Whistleblowing Policy

Introduction

1. All Directors and Staff are expected to maintain high standards of business and personal ethics, honesty and integrity in carrying out their duties and responsibilities and to conduct themselves in a professional manner at all times to bring credit to and enhance the image of the company.

2. Whistleblowing is the act of reporting misconduct within an organization and the policy provides a channel for directors, employees and external parties to bring to the attention of the Board any misdeed or impropriety committed by the directors, management and staff of the company.

3. All Staff and Students and any other persons are encouraged to raise genuine concerns about possible misconduct, misdeed or impropriety at the earliest opportunity, and in an appropriate way.

Scope

4. The whistleblowing policy shall surface and address concerns over any action or omission within the company relating to unlawful conduct, financial malpractice and fraud, criminal violation of prevailing laws, rules and regulations, conflicts of interest, non-compliance of company’s internal controls and procedures, unauthorized disclosure of information, abuse of authority for personal gain and discrimination and intimidation of staff in the course of work.

Responsibility

5. The Board Chairman and Deputy Chairman and the School Principal shall be the team authorised to investigate all concerns raised.

6. Where the concern raised is against one of the team members, the other members may appoint additional directors or school management members to assist in the investigation.

Safeguards

7. The policy is designed to enable directors, management and staff to raise concerns and the following safeguards are put in place to facilitate the process:

a. Protection – The school shall protect the whistleblower and ensure that he/she will not be victimized, discriminated, harassed or disciplined. However, the same protection will not be extended to someone who maliciously raises a matter they know to be untrue.

b. Confidentiality – Whistleblowers are encouraged to disclose their identity when reporting concerns and providing information. The identity of the whistleblower and the concerns raised together with all information shall be treated with the strictest confidentiality.

8. The whistleblower may be kept informed of the progress of the investigation and where possible, the final outcome subject to any legal and confidentiality constraint.

Reporting a concern

9. All concerns should be raised in writing via a letter or email to the team members. The information should include background, history of event, reasons for raising the concern, persons involved and evidence to support the concern raised.

10. The concern raised can be addressed to the team members as follows:

11. For reporting by email - The whistleblower can address the email to the following members in accordance with para 10:

12. For reporting by mail – The whistleblower can send the letter to the following address and attention the investigation members in accordance with paragraph 10: