancial loss to NLS or damage its reputation;

• Fraud against or making fraudulent statements to the Board, members of the public and government or state authorities;

• Manifestation of intention to mislead, deceive, coerce, or fraudulently influence any internal or external accountant or auditor in connection with the preparation, examination, audit or review of any financial statements or records of NLS.

• Unfair practices toward staff or external parties e.g. unfair HR practices, intimidation of staff.

SAFEGUARDS

8 .  The policy is designed to enable directors, management and staff to raise concerns and the safeguards are put in place to facilitate the process, namely to ensure protection against reprisals for the whistle-blower and to maintain confidentiality of the identity of the whistle-blower and the concerns raised.

a.   Protection: When raising concern or providing information about an actual, suspected, or anticipated wrongdoing, done in good faith; the individual , be it an employee or anyone else, he/she shall be protected against any reprisal.

b.   Confidentiality: Concern or information about an actual, suspected or anticipated wrongdoing as well as its source shall be treated with strictest confidence .

c.    Propriety: NLS shall not condone any frivolous, mischievous or malicious allegations.

9 .  Exceptions to the above include:

• When NLS is under legal obligation to disclose such information provided;

• When the information is already in the public domain;

• When the information is given in strict confidence to legal or auditing

• Professionals for the purpose of obtaining professional advice; and

• When the information is given to the Police for criminal investigation.

10 .  Concerns or information provided anonymously will still be given due consideration by NLS but will be investigated on their own merits.

PROCEDURES

11 .  Upon receiving a concern raised in writing or in email, assessment of the concern or information shall be made with due consideration given to the following factors:

• Seriousness of the issue raised;

• Credibility of the concern or information; and

• Likelihood of confirming the concern or information from the attributable sources

12 .  Depending on the nature of the concern raised or information provided, the investigation will be conducted, involving one or more of the following individuals or entities:

• The Audit & Risk Committee

• The External Auditor, and/or

• The Police or Commercial Affairs Department.

13 .  The amount of contact between the whistle-blower and the person(s) investigating the concern raised or information provided will be determined by the nature and clarity of the matter reported. Further information may be sought from the whistle-blower during the course of the investigation. When the investigation is completed, the investigating officer(s) will report the findings to the Audit & Risk Committee for its necessary action. The school will compile the number of concerns sent to the whistle-blowing channels and update the ARC at each meeting.

REPORTING A CONCERN

14 . All concerns should be made in writing, either in the form of a letter or email, and should include the background, history of events, reasons for raising the concern, persons involved and evidence to support the concern raised.

15 .  The concern raised can be raised via email with the subject title ‘Whistle-blowing Policy’ and addressed to the relevant investigation team members.

16 .  For reporting by mail, the whistle-blower can send the letter to the following address and attention to the relevant investigation members: