The Theatre Practice (henceforth known as “Practice”) is committed to a high standard of compliance with accounting, financial reporting, internal controls and auditing requirements and any legislation relating thereto. In line with this commitment, this policy aims to provide an avenue for employees and external parties to raise concerns and offer them reassurance that they will be protected from reprisals or victimisation for whistle blowing in good faith.
This policy applies to all employees as well as to all external parties who have business relationships with Practice. These parties include customers, suppliers, contractors, applicants for employment, and the general public.
Whistle blowing is defined as a deliberate, voluntary disclosure of individual or organisational malpractice by a person who has or has had privileged access to data, events, or information about an actual, suspected, or anticipated wrongdoing within or by Practice that is within its ability to control.
Below is a list of examples (though not exhaustive) of reportable incidents covered by this policy:
- Concerns about Practice’s accounting, internal controls, or auditing matters;
○ Impropriety, corruption, acts of fraud, theft and/misuse of Practice’s properties, assets, or resources;
○ Conduct which is an offence or breach of law;
○ Serious conflict of interest without disclosure;
○ Breach of Practice’s policies or code of conduct;
○ Concealing information about any of the above malpractice or misconduct;
○ Any other serious improper conduct that may cause financial or nonfinancial loss to Practice or damage its reputation;
○ Fraud against audience/donors/partners or making fraudulent statements to members of the public and government or state authorities;
○ Manifestation of intention to mislead, deceive, coerce, or fraudulently influence any internal or external accountant or auditor in connection with the preparation, examination, audit or review of any financial statements or records of Practice.
Protection against Reprisal and Confidentiality
When raising concern or providing information about an actual, suspected, or anticipated wrongdoing, done in good faith; the individual, be it an employee or anyone else, he/she shall be protected against any reprisal such as employment termination, retribution, or harassment.
However, Practice shall not condone any frivolous, mischievous or malicious allegations. Employees, found making such allegations, shall be subject to disciplinary action in accordance to the Human Resource policy on Code of Conduct. Concern or information about an actual, suspected or anticipated wrongdoing as well as its source shall be treated with strictest confidence.
Exceptions to above include:
- When Practice is under legal obligation to disclose such information provided;
- When the information is already in the public domain;
- When the information is given in strict confidence to legal or auditing
- Professionals for the purpose of obtaining professional advice; and
- When the information is given to the Police for criminal investigation.
Concerns or information provided anonymously will still be given due consideration by Practice but will be investigated on their own merits.
Concerns may be raised with or information provided to:
Private & Confidential
For the Attention of Audit Committee Chairman
The Theatre Practice Ltd
54 Waterloo Street
Email: [email protected]
Such reports are preferably made in writing, either in the form of a letter or email, and in detail setting out the background and history of events as well as the reason(s) for concern.
Assessment of the concern or information shall be made with due consideration given to the following factors:
- Seriousness of the issue raised;
- Credibility of the concern or information; and
- Likelihood of confirming the concern or information from the attributable sources
Depending on the nature of the concern raised or information provided, the investigation will be conducted, involving one or more of the following individuals or entities:
- The Audit Committee
- The External Auditor, and/or
- The Police or Commercial Affairs Department.
The amount of contact between the whistle blower and the person(s) investigating the concern raised or information provided will be determined by the nature and clarity of the matter reported. Further information may be sought from the whistle blower during the course of the investigation. When the investigation is completed, the investigating officer(s) will report the findings to the Audit Committee for its necessary action.