Whistleblowing

SDC Whistleblowing Policy

1. Introduction

1.1

This Policy is intended to provide a platform for employees and external parties (e.g. consultants, contractors, suppliers and island partners) to report any wrong-doings, unlawful conduct or malpractices within or involving Sentosa Development Corporation (SDC) and its subsidiaries and proprietary club (SDC Group). Individuals can raise their concerns about possible improprieties without fear of reprisals or adverse personal consequences.

1.2

The concern raised should generally cover the following without limitation:
- A criminal offence or fraudulent activity, e.g. asset misappropriation, corruption/bribery, financial/procurement irregularity, financial statement fraud;
- A failure to comply with company policies or any legal or regulatory obligation;
- Health and safety of any individual being put at risk;
- Racial or sexual harassment;
- Deliberate concealment relating to any of the above; or
- Alleged retaliation against employees and/or other persons who, in good faith, make reports in line with this policy.

2. Objectives

2.1	The Policy aims to: - Provide a confidential platform for whistleblowers and encourage them to raise concerns in good faith without fear of reprisals; and - Ensure that sound processes are in place to timely respond and act upon those reports with appropriate follow up actions.

3. Who is covered under the policy and protection accorded

3.1

The policy is applicable to all SDC Group employees and external parties (e.g. consultants, contractors, suppliers, island partners and their employees).

3.2

SDC will not tolerate the harassment or victimization of anyone raising a genuine concern, nor in the case of employees, to be put at risk of losing his/her job or suffering any form of retribution as a result, provided that:
- The report is made in good faith;
- he/she reasonably believes that the information and any other allegations contained therein are substantially true; and
- he/she is not acting for the purposes of personal gain or personal vendetta or to satisfy a personal grouse

4. Anonymity

4.1

SDC recognizes that whistleblowers may wish to raise a concern either anonymously or in confidence under this Policy. However, in order to effectively evaluate and investigate a concern, we encourage whistleblowers to identify themselves, where possible, to facilitate the appropriate and necessary follow-up clarifications. The strictest confidentiality will be maintained and only those involved in the investigation will know the whistleblower’s identity.

4.2

If a whistleblower request that their identity be protected, SDC-IAD will not disclose it without consent, subject to any legal requirements to the contrary. Under certain circumstances, SDC may be under obligation to reveal the whistleblower’s identity to parties such as lawyers, the police or investigators.

5. Procedures on reporting of concerns

5.1

The reporting channels are independently managed by the Internal Audit Department (SDC-IAD). Reports on any improprieties can be made in writing to the Director, Internal Audit through the following channels:

Email:	whistleblow@sentosa.gov.sg
Mail:	Director, Internal Audit 39 Artillery Avenue, Singapore 099958 (Mark on the envelope: “Private & Confidential – To be opened by Addressee Only”)

5.2

The following information should be made available whenever possible:
- Particulars of the whistleblower, i.e., name and contact number/email
- Incident description, i.e., date, time and place of the incident, how the incident occurred, frequency of occurrence, value of money or assets involved, etc.
- Identity and particulars of party/parties involved, including details of any witness
- Circumstances leading to the improprieties
- Any evidence, documentation other relevant information that would assist in the evaluation, investigation or substantiation of the reported matter.

5.3

This policy does not affect anyone’s rights or obligations to report directly to other relevant internal or external authorities. Concerns relating to Director, Internal Audit can be reported directly to the Audit Committee.

6. Abuse of system

6.1	The making of false or reckless allegations and the abuse of this mechanism are prohibited, and whistleblowers may be the subject of disciplinary or other legal action if the reports or allegations are malicious, frivolous or simply to cause anger, irritation, or distress.

7. Procedures on review of whistle-blowing reports received

7.1	All whistleblowing reports shall be received by the Director, Internal Audit, who will independently assess the matter so that these are properly considered, escalated and addressed (as appropriate) by the Management or other parties.