1. Objective & Definitions
1.1 Bethesda Cathedral (hereinafter the “Church” or “BC”) is committed to maintaining a high standard of integrity in the conduct of its affairs. At BC, we expect our Church Board, leaders and employees to conduct themselves with professionalism, honesty and integrity in the discharge of their duties.
1.2 As part of good corporate governance and in line with Christian doctrines and the values of the Church, BC has established this whistle-blowing policy (hereinafter called the “Policy”) to set out trusted avenues for the reporting of any Wrongdoing (as defined in paragraph 3 below) for further investigation by the Church without fear of reprisals or adverse consequences to a Whistleblower (as defined in paragraph 1.3 below).
1.3 In this Policy, the term “Whistle-Blowing” refers to a deliberate or voluntary disclosure of any inappropriate, unethical or unlawful behavior, malpractice or irregularity within the Church (“Wrongdoing”) by a person who has or has had privileged access to data, events, or information about any such actual, suspected or anticipated Wrongdoing that is within his/her knowledge or ability to control, including the Church’s employees, suppliers, service providers and Members (as defined in the Constitution of the Church) (“Whistleblower”).
1.4 Unless expressly defined in this Policy, or if the context indicates otherwise, all terms in this Policy shall have the same meaning(s) as specified in the Constitution of Bethesda Cathedral, as updated from time to time.
2. Reportable Incidents
2.1 The following are a list of examples (though not exhaustive) of reportable incidents which constitute Wrongdoing covered by this Policy:
2.2 For the avoidance of doubt, any legitimate expression of personal opinion, unhappiness, complaints and grievances concerning church operational matters and/or service quality, human resources policy, or private unhappiness and disputes between Members are not matters covered under this Policy.
3. Protection Against Reprisals and Confidentiality
3.1 All reports received by the Church of any Wrongdoing are handled in confidence, and will be used only for the purpose of conducting investigations by the Investigating Committee to be appointed by the Church Board and to take remedial action pursuant to the same, in accordance with the applicable laws and regulations of Singapore. In this regard:
3.2 In the event where the identity of the Whistleblower may need to be revealed on a need-to-know basis (e.g. requirement to testify in court should such a situation arises), the Church shall discuss and seek prior written consent of the Whistleblower.
3.3 The Church will not tolerate any reprisals against a Whistleblower or the harassment or victimization of any Whistleblower reporting on any Wrongdoing in good faith, even if the Whistleblower may turn out to be mistaken after the conclusion of investigations.
3.4 Notwithstanding paragraph 3.3 above, the Church prohibits the abuse of the investigation process set out in this Policy for the making of any false reports that are frivolous, vexatious, or which are motivated by malice or bad faith; and reserves the right to pursue legal and/or disciplinary action against such abusers.
4. Whistleblowing Reporting Procedures
4.1 The Whistleblower should address his/her concern to the Chairman of the Church Board. Upon receipt of the complaint, the Church Board shall appoint an Investigating Committee to investigate the complaint.
4.2 The complaint shall set out in detail the background and history of events as well as the reason(s) for concern. All concerns raised will be independently assessed to ensure that they are fairly and properly considered. As it is essential to have all critical information in order to be able to effectively evaluate and investigate a compliant, the report made should provide as much information and be as specific as possible, such as:
4.3 Where possible, the Whistleblower may disclose his personal details (name, contact details: email address and or telephone/handphone number) to enable the Investigating Committee to contact the Whistleblower for further information or clarifications during the course of investigation.
4.4 Concerns expressed anonymously are difficult to act upon effectively. However, they may be considered, taking into account the severity and credibility of the issues raised and the likelihood of confirming the concern or information from the attributable sources on the information provided.
4.5 The channels of reporting are to be made in writing, either in the form of a letter or email marked ‘Confidential’ and addressed to:
4.6 In the event that the complaint involves the Chairman of the Church Board, the report shall be addressed to the Vice Chairman of the Board of Elders or to the Senior Pastor.
5. Investigation Procedure
5.1 Upon receipt of a complaint from a Whistleblower, the Chairman of the Church Board shall immediately inform the Church Board and within 10 days convene an Investigating Committee comprising
5.2 A member of the Investigating Committee shall recuse himself/herself from participating in any investigations or any deliberations and decisions relating to any investigations if any actual, potential or possible bias or conflict of interest may arise.
5.3 The Investigating Committee shall:
5.4 Depending on the nature of the concern raised or information provided from the Whistle-Blower, the Investigating Committee may seek the assistance of external parties in its investigations, including but not limited to the following:
5.5 The Investigating Committee shall inform the subject of the complaint or allegations made against him/ her and provide him/her with an opportunity to respond to the complaint or allegations in writing. Unless the consent of the Whistle-Blower is obtained in writing, the communication of the complaint or allegations to the subject of the complaint shall preserve the anonymity of the Whistle-Blower. Where more information is required from the Whistle-Blower, the Investigating Committee may contact the Whistle-Blower (if his/her identity is known) to gather more details or evidence
5.6 The Investigating Committee shall review all complaints received and submit its findings in an investigation report (“Investigation Report”) no later than thirty (30) days from the date of convening of the Investigating Committee by the Chairman of the Church Board unless there are circumstances that warrant an extension. The Investigating Committee may extend the aforesaid deadline by another thirty (30) days if more time is needed for investigations and shall inform the Chairman of the Church Board of such extension prior to the expiry of the first thirty (30) days.
5.7 The identity of the Whistle-Blower shall be kept strictly confidential and shall not be disclosed in the Investigation Report or documented in any Church report thereafter.
5.8 The Church Board will review the Investigation Report and the recommendations and approve on the course of action to be taken. The Church Board shall thereafter inform the Whistle-Blower of the corrective/preventive actions to be taken.