Whistleblowing policy


1.1 Portcullis is committed to achieving and maintaining the highest standards of honesty, integrity, ethical and legal conduct. Accountability, transparency, responsibility and fairness lie at the heart of Portcullis’ corporate ethos.


2.1 The Objective of a Whistleblowing Policy (the Policy) is to establish a safe, secure and responsive system that supports and encourages responsible whistleblowing within the Portcullis Group (the Group).

2.2. In particular, the Policy aims to create a culture and working environment whereby employees, service providers, clients, customers and other stakeholders are encouraged and enabled to raise concerns on misconduct, unethical behaviour or malpractice within the Group, without fear of harassment and/or reprisal as well as to enable the taking of appropriate remedial action. 


3.1 The Policy applies to all employees and staff of the Group including but not limited to the following:  officers, directors, managers, supervisors, contractors, part-time workers, trainees, seconded staff, interns or any other person associated with the Group. 

3.2 The Policy also applies to all Clients and Customers of services offered or provided by the Group including individuals who have dealings or contact with the Group as prospective clients or customers.

3.3 The Policy also applies to all other outside parties such as banks, financial institutions and other stakeholders who have dealings with the Group or who are affected by the business activities of the Group.


4.1 Whistleblowing essentially concerns the disclosure of information relating to actual or suspected misconduct, unethical behaviour or malpractice by employees of the Group (whether as individuals or as a group of individuals).

4.2 In some cases, the Whistleblower (the person making the disclosure) may be an employee of the Group (internal whistleblower). In other cases, the disclosure may come from a customer or client of the Group or some outside party such as a bank or financial institution (external whistleblower).

4.3 Examples of misconduct, unethical behaviour or malpractice include (the list is not exhaustive):

  • Fraud, corruption, bribery or theft
  • Money laundering
  • Tax and other financial offences
  • Unauthorised access to and/or disclosure of confidential information
  • Professional misconduct
  • Failure to comply with applicable laws and regulations such as Data Protection Regulations, MAS Regulations
  • Failure to disclose serious conflicts of interest
  • Failure to comply with the Code of Conduct of the Group
  • Unsafe workplace practices
  • Abuse of power including harassment 
  • Discrimination based on gender, race and disabilities

4.4 The Policy does not apply to cases where the complainant has some personal grievance (for example, rudeness) against an employee. In such cases, the complainant should use existing procedures such as communication with the relevant manager or supervisor of the employee. 


5.1 All reports are to be communicated in confidence to the Head or Deputy Head of the Whistleblowing Committee (WBC) at:

  • Address:  6 Temasek Boulevard, #09-05 Suntec Tower Four, Singapore 038986
  • Email:  [email protected]
  • Tel: +65 6496 0496

5.2 The report (complaint) may be oral or written. The report should provide as much relevant information as possible. Where the report is made orally, the complainant should follow up with a written report as soon as is practicable. In all cases, the more detail that is provided the easier it will be to carry out investigations. Whilst anonymous reports will be accepted it is much preferred that the complainant make their identity known since this will make it easier to assess, verify and act on the complaint.


6.1 All information contained in the Report, including the identity of the complainant, will be treated as confidential information. The Group, however, reserves the right to use the information to conduct appropriate investigations and to take remedial action required by applicable laws and regulations (including disciplinary action). This includes communicating the complaint and the results of the investigation to the proper or appropriate external authorities and regulatory bodies including the Singapore Police, Commercial Affairs Department and Monetary Authority of Singapore.

6.2 The Head of WBC together with the Deputy Head and the ordinary member of the WBC shall on receipt of the complaint Report, examine the Report and reach a preliminary decision as to:

  1. whether there appears to be some basis for the complaint, and 
  2. whether bearing in mind the gravity of the alleged misconduct, unethical behaviour or malpractice, a formal investigation should be conducted by the Group.

6.3 Where the WBC decides that a formal investigation should be conducted, the Head of WBC shall appoint an Investigation Committee of 3 persons to examine and investigate the complaint. The complainant will be informed of the composition of the Investigation Committee.

6.4 The Investigation Committee will, so far as is possible, comprise senior staff of the Group (heads of departments, managers or directors). Staff appointed to the Investigation Committee must not be involved and/or connected with the subject matter of the complaint. In appropriate cases, the Head of WBC may appoint suitable persons from outside Portcullis such as an external accountant, computer forensic investigator, etc. to sit on the Investigation Committee or to assist the Investigation Committee in the investigations. The Head of WBC shall not be a member of the Investigation Committee.

6.5 At the conclusion of the investigation, the Investigation Committee will submit its findings and recommendations to the WBC. 

6.6 The WBC will decide on what action (if any) is to be taken including referral to the relevant authorities.

6.7 In cases where the complainant provided his/her identity the results of the preliminary decision and the conclusion reached by the Investigation Committee (if any) and the action taken (if any) will be communicated to the complainant.

6.7 The Group undertakes to carry out all investigations in an expeditious and fair manner. The extent of the investigation will depend on the nature of the complaint, the information provided and the general circumstances of each case.

6.8 In the course of conducting the investigation, the subject of the complaint may be informed of the details of the complaint and provided with an opportunity to respond to the complaint subject to applicable laws and regulations.

6.9 Where the Report concerns or involves the conduct or behaviour of any member of the WBC, the Report and complaint shall be made to the most senior member in rank of the WBC. In such circumstances, the most senior member in rank of the WBC shall appoint an ad hoc member of the WBC to handle the complaint, report and investigation (if any). 


7.1 Information as to the identity of the Whistleblower will, so far as possible, be treated in the strictest confidence. However, during the course of investigation by the WBC and the Investigation Committee, it may be necessary to refer to the identity of the complainant as part of the investigation procedure. Further, in appropriate cases and at the proper stage, it may be necessary for the complainant to come forward as part of the investigations. Failure to do so may, depending on the circumstances, have a substantial impact on the investigation.

7.2 The Group will not in any case permit or condone any discrimination, harassment or abuse against a whistleblower. If a whistleblower under the Policy is of the view that he or she is being discriminated against, harassed or abused as a result of the report, he or she should report the matter to the Chairman or President of the Group, as the case maybe, so that appropriate action can be taken.

7.3 In those cases where after investigation, the complaint is dismissed or not proceeded with, no action will be taken by the Group against the Whistleblower unless the investigation shows that he or she acted frivolously, maliciously or for personal gain.