Purpose

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The Bible Church, Singapore (“the Church”) is committed to good governance and requires its leaders and staff to fulfil their responsibilities with honesty and integrity, in compliance with all applicable laws and regulations.

 

The objective of the Whistle-blowing Policy is to establish a confidential channel within the Church for members, employees, or other external parties to report genuine concerns about suspected or actual illegal, unethical, or inappropriate conduct or practices occurring within, by, or under the control of the Church, so that the Church may evaluate these concerns and take appropriate follow-up action.

 

Whistle-blowers

 

A whistle-blower is an individual who, in good faith, reports any suspected or actual illegal, unethical, or inappropriate conduct or practices occurring within, by, or under the control of the Church. A whistle-blower’s role is to report, not to investigate the facts or determine the action to be taken.

 

A report is made in good faith when it is made: (i) out of genuine concern, without malice, recklessness, or consideration of personal benefit; and (ii) out of a reasonable basis to believe that the report is true. A report is not made in good faith when it is made maliciously, recklessly, or is known to be false.

 

Whistle-blowing Committee

 

The Whistle-blowing Committee (“the Committee”) will comprise: the Lead Pastor, the Council Chairman, and two other church members appointed by the Church Council. If any member of the Committee faces any potential conflict of interest in a matter, he/she shall recuse him/herself for that matter.

 

The Committee’s role is to carry out confidential investigations to establish if there is sufficient evidence to support the whistle-blower’s concern. The Committee will:

1. Receive, handle and investigate reports;

2. Determine the responses, including who will be informed and/or who will be enlisted to assist in investigations; 

3. Decide whether to seek advice from legal or audit professionals, or refer the matter to the relevant authorities;

4. Report the findings to the Church Council; and

5. Where appropriate, provide updates to the whistle-blower on the progress of the investigations and notify him/her of the final outcome.

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Depending on the nature of the report or the information provided, the investigation may be conducted involving the following parties:

1. The Church Council;

2. An external auditor or legal advisor;

3. The Police;

4. The Registrar of Societies.

 

Where there is insufficient evidence to establish the whistle-blower’s concern, but there is no evidence that the report was made in bad faith, the Committee must closely monitor the matter reported for a period to be determined by the Committee.

 

Reportable Matters

 

Reportable matters under this Policy include, but are not limited to, the following:

1. Financial matters e.g. fraudulent activities or transactions, embezzlement, corruption, misusing church funds or resources;

2. Abuse of power or authority e.g. any form of bullying, harassment, or discrimination;

3. Inappropriate conduct e.g. sexual misconduct; or

4. Any other illegal activities.

 

Feedback on doctrinal or theological concerns, the quality of the Church’s programmes or services, or private grievances are not reportable matters under this Policy and may be directed to the Church Council, pastors, or ministry staff as appropriate.

 

Procedure for Reporting

 

Staff should first discuss any concerns with their immediate supervisor. If this does not resolve the concern, or if the staff is uncomfortable in speaking with his/her supervisor, he/she may submit a report using the procedure detailed in this Policy. Similarly, church members or attendees should first raise any concerns with their respective ministry staff or leaders. If this does not resolve the concern, or if the church member or attendee is uncomfortable in speaking with his/her ministry staff or leaders, he/she may submit a report using the procedure detailed in this Policy.

 

Concerns should be raised in writing to the Senior Pastor, the Council Chairman, or anyone who may be so appointed as part of the Whistle-blowing Committee.

 

Whistle-blowers should provide specific information in the report. This includes details such as the identities of parties involved, the nature and description of the alleged wrongdoing, the relevant dates or period of time, and any evidence that may substantiate the concern raised e.g. emails, text messages, photos, documents.

 

Whistle-blowers are encouraged to identify themselves in the report and provide contact details, in case further information or clarification is required. Anonymous concerns will be investigated on their merits, but may be difficult to act upon effectively if the information provided is vague or insufficient.

 

Confidentiality and Protection

 

The Church will endeavour not to reveal the identity of the whistle-blower unless the whistle-blower consents to disclosure. However, the Church may not be able to maintain confidence in exceptional circumstances, including but not limited to the following:

1. Where the Church is under a legal obligation to disclose part or all of the information provided;

2. Where the information is already in the public domain;

3. Where the information is given on a confidential basis to the Church’s legal advisers/auditors for the purpose of obtaining professional advice; or 

4. Where the information is given to the Police or other authorities for formal investigation.

 

The Church will not tolerate harassment or victimisation of whistle-blowers. No person who reports a genuine concern under this Policy in good faith shall be subject to retaliation or adverse employment consequences (in the case of a staff).

 

However, the Church will not condone frivolous, reckless, or malicious allegations. Where it is clear the report was made in bad faith, such individuals will be subject to appropriate action as determined by the Committee.
 

Written by Goh Yi Ling

29 October 2021

Discussed and accepted by Council in Feb 2022