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whistleblowing policy

1.    OBJECTIVE

1.1    This will provide an avenue for all parties (including employees, volunteers, vendors and other stakeholders) to duly disclose mismanagement, corruption, illegality or some other wrong doing in CCMC. It will ensure that such concerns are treated seriously and appropriately, and that any person(s) raising such concerns in good faith will be protected from reprisals or retaliation. 
 
1.2    The nature of the concerns covers any of the following acts:

a.    abuse of power or authority; 
b.  financial fraud e.g. misappropriation of assets, embezzlement of funds, accounting manipulation; 
c.    non-compliance of internal controls procedure; 
d.    material conflicts of interest without disclosure; 
e.   bribery and corruption e.g. inappropriate personal gain, gift, or facilitation payments; 
f.     serious endangerment to environment, health, and safety of individuals; 
g.    breach of law and justice; 
h.    improper conduct; and 
i.     concealment, or deliberate failure to report, a known control breach or weakness. 
 
1.3    This policy does not cover grievances. Grievances deal with an individual or personal matter and is not a whistle-blowing concern. Grievances will be handled by the Pastor-Parish Relations and Staff Committee (“PPRSC”). 
 
2.    REPORTING PROCEDURE
 
2.1    CCMC encourages whistle-blowers to put their names to their submission. Concerns expressed anonymously are more difficult to act upon effectively, but they will be considered, taking into account the seriousness and credibility of the issue raised and the likelihood of confirming the allegation from attributable sources and information provided. 
 
2.2    The whistle blower may make report via email to: churchgovernance@ccmc.org.sg or submit a written and sealed report, marked ‘Private & Confidential’ to CCMC Church Office, attention to: Church Governance Chairperson.
 
2.3.  As it is essential for CCMC to have all critical information in order to be able to efficiently evaluate and investigate a complaint, the concern made should include: (a) background, history, and reason for the concern; (b) dates or period of time; (c) nature of concern; (d) name of the person involved in the events; (e) evidence substantiating the concern (eg, documents, e-mails, voice logs, or witness); and (f) contact details (in case further information is required). 
 
2.4    The whistle-blower who reports a concern must meet any reasonable request to clarify any facts and/or circumstances, provide information, and cooperate with an investigation. A lack of information can be a reason to decide not to conduct an investigation and/or to conclude that the concern has no factual basis. 
 
2.5    The whistle-blower is required to keep all information confidential. 
 
2.6    Allegations made in bad faith may result in disciplinary or other appropriate action. 
 
2.7    CCMC will ensure that no disciplinary measures or other steps will be taken against the whistle-blower if such concern made in good faith later turns out to be mistaken, misguided, or inconclusive. 
 
2.8.   The Local Church Executive Committee ("LCEC") will be kept informed of all whistle-blowing cases.

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