Below is the whistleblowing policy posted online by SingPost. There could be (I hope is) a more comprehensive policy available internally to employees as this policy is quite basic.

Few things to note:

– it encourages but does not require whistleblowers to provide names and contact details (which is good)

– there is no external hotline but instead a SingPost email address and a postal address to the Group IA (which is not the best but external hotline doesn’t mean it’s effective)

– there’s no provision for whistleblowing to the chairman of the AC (or another independent director) (which is not the best)

– perhaps it should also have indicated that they can blow the whistle to SGX Regco whistleblowing office (as some whistleblowers have done)

Looking at the company’s announcement, it’s not clear at what stage were the external legal counsel and advisers engaged. Group IA, which commenced investigations, may not have sufficient expertise, resources and independence. IA has dotted line reporting to Group CEO and there’s also self-review risk as IA is supposed to provide assurance on internal controls and risk management.  Investigation is not a core function of IA and IA may have not have necessary skills and experience to undertake investigations.

SingPost also said the AC ‘had no assurance concerning management’s representations and handling of the internal investigations’. This seems to suggest management was handling the investigations, at least initially.

I think there are questions regarding whether there was too much reliance on the Group IA and management in conducting investigations, at least when the complaints were first received.

We do not know if the whistleblowers implicated the C-suite execs who have been terminated. If so, it’s even more important that they shouldn’t be involved in handling investigations.

Sometimes, boards have too much trust in management. There needs to be a degree of skepticism.

Let me add that the GCEO and GCFO are challenging the terminations. So I’m not passing judgement as to whether the company’s actions are justified.

https://www.singpost.com/sites/default/files/2020-07/Whistleblowing-SingPostwebsite.pdf