Recent fraud scandals have underscored the increasing importance of strong corporate governance. As the Southeast Asian startup and scaleup ecosystem matures, investors and boards are increasing their focus on corporate governance enhancements.

Specifically, companies are strengthening their whistleblowing frameworks, policies and programs given that:

1. Some of the region’s (i.e. E-fishery, Zilingo) and world’s (i.e. Enron, 1MDB) largest financial misstatement frauds arose from whistleblowing; and
2. Studies done by PWC and the Association of Certified Fraud Examiners have revealed that whistleblowing is the most common and often the most important method of fraud detection.

Ultimately, good governance safeguards company integrity, exposes wrongdoing, and fosters trust with stakeholders.

With this in mind, Steward Redqueen and Integra Partners have partnered again to develop a new Whistleblowing Policy template, to add to the suite of policy templates developed in 2024. By adopting such policies, companies can foster a culture of accountability and transparency, ultimately contributing to a more confident and secure start-up ecosystem.

The Whistleblowing Policy template is structured to allow companies to clearly articulate the relevant whistleblowing scope, management processes and procedures, roles and responsibilities, and monitoring, evaluation and learning activities. The template also provides guidance on how companies should approach whistleblower protection through clear commitments to protecting confidential information. Similar to the existing suite of policy templates, we included adaptable language that companies can adjust based on company maturity. For example, more mature companies should engage an independent external third party to receive reports to facilitate impartiality, while young companies should exercise discretion when relying on their Board members to receive reports.

The Whistleblowing Policy template can be found in Singapore Venture and Private Capital Association’s Maturation Map here and on Integra’s website here.