PDPA Policy | Playeum

Playeum's Whistleblowing Policy

1. Policy Objective

Whistle-blowing is the act of reporting concerns, in good faith, about misconduct or malpractice that may be detrimental to Playeum and/or the public interest. It is an essential part of sound governance.

This policy reflects the Board’s commitment to proper ethical behaviour and ensures employees and stakeholders can report concerns without fear of reprisal or unfair treatment.

The objectives are to:

Provide a formal process and framework for raising and handling whistle-blowing concerns.
Encourage employees and stakeholders to report improper, unethical, or inappropriate behaviour.
Assure that all reports will be addressed, treated confidentially, and safeguarded from reprisal.
Promote a culture of accountability, integrity, and transparency.

2. Policy Scope

This policy applies to employees and relevant stakeholders who, in good faith, report misconduct or malpractice.

3. Roles & Responsibilities

Board of Directors: Oversees whistle-blowing practices in Playeum.
Whistle-blowing Governance Officer (or designated staff): Ensures procedures are carried out according to the policy
Other Stakeholders: May include the whistle-blower, alleged party, receiving staff, investigator, Head of Internal Audit, and Board members.

4. Confidentiality and Protection

Playeum respects and preserves the confidentiality of whistle-blowers, keeping reports secure and accessible only to designated persons.
Anonymous reporting is permitted.
The Governance Officer ensures confidentiality safeguards for both the whistle-blower and those involved in the case.
If lawful disclosure of the whistle-blower’s identity is required, Playeum must first seek the whistle-blower’s consent.

5. Whistle-Blowing Process

5.1 General Principles

Reports must be made in good faith. False reports made for personal gain or malicious intent will result in disciplinary action.

Reports can be verbal or written to:

Executive Director
Playeum Ltd
21 Bedok North Street 1
Common Ground Civic Centre
#01-01
Singapore 469659

Or email: whistleblowing@playeum.com

All reports, including anonymous ones, will be logged in a register.
Acknowledgements will be sent if the whistle-blower’s identity is known.

5.2 Reporting Channels

Immediate Supervisor → escalates to the Governance Officer.
If the Supervisor is involved/reluctant → directly to the Governance Officer.
If key management is involved or the case is serious → report to the Board Chair or designated Board member (e.g. Audit Committee Chair).
External reporting: Concerns may also be reported to the Commissioner of Charities or relevant agencies.

5.3 Timelines

Escalation to Governance Officer: within 3 days.
Formal acknowledgement: within 2 weeks.
Updates and closure: communicated within reasonable timeframes.

5.4 Safeguards

Confidentiality and protection from reprisal, discrimination, or other adverse consequences are guaranteed.

6. Process Stages

6.1 Assessment

Conducted by the Governance Officer (or designated staff).
Determines whether the concern is appropriate (not a grievance), adequately detailed, and significant (e.g. health/safety risks, legal breaches, fraud).
Anonymous reports are assessed for substantiating evidence.
All assessments are documented and communicated to appropriate parties.
Inappropriate concerns may not be investigated; malicious reports may result in disciplinary action.
Whistle-blowers (except anonymous ones) may be contacted for clarification.

6.2 Investigation

Investigator appointed by Governance Officer; Board/Audit Committee endorsement may be sought.
Independence, integrity, and competence of investigators ensured.
Investigation process includes:
1. Defining objectives.
2. Gathering evidence.
3. Reporting findings and recommendations.
Parties involved may include whistle-blower, alleged party, witnesses, staff, management, Board members, or external experts.
Duration depends on complexity.
Investigation report reviewed by Board or Audit Committee; external advice may be sought.

Possible outcomes:

No grounds → case closed.
Grounds found → disciplinary action (e.g. reprimand, suspension, termination) and remedial measures implemented
Possible criminal offence → legal advice sought and matter referred to authorities.

Whistle-blowers will be notified of the outcome. If dissatisfied, they may escalate internally or externally.

6.3 Action

No grounds: Governance Officer closes the case.
Grounds found: Disciplinary action assigned to responsible person (ED/Board Chair/Director); remedial measures implemented.
External referrals: Acknowledgement and tracking required.
The Governance Officer ensures closure review and follow-up with the Board/Audit Committee.

7. Communications

Policy provided to all employees upon joining Playeum by the Executive Director.
Accessible to all staff via Common Drive.
Updates are communicated and explained as appropriate.
Staff involved in whistle-blowing receive relevant training.

8. Role of the Whistle-blowing Governance Officer

Conduct or oversee inquiries into concerns.
Ensure investigations are led by independent, qualified persons.
Recommend external investigators if necessary.
Ensure responses and actions are appropriate.
Guarantee safeguards for whistle-blowers against reprisal, discrimination, or harassment.
If concerns involve key management, the Board appoints members (e.g. Audit Committee Chair) to assume the role.

9. Questions to Guide Reporting

What misconduct occurred?
Who committed the misconduct?
When did it happen and when did you notice it?
Where did it happen?
Have you approached the person? If yes, what was said?
Do you have evidence to support your concern?
Were other people involved? If yes, who?
Do you have further details that may assist the investigation?
Have you reported the incident internally or through other channels? If yes, to whom?