1.  Is there a law on whistleblowing in your country?
  2. Does local law require private entities to establish a whistleblowing system? (If so, which private entities?)
  3. What legal risks does an entity face for not establishing a reporting channel?
  4. Are there any mandatory requirements for establishing a reporting channel under local labour law?
  5. Does local law require employee involvement when establishing a whistleblowing system?
  6. Does local law prohibit employees from disclosing irregularities/misconduct externally, e.g. to the public?
  7. Is there legal whistleblower protection aimed at preventing discrimination against or dismissal of a whistleblower (as employee) under local labour law?
  8. Are there any mandatory requirements and/or accompanying measures under local data protection law?
  9. Does local law prohibit a group of entities from different jurisdictions from setting up a joint whistleblowing system?

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Singapore
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1. Is there a law on whistleblowing in your country?

There is no overarching legislation on whistleblowing in Singapore.

Under Singapore law, however, there are certain situations where there is an obligation to give information about the commission or the intention of a person to commit a criminal offence. Members of the public are also obliged to provide any information relating to corrupt acts they are in possession of if the Director of the Corrupt Practices Investigation Bureau requires them to do so.

While there is no overarching legislation, specific statutes like the Prevention of Corruption Act 1960 and Misuse of Drugs Act 1973 contain safeguards for the protection of informers. If information relating to the offences falling under these statutes is provided, 

  1. The informer’s name, address, or any matter which might lead to discovering his/her identity will not be disclosed to any witness. 
  2. If any evidence, such as books, documents or papers are to be inspected during proceedings, the court will ensure that the informer’s details, which may be found on the evidence(s), will be concealed or destroyed such that his/her identity will be protected.

This protection is not absolute. If it is found that the informer had knowingly made a false statement, the informer’s identity may be disclosed. 

2. Does local law require private entities to establish a whistleblowing system? (If so, which private entities?)

No, Singapore law does not require private entities to establish a whistleblowing system (although most if not all government agencies and many private corporations do).

The Code of Corporate Governance, which applies only to listed companies and does not have the force of law, requires listed companies to publicly disclose and communicate to their employees the existence of a whistleblowing policy. 

There are currently no sanctions or legal risks for an entity without a whistleblowing system.

4. Are there any mandatory requirements for establishing a reporting channel under local labour law?

No, there are no mandatory requirements for establishing a whistleblowing system under local labour law.

However, certain government agencies and companies may have their own whistleblowing policies for employees to make reports without fear of reprisal, discrimination or adverse consequences. 

Whistleblowing policies usually provide for the appropriate channel(s) to report wrongful practices or misconduct. Workplace harassment, financial and non-financial malpractice, failure to comply with law and regulations are generally classified as reportable incidents.

5. Does local law require employee involvement when establishing a whistleblowing system?

No.

6. Does local law prohibit employees from disclosing irregularities/misconduct externally, e.g. to the public?

No, although this may be provided for in the whistleblowing policy of the entity (if any). 

No, although this is usually provided for in the whistleblowing policy of the entity (if any). 

8. Are there any mandatory requirements and/or accompanying measures under local data protection law?

Personal data is protected in Singapore by the Personal Data Protection Act 2012 (the “PDPA”). While there are no specific measures in the whistleblowing context, the PDPA generally prohibits the collection, use, and disclosure of personal data without consent. There are certain exceptions (e.g. the disclosure of personal data is permitted if it is necessary for any investigation or proceeding).

9. Does local law prohibit a group of entities from different jurisdictions from setting up a joint whistleblowing system?

No, it does not.