CFA Society Singapore (“CFA Society Singapore” or as appropriate in the context, “the Society”, “we”, “us”, or “our”) is committed to lawful and ethical behaviour in all of its business activities. All employees and representatives of CFA Society Singapore, including CFAS leaders, should practice honesty and integrity in performing their responsibilities and complying with all applicable laws and regulations, as well as this Code of Conduct.

a. Purpose:

The Whistleblowing Policy is intended to encourage and enable members, employees and others to raise serious concerns so that the Society can address and correct inappropriate conduct and actions. The Policy:

• Provides a means for members, employees and other organization leaders to raise good faith concerns regarding suspected violations of law and/or the Society’s policies including this Code of Conduct;
• Facilitates cooperation in any inquiry or investigation by any court, agency, law enforcement or other governmental body; and
• Protects individuals who take such action from retaliation or any threat of retaliation by any other employee or agent of the Society.

b. Scope:

The Whistleblowing Policy applies to all Society leaders, employees, contractors, directors, officers, and volunteers.

c. Statement of Whistleblowing Policy:

No Society leader, officer, director, employee, or agent of the Society shall take any harmful action with the intent to retaliate against any person for (a) providing any truthful information relating to the commission or possible commission of any offense in connection with any official inquiry or investigation or (b) reporting in good faith any violation or suspected violation of law or policy. Efforts will be made to treat a report of unethical or illegal conduct as confidential, consistent with the need to investigate and prevent or correct the action. CFA Society Singapore will explore anonymous allegations to the extent reasonably practicable. Any individual reporting a violation or suspected violation pursuant to this Policy must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation.

• Process for Reporting: Reports of violations or suspected violations of law and/or Society policies including this Code of Conduct or reports of retaliation may be reported directly to the Audit Committee.

In the event that an individual’s concern rises to the level that he/she reasonably believes that notice to the Audit Committee will be disregarded or otherwise not fairly considered, the individual may then report violations or suspected violations to the Board of Directors.

• Process for Handling Reports: Reports of suspected violations of law and/or Society policies including this Code of Conduct and reports of retaliation will be investigated promptly and, in a manner, intended to protect confidentiality. The Audit Committee will manage such investigation and may request the assistance of outside counsel or other outside parties as they deem necessary. The Audit Committee will directly prepare, or ensure suitable preparation of, a report of the findings of the investigation and submit the report to the Board. In the event that the report concerns any Audit Committee member/s, either the affected Audit Committee member should recuse themselves or the Audit Committee should refer the investigation to the Board.
• Seeking of external advice: Should there be a need to seek external advice, including but not limited to regarding ethical decisions and/or reports of suspected violations, approval prior to such engagement would be required from either the Audit Committee and/or the Board of Directors, depending on which is the relevant investigating body. Such approval would need to specify the scope of the advice sought, as well as approved limits on any related payments. Such decisions may not be made by individual Board and/or Audit Committee members.

Appropriate sanctions may be imposed for violations of law and/or Society policies including this Code of Conduct. Sanctions may include cautionary admonition, request for remedial action, request for resignation, removal from office and/or appointment, or such other action as the Board shall deem suitable.

If you have any cases to report, please email [email protected].