Summary of Whistleblowing Policy

INTRODUCTION 

• Whistle-blowing Policy (“Policy”) aims to provide an avenue for employees and relevant stakeholders of Startups Venture (“SV”) to raise concerns and offer reassurance that they will be protected from reprisals or victimisation when such concerns are provided in good faith.
  
  

REPORTABLE INCIDENTS 

• Concerns raised under this Policy should be done in good faith and the alleged misconduct or malpractice should have a large potential adverse impact on SV and/or public interest. 
• The examples below are intended to give an indication of the kind of conduct which might be considered as irregularities. These include but not limited to: 
• • Concerns about SV’s accounting, internal controls or auditing matters 
  • Breach of or failure to implement or comply with SV’s policies - Impropriety, corruption, acts of fraud, theft and/misuse of SV’s properties, assets or resources 
  • Conduct which is an offence or breach of law 
  • Abuse of power or authority 
  • Serious conflict of interest without disclosure 
  • Intentional provision of incorrect information to public bodies 
  • Any other serious improper matters which may cause financial or non-financial loss to SV, or damage to SV’s reputation 
  • Acts to mislead, deceive, manipulate, 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 SV 
  • Concealing information about any malpractice or misconduct 
  • Threats to health or safety of employees, members of congregation, vendors and/or the public 
    
    
• General complaints and grievances over service quality, organisation deficiency, operational matters, unhappiness over private conduct of fellow members etc. are not concerns for whistle-blowing. These concerns should be taken up with the members of the management team and/or with the leadership team. 
  
  

PROTECTION AGAINST REPRISALS 

• A person, who raised a concern in good faith, will be protected from any form of reprisal, discrimination or harassment, even if the concern is later proven to be unsubstantiated. 
• However, SV does not condone frivolous, mischievous or malicious allegations.
  
  

CONFIDENTIALITY

• All concerns raised and identity of whistle-blowers will be treated with strict confidentiality.
  
  

WHISTLE-BLOWING PROCESS

• Concerns should be raised in writing using “Whistle-Blower Report Form”. The information reported should be as specific as possible, such as details of the parties involved, dates or period of time, description of the incident and evidence substantiating the concern raised, where possible. 
• Whistle-blowers are expected to provide their names and contact numbers to facilitate investigation. SV will consider concerns lodged anonymously if the concerns are substantiated with documentary evidence.
• Process in summary: