Effective date: January 2024

  1. POLICY PURPOSE
    1. SPH Media Limited and its related corporations (as defined under the Companies Act, Cap 50) (“SPH” or the “Group”) does not tolerate any malpractice, impropriety, illegal or unethical behaviour by staff in the course of their work. This policy is intended to provide a framework to promote responsible and secure whistle blowing without fear of adverse consequences.
    2. This policy aims to create a work environment where Employees, vendors, service providers, customers and other stakeholders are able to raise concerns on misconduct, irregularities or malpractices, without fear of harassment and/or victimisation and with an assurance that all reasonable efforts will be made to ascertain the relevant facts behind their reported incidents for appropriate actions to be taken.
    3. This policy’s objectives include:
      1. Encourage timely reporting of suspected illegal or unethical behaviour within or by SPH;
      2. Provide a confidential channel for escalation of concerns without fear of reprisal;
      3. Ensure consistent and timely response to reported concerns;
      4. Ensure appropriate oversight by the Board of Directors;
      5. Serve as a means of preventing and deterring misconduct that may be contemplated;
      6. Protect the rights of SPH; and
      7. Promote a culture of openness, accountability and integrity.
  2. APPLICATION
    1. This Policy applies to:
      1. the Group;
      2. All Employees in the Group; and
      3. Third Party Representatives; and
      4. External Parties (where relevant).
    2. The Policy allows for reporting by Employees or External Parties of such matters to the Internal Audit Division of SPH, without fear of reprisal, discrimination or adverse consequences, and also permits SPH to address such reports by taking appropriate corrective action, including, but not limited to, disciplinary action up to termination of the employment and/or services of those responsible.
    3. Reportable incidents, whether suspected or confirmed, for whistle blowing include:
      1. All forms of financial or non-financial malpractices or impropriety such as fraud, embezzlement, misappropriation, corruption, falsification of financial statements or theft.
      2. Harassment and abuse and misrepresentation of power and authority;
      3. Violation of intellectual property rights, or laws and regulations;
      4. Actions detrimental to health and safety or the environment;
      5. All forms of discrimination on the basis of gender, race, religion or disabilities;
      6. Conflict of interest;
      7. Breach of SPH’s policies or Code of Ethics;
      8. Concealing, manipulation or destruction of information or documentation about any of the above malpractice or misconduct; and
      9. Retaliation against anyone who reported a reportable incident in good faith.
  3. DEFINITION
    1. “Employees” refer to all employees in the Group, including but not limited to officers, Directors, part-time workers, trainees, seconded staff, interns or any other persons employed with the Group.
    2. “External Parties” refer to persons or entities with which SPH conducts or may conduct dealings in the course of its business, including but not limited to service providers, business partners, and their respective officers, employees and agents.
    3. “Receiving Officer” refers to the Head of SPH’s Internal Audit Division who is responsible for the investigation, handling and escalation of reportable concerns.
    4. “Third Party Representative” refers to any party acting on behalf of SPH. Third Party Representatives includes but is not limited to the following: agents, consultants, teaming partners, independent contractors, and joint-venture partners, but shall not include brokers.
    5. “Whistle Blowing” refers to a voluntary disclosure of individual or organisational malpractice by a person who has privileged access to data, events or information about an actual, suspected or anticipated wrongdoing or malpractice within or by SPH that is within its ability to control. There are two categories of whistle blowers namely:
      1. “Internal Whistle Blowers” refers to Employees who are expected to report incidents of misconduct involving peer, supervisor/superior or top management staff to the Receiving Officer.
      2. “External Whistle Blowers” refers to contractors, customers, suppliers, and other members of the public who report wrongdoings of Employees to the Receiving Officer.
  4. GUIDANCE
    Reporting Mechanism
    1. SPH encourages Employees and External Parties to put their names to their allegations whenever possible. Concerns or irregularities expressed anonymously are more difficult to act upon effectively, but they will be considered, taking into account the following:
      1. Severity of issues raised;
      2. Significance and credibility of concerns;
      3. Likelihood of confirming the allegation from attributable sources and information provided.
    2. All valid concerns or irregularities raised will be acknowledged and treated with confidence throughout the process.
    3. Concerns may be raised verbally or in writing. As it is essential for SPH to have all critical information in order to be able to effectively evaluate and investigate a complaint, the report made should provide as much detail and be as specific as possible. Submissions can be made to the Receiving Officer via mail and/or email as follows:

      Address: Internal Audit Division, 1000 Toa Payoh North, SPH News Centre, Tower Block, Level 11, Singapore 318994
      Email: whistleblow@sph.com.sg
    1. Significant complaints received via the SPH Whistle Blowing channels are to be forwarded to the Chairman of the SPH Audit and Risk Committee (“ARC”) for decision and guidance on the next course of action(s).

      Safeguards
    2. SPH prohibits discrimination, retaliation or harassment of any kind against a whistle blower who submits a complaint or report in good faith. If a whistle blower believes that he or she is being subjected to discrimination, retaliation or harassment for having made a report under this Policy, he or she should immediately report those facts to the Receiving Officer. Reporting should be done promptly to facilitate investigation and the taking of appropriate action.
    3. At the appropriate time, the party making the report/complaint may need to come forward as a witness. If a whistleblower makes an allegation in good faith but it is not substantiated by the investigation, no action will be taken against him or her. If, however, an allegation was made frivolously, maliciously or for personal gain, appropriate action may be taken accordingly.

      Complaints Handling
    4. All information submitted through the whistleblower reporting mechanism or disclosed during the course of investigation will remain confidential, except as necessary or appropriate to conduct the investigation and to take any remedial action, in accordance with any applicable laws and regulations.
    5. SPH reserves the right to refer any concerns or complaints to appropriate external regulatory or enforcement authorities. Depending on the nature of the complaint, the subject of the complaint may be informed of the allegations against him or her and be provided with an opportunity to reply to such allegations. Employees who fail to cooperate in an investigation, or deliberately provide false information during an investigation, shall be subject to strict disciplinary action up to, and including, immediate dismissal.
    6. If, at the conclusion of an investigation, SPH determines that a violation has occurred or the allegations are substantiated, appropriate disciplinary action in accordance with the Fair Employment Policy will be taken.

      Handling External Media
    7. Where any alleged misconduct arising from the whistleblowing channels is to be disclosed by SPH to external media, SPH will ensure that there is fairness and objectivity in its corporate statements with no misrepresentation and unprofessional pursuit of publicity.
    8. Where information is confidential, SPH shall not, except in the course of duty or under compulsion by law, disclose, divulge or make public any information of a confidential nature relating to the details of the alleged misconduct.
    9. During the course of investigation, the whistle blower or any party privy to the confidential information shall not inform external media or any colleagues to avoid prejudicing the investigation.
  5. ADMINISTRATION – COMMUNICATIONS, TRAINING AND POLICY REVIEW

    Communications and Training
    1. This policy shall be communicated to all relevant stakeholders at the outset and as appropriate thereafter; and all Employees shall be trained on the principles of this policy.

      Policy Review
    2. This policy shall be reviewed regularly for any revisions that may be necessary to maintain compliance with applicable laws and regulations or accommodate organisational changes.