Introduction

NAFA (“the Academy”) as an academic arts institution of higher learning is committed to high standards of corporate governance. It takes a serious view on any breach of the Code of Conduct, irregularity, malpractice, impropriety, fraud or other inappropriate activity from all employees in the course of their work. Our Whistle-blowing Policy aims to promote responsible and secure whistle-blowing without fear of adverse consequences.

Reporting Channels

If an employee or external party observes any actual or potential breach of the Code of Conduct, irregularity, impropriety, fraud or other inappropriate activity by a fellow employee or third party relating to the Academy, he/she should report this in writing (either via email or mail), marked “Private and Strictly Confidential” through any of the following channels of reporting:

1. Division Head or Head (HR) with cc to NAFA President “President”
   Via respective email
2. President
   Via Email
   [email protected]
3. The Chairman of Audit & Risk Management Committee
   Via Mail
   Nanyang Academy of Fine Arts
   Bencoolen Street
   Singapore 189655

Anonymous reports may still be considered based on the seriousness and credibility of the issues raised, and the likelihood of confirming the allegation from attributable sources and information provided, although they will be more difficult for Management to act upon effectively. As such, we encourage all parties to put their names to their allegations whenever possible.

What To Report?

The whistle-blower should report any actual or potential breach of the Code of Conduct, irregularity, impropriety, fraud or other inappropriate activity as soon as is practicable. In order for the Academy to effectively evaluate and investigate a complaint, the whistle-blower’s report must provide the following essential information:

• background and history of the complaint;
• details of the parties involved;
• date(s) or period of time;
• the type(s) of concern(s) and the reason(s) for raising the concern;
• evidence substantiating the concern(s) raised, where possible; and contact details.

All allegations must be made in good faith. If the allegations are not subsequently confirmed by an investigation, the whistle-blower will still be protected from possible reprisal, unfair treatment, harassment or adverse consequences, if he/she has acted genuinely and has reason to believe that there are grounds for the allegations. Disciplinary action may be taken against employees who make an allegation frivolously, maliciously or for personal gain.

Reporting By Other Persons (Non-Employee/Officers)

While the Academy may not be in a position to provide the safeguards set out in this policy to persons who are not employees or officers of the Academy and related companies (“Other Persons”), nevertheless, any report received from Other Persons concerning possible improprieties in financial reporting or other matters will be processed with the same diligence and appropriate timely manner as a report received from an employee to ensure that appropriate action is taken to correct the weaknesses in internal controls and policies which have allowed or might allow the perpetration of fraud and/or misconduct and to prevent a recurrence.

Handling Of Complaints

Based on initial inquiries conducted, if it is determined that investigation is necessary, the President or the Chairman of the Audit & Risk Committee, as applicable, will decide on any of the following investigation modes:

• investigate internally
• refer to the external auditor
• refer to appropriate law enforcement agencies, and/or
• investigation by an independent inquiry.

To ensure independence in an internal investigation, the investigation panel with at least 3 members shall be appointed by either President or Chairman of the Audit & Risk Committee, as applicable. The composition of the Panel will consist of members from Senior Management and/or other relevant departments, depending on the nature of the complaint raised. It will not involve any member who is involved or implicated in the whistle-blowing report.

Any disciplinary or corrective action initiated against the reported employee as a result of the findings of an investigation pursuant to the Whistle-Blowing Policy and Procedure shall adhere to the applicable staff conduct and disciplinary procedures, including terminating the employment and/or service of those responsible if deemed suitable.

All investigation reports will be submitted to the Audit & Risk Committee for information, and Chairman of the Committee will in turn report to the Board of Directors. The Secretary of the Audit & Risk Committee will be responsible for maintaining a record of concerns/complaints raised under the Whistle-blowing Policy and the outcomes, but in a form which does not endanger confidentiality and where applicable, will protect the identity of the whistle-blower(s).

The retention period of all whistle-blowing reports, including the investigation reports, will be 3 years from the date of the investigation report.

Reply To The Whistle-blower

The whistle-blower will receive the following follow-up notification on his/her concern within two (2) weeks of the complaint:

1. acknowledging that the concern has been received;
2. indicating how the matter will be dealt with;
3. giving an estimate of the time that it will take for a final response;
4. informing whether initial inquiries have been made;
5. notifying reason(s) should it be decided that no action is to be taken;
6. If it is determined that a whistle-blower has experienced any reprisal which should not have occurred, President or the Audit & Risk Committee, as applicable, shall recommend appropriate remedial actions to be taken.

The Investigating Panel may seek further information from the whistle-blower.

Subject to legal constraints, the whistle-blower will be updated on the outcome of the investigation at the appropriate time.

Confidentiality

Every effort will be made to maintain confidentiality over the report of concerns or irregularities throughout the process of the investigation. However, there may be instances, such as government investigations, arising from the report, which will result in the loss of confidentiality.

Review

An internal review will be conducted annually; and where necessary, additional ad hoc reviews can be conducted to ensure that the Whistle-blowing Policy and Procedures will remain relevant and effective.