Singapore, 27 February 2025 – An inaugural study on whistleblowing policies of Singapore-listed issuers by the Centre for Investor Protection at NUS Business School revealed many gaps in the whistleblowing policies, raising concerns about their overall effectiveness in ensuring good corporate governance.
The study analysed whistleblowing disclosures in the latest annual and sustainability reports for FY2023 and FY2024 as well as on corporate websites from 536 Singapore Exchange (SGX) primary-listed issuers. Each policy was evaluated against SGX listing requirements and good practices using a custom-developed 20-item Whistleblowing Scorecard. The findings indicated an average score of 20.6 out of 40, with only 54.7% of issuers achieving a score of 20 or above and less than 10% reaching 30 or higher. This reinforces the gaps in the whistleblowing policies of most issuers.
Gaps remain in issuers’ compliance with SGX rules
While all issuers have a whistleblowing policy in place, significant gaps remain in their compliance with specific SGX requirements, such as an independent function to investigate complaints and how protection of confidentiality of the whistleblower is ensured. 23.7% of issuers did not disclose having a designated “independent function” to investigate whistleblowing reports, 13.1% failed to identify the function or individual and 6% disclosed having a designated team but did not identify what the team was, such as the function or positions of those in the team.
On the matter of confidentiality, although 85.1% of issuers committed to maintaining confidentiality, they failed to specify the procedures in place, and 6.2% did not disclose any information about keeping the whistleblower’s identity confidential. The report further highlights issues related to the protection of whistleblowers against reprisals. Most issuers fell short of detailing the support mechanisms available during the investigation period, with only 0.7% providing specific measures. Additionally, only 19.8% of issuers disclosed actions to assist whistleblowers who may experience detriment or harassment.
Regarding oversight, 19.8% of issuers did not go beyond a generic reference to Provision 10.1 of the Code of Corporate Governance on the duty of the Audit Committee to review the policy and arrangements for whistleblowing. Although 69.0% stated that their Audit Committee oversaw whistleblowing matters, they did not disclose how this oversight was conducted.
The study also uncovered shortcomings in other aspects of the whistleblowing practices.
Less than half of issuers (46.3%) have published their whistleblowing policy on their website, and only 35.4% extend their policies to cover environmental, social, and governance (ESG) issues—including breaches related to health, safety, and human rights violations. Although all policies permit employees to report misconduct, only 9.7% allow members of the public to do so. Misconduct may not only be discovered by employees. Moreover, while 64.7% of issuers express a commitment to communicating their whistleblowing policy, only 8.2% provide specific details on how this is achieved.
Transparency is further compromised, with 80% of issuers failing to disclose whether they acknowledge complaints, which may lead whistleblowers to feel they are ignored. In terms of complaint management, less than half of issuers (42%) confirmed that all complaints are reviewed—primarily by Audit Committees, while just 28% said they investigate all complaints and another 31% said they investigate some complaints. Training on the policy is provided by a mere 15.5% of issuers.
Last but not least, 29.3% did not disclose number of complaints and 66.2% said they did not receive a single complaint. The lack of complaints may indicate a lack of trust in the policy and not an absence of misconduct.
These findings raise serious concerns about the effectiveness, transparency, and overall governance of whistleblowing mechanisms among SGX-listed issuers.
Professor Mak Yuen Teen, Director of the Centre for Investor Protection (CIP), said, “Many corporate scandals could have been prevented if organisations have in place robust and rigorous whistleblowing policies that foster trust amongst employees and other stakeholders. Our study shows that a significant number of policies are poorly designed and are unlikely to build necessary confidence for effective whistleblowing. However, effective implementation goes beyond merely fulfiling the required formalities. It necessitates the cultivation of a healthy corporate culture and effective board oversight and monitoring.”
Associate Professor Susan See Tho, Department of Accounting, NUS Business School and Member of the CIP, said “Whistleblowers are individuals who demonstrate genuine concerns for their organisations’ long-term well-being by courageously bringing questionable practices to light. Even before they step forward as whistleblowers, they carefully assess the effectiveness of the whistleblowing policy and whether the leadership will ‘walk its talk’ by addressing the issues with utmost confidentiality and while assuring personal protection. Any ineffectiveness in the policy or the leadership, even if they are perceived, would lead individuals away from the act of whistleblowing and this could mean missed opportunities for preventing corporate disasters.”
The full report is available for download from the following link: https://bschool.nus.edu.sg/cip/wp-content/uploads/sites/144/2025/02/Will-You-Listen.pdf
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About National University of Singapore (NUS)
The National University of Singapore (NUS) is Singapore’s flagship university, which offers a global approach to education, research and entrepreneurship, with a focus on Asian perspectives and expertise. We have 16 colleges, faculties and schools across three campuses in Singapore, with more than 40,000 students from 100 countries enriching our vibrant and diverse campus community. We have also established more than 20 NUS Overseas Colleges entrepreneurial hubs around the world.
Our multidisciplinary and real-world approach to education, research and entrepreneurship enables us to work closely with industry, governments and academia to address crucial and complex issues relevant to Asia and the world. Researchers in our faculties, research centres of excellence, corporate labs and more than 30 university-level research institutes focus on themes that include energy; environmental and urban sustainability; treatment and prevention of diseases; active ageing; advanced materials; risk management and resilience of financial systems; Asian studies; and Smart Nation capabilities such as artificial intelligence, data science, operations research and cybersecurity.
For more information on NUS, please visit nus.edu.sg.
About NUS Business School
The National University of Singapore (NUS) Business School is known for providing management thought leadership from an Asian perspective, enabling its students and corporate partners to leverage global knowledge and Asian insights.
The school has consistently ranked first in Asia by independent publications and agencies, such as The Financial Times, and Quacquarelli Symonds, in recognition of the quality of its programmes, faculty research and graduates.
The school is accredited by AACSB International (Association to Advance Collegiate Schools of Business) and EQUIS (European Quality Improvement System), endorsements that the school has met the highest standards for business education.
About the Centre for Investor Protection
Established in 2024 at the NUS Business School, the Centre for Investor Protection (CIP) is the first of its kind in Singapore dedicated to research on investor protection. A truly independent entity that advocates for the interests of investors through independent research focused on improving investor protection policies and practices, it aims to help strengthen and ensure the long-term sustainability of the Singapore capital market and beyond.
For media enquiries, please contact:
Professor Mak Yuen Teen
Department of Accounting
NUS Business School
Email: bizmakyt@nus.edu.sg