IREIT Global Group Pte. Ltd. (the “Company”), the manager of IREIT Global, has put in place a channel to allow whistleblowing by all stakeholders to report, without fear of retaliation, discrimination or adverse consequences, on any concerns about illegal, unethical, unprofessional, unacceptable practice and misconduct, or otherwise inappropriate behaviour or activities that they may observe on its employees, officers and directors in the course of their work.
Who should report?
- Any other parties whom the Company, IREIT Global or the subsidiaries of IREIT Global (the “Group”) has a business relationship with
What to report?
Reportable concerns include and are not limited to the following activities (actual or suspected):
- Financial malpractice or impropriety
- Fraud or corruption or any dishonest act
- Criminal activity including forgery or falsification of and alteration to Company documents/accounts
- Breach of legal obligation (including negligence, breach of contracts)
- Any forms of harassment
- Conflict of interest without disclosure
- Abuse of power or authority
- Danger of destruction to and unsafe practices in the work environment
- Improper conduct or unethical behaviour (eg. disclosure of confidential and proprietary information to party(ies) without prior authorisation and a need-to-know basis; accepting/seeking anything of material value from business associates eg. vendors)
- Attempts to conceal any of the above
- Any other similar or related inappropriate conduct or activities that might lead to other damaging implications to the Group.
How to report?
Such concerns should be reported in writing and by emailing it to firstname.lastname@example.org.
Handling of whistleblowing reports
All whistleblowing reports will be routed directly to the Chairman and members of the Audit and Risk Committee, and the Chief Financial Officer to allow independent investigation of the concern raised and to determine the appropriate follow-up actions. All information provided will be investigated, but consideration will be given to these factors:
- Severity of the concern raised;
- Credibility of the concern or information; and
- Likelihood of confirming the concern or information from other sources.
Depending on the nature of the concern raised or information provided, the investigation conducted may involve one or more of these persons or entities:
- The Audit and Risk Committee;
- The external and/or internal auditor;
- Forensic professionals or private investigators; and
- The police, Commercial Affairs Department or other authorities.
If, at the conclusion of an investigation, it is determined that a violation has occurred or the allegations are substantiated, remedial action commensurate with the severity of the offence will be taken.
Regardless of the significance of allegations or the outcome, all whistleblowing reports will be tabled and discussed at Audit and Risk Committee meetings.
Responding to whistleblowing reports
The Audit and Risk Committee Chairman will write to the whistleblower within three days to acknowledge receipt of the concern. Within a reasonable timeframe, the Audit and Risk Committee Chairman will write to the whistleblower to:
- Indicate how it propose to deal with the concern;
- Give an estimate of time it will take to provide a full response;
- Inform whether any initial enquiries have been made;
- Supply information on support available to the whistleblower; and
- Inform the whistleblower if further investigations will take place and if not, to provide reasons.
Issues to consider
It is necessary for the Audit and Risk Committee to be given all vital information in order to be able to effectively and investigate any concerns. As such, the report should be as specific and detailed as possible. It should contain basic details such as the parties involved, dates or period of time, the type of concerns, evidence substantiating the concerns, and contact details.
Anonymous reports will be disregarded and no further action will be required. All whistleblowers are expected to:
Acting in good faith means without malicious intentions and in the best interest of the Group. If allegations are proven to be malicious, appropriate actions, including legal action and blacklisting, may be taken.
- Act in good faith;
- Have reasonable grounds; and
- Not make the report for personal gain.
Confidentiality of identity
The identity of the whistleblower will be kept confidential. Consent will be sought should there be a need to disclose the identity of the whistleblower for investigation purposes, subject to the following circumstances:
- Where there is a legal obligation to disclose information provided;
- Where the information is already in the public domain;
- Where the information is given on a strictly confidential basis to legal or auditing professionals for the purpose of obtaining professional advice; and
- Where the information is given to the police or other authorities for criminal investigation.
In the event the Audit and Risk Committee is faced with a circumstance not covered by the above, and where the whistleblower’s identity is to be revealed, it is the endeavour of the Audit and Risk Committee to discuss this with the whistleblower first.
The report should be factual and contain as much information as possible to facilitate proper assessment and urgency of investigative procedures.
During the course of investigation:
- The whistleblower and any party(ies) or personnel may be contacted for further information and/or any documents that can shed light on the investigation.
- Great care, sensitivity and timeliness must be exercised whilst carrying out the investigation to avoid misleading or wrongful conclusions or actions which may affect the evidence of the investigation or result in wrongful accusations of any party(ies).
- Recommended actions will be initiated.
- Investigation results are confidential and will not be disclosed or discussed with anyone other than those with a legitimate need to know. The whistleblower will not be updated on the outcome of the investigations other than confirmation that the concern has been dealt with by the Company. This is to safeguard all parties, including the Company.
In consideration of all whistleblowing activities, the Audit and Risk Committee will then decide whether to report the concern to the Board of Directors.
The Audit and Risk Committee, and where appropriate the Board of Directors, are to review actions taken by the Company towards whistleblowing initiatives and ensure that fraudulent practices are reviewed without prejudice or biasness, and executed with professional integrity in compliance with the Company’s policy.
Immunity or Protection from Disciplinary Action
The Company encourages the reporting of any concerns about illegal, unethical, unprofessional, unacceptable practice and misconduct, or otherwise inappropriate behaviour or activities and in pursuit thereof, shall use its best endeavours to grant immunity or protection to whistleblowers. A whistleblower acting in good faith and who has not himself or herself engaged in such concerns shall be protected from any forms of harassment, retaliation, adverse employment or career advancement consequence or discrimination, including but not limited to demotion, dismissal or reduction of compensation or privileges of employment.
The Company reserves the right to modify the contents to maintain compliance with the applicable laws and regulations or accommodate organisational changes.
Approved and adopted by:
Audit and Risk Committee on 10 May 2018
Board of Directors on 10 May 2018