Whistleblowing in Singapore: SGX rules, the Code and the Workplace Fairness Act

No. There is no general whistleblower statute, and Singapore law does not require a private company to have a whistleblowing system. Protection comes in pieces. The Prevention of Corruption Act s.36 bars a witness from disclosing an informer's name or address in corruption proceedings. The Workplace Safety and Health Act s.18(2) stops an employer dismissing an employee for reporting a safety matter to an inspector in good faith. The Companies Act s.207(9A) requires a public company's auditor who has reason to believe a serious offence involving fraud or dishonesty has been committed against the company to report it to the Minister. For listed issuers the obligations come from SGX Rule 1207(18A) and (18B) and the Code of Corporate Governance; for financial institutions, from the MAS Guidelines on Individual Accountability and Conduct; and, once in force, the Workplace Fairness Act will protect employees of employers with 25 or more staff from retaliation for raising a grievance about workplace discrimination or harassment.

Mainboard Rule 1207(18A) and (18B), and Catalist Rule 1204(18A) and (18B), apply to annual reports for financial years beginning on or after 1 January 2021, published from 1 January 2022. Under (18A) the annual report carries a statement that the issuer has a whistleblowing policy setting out the procedures for a whistleblower to report misconduct or wrongdoing relating to the issuer and its officers. Under (18B) it explains how the issuer has complied with four things: it has designated an independent function to investigate reports made in good faith, it keeps the identity of the whistleblower confidential, it discloses its commitment to protect the whistleblower against detrimental or unfair treatment, and the Audit Committee is responsible for oversight and monitoring. SGX RegCo said on 24 June 2021 that all issuers must establish and maintain a whistleblowing policy. The NUS Centre for Investor Protection's report of 27 February 2025, covering 536 issuers, found that 29.3 percent did not reveal the number of complaints, nearly two-thirds disclosed zero, and fewer than half disclosed an independent function to investigate them.

No. Rule 1207(18B) requires confidentiality of the whistleblower's identity and does not mention anonymous reports. The expectation of anonymity comes from MAS. Paragraph 5.3(iii)(d) of the Guidelines on Individual Accountability and Conduct, in force since 10 September 2021, says a financial institution should have "a formalised whistleblowing programme, including the whistleblowing channel(s) available to employees, procedures to ensure anonymity and adequate protection of employees who raise concerns". The MAS FAQ adds that the policy should offer employees anonymity and protection from negative consequences, and that the route may be run by an independent unit inside the institution, centralized at head office, or managed by a third party. CPIB's own figures show why it matters: 35 percent of the corruption reports it received in 2025 were anonymous. An issuer that accepts anonymous reports and can still ask follow-up questions meets the SGX rule and the MAS expectation at once.

It gives employees of a covered employer a grievance process for workplace discrimination and harassment, and a legal bar on retaliation. Under section 25 a grievance means a complaint about discrimination by the employer, or harassment by the employer or another employee, so the process is not a general whistleblowing route. The Act was passed on 8 January 2025, the Workplace Fairness (Dispute Resolution) Act on 4 November 2025, and the Ministry of Manpower aims for it to take effect in end-2027. Section 27(1) requires the employer to commit in writing to inquiring into each grievance, informing the employee of the outcome, keeping a written record for a stated period, and not disclosing the employee's identity unless reasonably necessary, and section 27(2) requires every employee to be told the process in writing. Section 28 prohibits any retaliatory act against an employee because they raised a grievance, brought proceedings, gave evidence or information, or alleged a contravention, and section 28(2) names dismissal as one. Section 31 sets administrative penalties per contravention, including each occasion of retaliation and the failure to develop the section 27 process, and section 34 civil penalties for serious contraventions. Under section 4 the Act does not apply to employers with fewer than 25 employees, or another number the Minister prescribes.

It depends on the wrongdoing. Corruption goes to the Corrupt Practices Investigation Bureau, by e-complaint, by email or in writing to its office. CPIB received 160 corruption-related reports in 2025, registered 68 as new cases, and prosecuted 90 individuals, 94 percent of them from the private sector. Misconduct at a listed issuer can go to the SGX RegCo Whistleblowing Office, set up in January 2020 to receive reports in confidence. Regulatory breaches or misconduct at a financial institution go to MAS through its online form, which asks for a name and email. A cartel participant who is first to notify the Competition and Consumer Commission may receive immunity from financial penalties if no investigation has begun and it meets the leniency conditions, including full cooperation and ending its part in the cartel. A safety matter can be reported to a Workplace Safety and Health inspector, and the Workplace Safety and Health Act protects the employee who does so in good faith. None of these routes replaces the internal one the SGX rule and the Code require.

Less than the case suggests. The Commercial Affairs Department raided Wirecard's Singapore entities on 8 February 2019, nine days after the Financial Times published its first report on 30 January. MAS directed Wirecard SG on 30 September 2020 to cease its payment services and return all customer funds by 14 October 2020. In June 2023 James Aga Wardhana and Chai Ai Lim were convicted of criminal breach of trust and related offences and sentenced to 21 and 10 months, and Henry Yeo Chiew Hai to 12 months, while Edo Kurniawan remains at large under an INTERPOL Red Notice. The same month MAS imposed SGD 3.8 million in composition penalties on Citibank, DBS, OCBC and Swiss Life for anti-money laundering breaches linked to Wirecard. R. Shanmugaratnam of Citadelle Corporate Services was convicted on 22 September 2025 on 13 charges of falsifying balance confirmation letters claiming the firm held over EUR 1.1 billion, and sentenced on 6 January 2026 to ten years; James Henry O'Sullivan received six and a half years; both are appealing. In October 2023 Abdul Jabbar of Rajah & Tann told CNA that the current patchwork of legislation was inadequate and that one clear law giving comprehensive protection would help, and Mak Yuen Teen said wrongdoing goes undiscovered because of the lack of whistleblower protection. No whistleblower statute has been passed.