Whistleblowing Policy

NTUC HEALTH CO-OPERATIVE LTD.
WHISTLEBLOWING POLICY
 

  1. INTRODUCTION

    NTUC Health is committed to doing the right thing by maintaining high standards of professionalism, integrity, transparency, and accountability, and is dedicated to fostering a culture of openness and trust across the organisation.

    In this respect, NTUC Health aims to provide a whistleblowing channel through which internal and external stakeholders can raise concerns for matters impacting public interest, such as NTUC Health, other employees, customers, suppliers, and the general public, without fear of reprisal or adverse consequences. 
     
  2. PURPOSE

    The Whistleblowing Policy (“Policy”) provides an avenue for employees and external parties to raise genuine concerns about actual or suspected illegal conduct, unethical behaviour, or fraudulent activities within NTUC Health. All reports will be independently investigated, and appropriate actions will be taken. It also offers assurances that the Whistleblower will be protected from reprisals or victimisation for whistleblowing in good faith without malice.
     
  3. REPORTABLE INCIDENTS

    This Policy is intended to cover serious concerns that could have a significant impact on NTUC Health. Some examples of concerns include, but are not limited to:
     
    1. Fraud - This generally relates to any illegal act characterized by deceit, concealment, or violation of trust.
      • Financial irregularities, including improper accounting practices, internal controls, or auditing matters
      • Theft or misuse of NTUC Health's assets and/or resources
      • Intentional provision of incorrect information to public bodies
      • Concealing information about any malpractice or misconduct
         
    2. Corrupt Conduct - This generally relates to actions taken to obtain or offer improper benefits or favors with a corrupt intent.
      • A criminal offence involving corruption, bribery, kickbacks, and blackmail
      • Profiteering from insider knowledge of the business
      • Abuse of power or miscarriage of justice for personal gain
      • Disclosure of confidential information to outside parties
         

    3. Other Malpractices - This generally relates to deliberate breach or circumvention of laws, regulations, or internal policies with serious consequences that are of a matter of public interest.

      • Failure to comply with any legal or regulatory obligation
      • Major Breaches of NTUC Health's policies or Code of Conduct
      • Endanger the health and safety of others
      • Racial or sexual harassment of others
      • Any other misconduct or breaches that may cause significant financial loss, non-financial loss, or damage to NTUC Health's reputation

      General complaints or feedback on NTUC Health's care services, facilities, or business operations should be directed to the NTUC Health Contact Us channels available on the corporate website. Staff grievances should be reported following the NTUC Health Staff Grievance Policy.
       

  4. REPORTING PROCEDURES

    The Whistleblower can address his or her concerns through the independent channel manned by NTUC Health's Internal Auditors (PricewaterhouseCoopers) as follows:

    Email: whistleblowing@ntuchealth.sg
    Hotline: +65 88264975 (9am – 6pm, Monday to Friday)
    Attention: Audit & Risk Committee (ARC) Chairman & members

    When making a report, the Whistleblower should, as far as possible, include the following information:-

    • Your contact information;
    • Name(s) of the alleged person(s)/company(ies);
    • Your relationship with the alleged person(s)/company(ies);
    • Detailed description of the incident (including date, time, location, methods, and action/ behaviour);
    • Period of time the impropriety had been perpetuated;
    • Has management been informed (if yes, please provide the notification date and contact information of the person notified);
    • Particulars of witnesses and/or any other information that may substantiate the incident.

    Whistleblowers may choose to remain anonymous. However, it is encouraged that they provide their identity when reporting a case to facilitate investigation.

    NTUC Health acknowledges that reports from anonymous sources are important and will be treated with due consideration. However, Whistleblowers submitting anonymous reports should be aware that NTUC Health's ability to follow up may be limited if the Whistleblower cannot be contacted for clarification and/or additional information. Where an anonymous report contains sufficient and credible information to warrant further action, the ARC may, at its discretion, initiate an investigation.
     

  5. CONFIDENTIALITY

    All reports are treated with the utmost confidentiality. 

    Every effort shall be made to protect (a) the Whistleblower's identity and (b) the information provided by the Whistleblower, subject to certain exceptions.

    Exceptions for disclosure of the information or identity of the Whistleblower are:
     

    • NTUC Health is under a legal obligation to disclose the information;
    • The information is already in the public domain;
    • The information is given on a strictly confidential basis to legal or auditing professionals to obtain professional advice; and
    • The information is provided to law enforcement authorities for criminal investigations. 

    If the ARC is faced with a circumstance not covered by the above, and where the complainant's identity is to be revealed, the ARC will endeavour to consult the Whistleblower beforehand.
     

  6. PROTECTION

    NTUC Health ensures that Whistleblowers who report concerns in good faith will be protected from reprisals, retaliation, or victimization, even if the allegations are found to be unsubstantiated or incorrect.

    However, NTUC Health reserves the right to take appropriate action if it is determined that a report has been made maliciously, frivolously, or for personal gain. Such actions may include disciplinary measures for employees or referral to law enforcement authorities in the case of third parties.
     

Last updated: 03 July 2025