Whistleblowing Policy
Intent
JCU (Singapore Campus) is committed to providing a dynamic, inclusive, and productive work environment for its employees. To uphold these values, this Whistleblowing Policy establishes a framework for the disclosure of concerns relating to suspected wrongdoing, deliberate concealment, unethical, illegal, or improper conduct within the University.
The objective of this policy is to encourage employees, students, and other stakeholders to report legitimate concerns without fear of reprisal, by establishing the process for complaint management, investigation, and protection to the whistleblower thereby ensuring a transparent and accountable environment.
Whistleblowing refers to the act of reporting concerns related to misconduct, including but not limited to:
- Violations of laws or regulations
- Academic dishonesty or fraud
- Financial mismanagement or fraud
- Bribery and kickbacks
- Theft and fraud
- Discrimination, harassment, or bullying
- Health and safety risks
- Environmental hazards
- Retaliation against whistleblowers
This policy does not apply to staff grievances or complaints relating to job performance and/or terms and conditions of employment.
Scope
This policy applies to all members of the University community, including:
- Employees (Academic and Professional)
- Students
- Former Employee/s
- Contractors
- Other stakeholders engaging with the University
Definitions
Employees – employees are provided with a Contract of Service which defines the employer/employee relationship. The duration of the employment contract may vary as indicated below:-
- Fixed term contract – 1 year and above
- Short Term Contract – less than 1 year
- Ongoing – no fixed time frame indicated.
Students – Full and part-time students that are enrolled in any course of the University.
Former Employee/s – any individual previously employed by the University but has since ceased to be an employee.
Contractors – Third party consultants and vendors
Other stakeholders engaging with the University - such as parents, guardians, regulatory bodies
JCU (Singapore Campus) / University – James Cook University Pte Ltd
DVC – Deputy Vice-Chancellor, Singapore.
Policy
- Roles and Responsibilities
Whistleblowers: Provide accurate and detailed information in good faith.
Designated Officers: Ensure reports are handled confidentially and investigated thoroughly.
University Leadership: Promote a culture of integrity and accountability.
- Reporting Guidelines
Reports should include as much information as possible to facilitate thorough investigations, e.g., dates, time, individual(s) involved, evidence such as documents, photographs and audio/video recording/s.
Anonymous reporting is permitted, but whistleblowers are encouraged to provide their contact information for follow-up. An anonymous whistleblower should be aware that the University’s ability to follow up on the report may be limited where there is inability to contact the informant for the necessary details to commence investigation, where required.
Reports made in good faith will be taken seriously, even if the claims are later found to be unsubstantiated.
- Reporting Channels
To file a report, please use the secure online reporting system available at:
https://jcus.confideplatform.com/c/whistleblower
This link provides access to a confidential platform where you can submit your concerns at any time. The system is monitored by the University’s designated compliance team, and all reports will be reviewed and investigated in accordance with this policy.
- Handling of Reports
Acknowledgement: Reports will be acknowledged within 3 business days from date of receipt.
Assessment: Reports will be assessed to determine the appropriate course of action.
Investigation: Investigations will be conducted by a committee of inquiry, with the findings and recommendations to be submitted to the Chairman of the committee within two (2) weeks or such reasonable number of days as required under the circumstance.
Resolution: Outcomes may be subject to privacy constraints and will be communicated to the whistleblower only where appropriate and feasible. Due to legal or privacy constraints, we may not be able to share all the details of the investigation outcome, or any disciplinary action taken. This is to protect all parties involved.
Documentation: All reports, findings, investigations, and the corresponding actions taken shall be thoroughly documented, and incorporated into the final reports for submission to the JCUS Audit, Risk and Compliance Committee who in turn will report to the JCUS Board of Directors
- Protection of Whistleblowers
Confidentiality: The University will exert best efforts to protect the identity of the whistleblower, and to ensure that the report/complaint made remains confidential to preserve its integrity.
Right to external disclosures: While members of the University community are encouraged to report suspected misconduct or wrongdoing through the University’s internal whistleblowing channel, the University acknowledges and respects the individual’s right to make reports directly to external authorities in accordance with the applicable laws of Singapore. Nothing in this policy is intended to restrict or discourage individuals from exercising their legal rights to report such matters externally, especially where the internal channel may be inappropriate or where there is a legal obligation to do so.
Assurance on Disclosures Involving Senior Personnel: The University acknowledges that disclosures concerning a direct supervisor or senior member of staff may give rise to concerns about impartiality or reprisal. Employees are assured that all such reports made in good faith will be handled with the same diligence, confidentiality, and protections as any other report under this Policy. Individuals making disclosures shall not be subjected to any form of retaliation, disadvantage, or adverse consequence arising from such a disclosure. Any retaliatory conduct will constitute a serious breach of this Policy and may result in disciplinary action.
Protection from Retaliation: The University shall not tolerate any form of retaliation against whistleblowers, who, in good faith report concerns internally or externally. This includes dismissal, demotion, threats, or other unfair treatment. Anyone who believes they have experienced retaliation should report it promptly to the Chief People Officer. Those found to have retaliated may face disciplinary or legal action.
- Malicious Reporting
Deliberately false or malicious allegations are prohibited and may result in disciplinary action. This does not apply to reports made in good faith that are later found to be unsubstantiated. - Monitoring and Review
This policy will be reviewed periodically to ensure its effectiveness and alignment with legal and ethical standards. Suggestions for improvement are welcome and can be directed to the Chief People Officer.
FAQs
The Policy provides a secure, confidential, and legally compliant mechanism for individuals to effectively report concerns relating to misconduct within or connected to the organisation. These may include but are not limited to:
- Violations of laws or regulations
- Academic dishonesty or fraud
- Financial mismanagement or fraud
- Bribery and kickbacks
- Theft and fraud
- Discrimination, harassment, or bullying
- Health and safety risks
- Environmental hazards
- Retaliation against whistleblowers
No, they are not the same. Whistleblowing refers specifically to reporting serious concerns such as misconduct, unethical behaviour, legal violations, or breaches of company policies that may affect the organisation or the public interest.
- Feedback typically involves suggestions or observations to improve services, processes, or performance.
- Complaints and grievances usually relate to personal concerns, such as workplace issues, interpersonal conflicts, or dissatisfaction with internal decisions.
We provide separate channels for each type of communication to ensure your concerns are directed to the appropriate team.
Any individual whether internal or external to the organisation, may submit a report.
Reports can be submitted securely and confidentially at any time via our online whistleblower portal, operated through the Confide Platform. The portal is accessible 24/7 and is designed to protect your identity and the integrity of the information submitted.
Yes, you may submit a report anonymously and are not required to identify yourself. If you choose to remain anonymous, please retain the access credentials provided upon submission so that you can monitor updates or respond to follow-up questions.
Yes. All reports and identities of whistleblowers shall be treated with strict confidentiality. Disclosure of your identity will only occur where:
- Required by law or regulatory obligation;
- Necessary to prevent a serious threat to life, health, or safety; or
- Essential to the integrity or fairness of the investigation.
Where disclosure is necessary, we will take all reasonable steps to notify and protect the whistleblower.
Your data is stored and processed in accordance with applicable data protection and privacy laws. The Confide Platform uses end-to-end encryption and strict access controls.
All reports shall be appropriately reviewed and investigations shall be conducted promptly, impartially, and in a manner that preserves confidentiality and fairness for all parties involved.
Where legally and operationally appropriate, the whistleblower may be provided with updates on the progress or conclusion of the matter. However, details may be limited to preserve legal privilege, privacy rights, or the integrity of the process.
Timelines may vary depending on the complexity and nature of the matter. Investigations will be conducted by a Committee of Inquiry, with the findings and recommendations to be submitted to the Chair of the Committee of Inquiry within two (2) weeks or such reasonable period as required under the circumstance.
Yes. Any form of retaliation against any individual who makes a report in good faith, cooperates in an investigation, or is perceived to have done so, is strictly prohibited.
If you believe you are experiencing or have witnessed retaliation, report it immediately to Chief People Officer. Retaliation will be immediately investigated and addressed with appropriate disciplinary or legal action.
A report made in good faith is one based on reasonable belief that misconduct has occurred or is likely to occur. Whistleblowers are not expected to have evidence, but the concern must be genuine, and not malicious or knowingly false.
Knowingly submitting false or misleading information is a breach of the Policy and may result in disciplinary or legal consequences. The program is intended to encourage integrity and protect legitimate concerns.
The Policy applies equally to all levels within the organisation, including executive leadership and the Board. Reports concerning senior personnel will be escalated to appropriate independent channels or external authorities if necessary.
Yes. If you have more information after submitting your initial report, you can add to it via the secure Confide Platform or follow up with the relevant contact point.
Legal Disclaimer
This FAQ is intended to provide general information only and does not constitute legal advice. The organisation reserves the right to amend, update, or revise this program in response to changes in legislation or internal policy. In the event of a conflict between this document and applicable laws or regulations, the latter shall prevail.