Section I: Purpose

PBSP is committed to the highest standards of integrity, transparency, and accountability. It seeks to ensure that its systems and processes promote these standards and that its employees adhere to the same. Allegations of fraud and dishonesty are serious matters and will be dealt with accordingly.

The Whistle Blower Policy is created to provide a formal mechanism for reporting possible misconduct of irregularities so that appropriate action may be taken.

The policy provides an avenue for employees, suppliers, donors, partners, contractors, beneficiaries and other third parties to raise concerns about possible wrongdoing, unethical behavior and misconduct. A person who reports a concern (the “Whistle Blower”) shall be protected from any form of retaliation or reprisal.

Section II: Scope

This policy applies to the Board of Trustees, Management and Staff of PBSP. It will also cover third party entities who may be involved directly or indirectly in an illegal or unethical transaction. PBSP will ensure an objective and impartial investigation, regardless of the subject’s position, title, length of service or relationship with PBSP. This includes any party who may be involved or becomes involved during the course of the process.

Section III: Definition of Terms

Corruption – is a form of dishonesty or criminal activity undertaken by a person or organization to acquire illicit benefit

Criminal Act – a crime or an action committed by a person that violates a law which is punishable by authorities

Fraud – any wrongful or criminal deception intended to result in financial or personal gain

Illegal – is a description for something that is in violation of statute, regulation or ordinance

Retaliation – is any intentional or reckless act of discrimination, reprisal, harm, harassment or retribution, direct or indirect, which is recommended, threatened, or taken against anyone who either refuses in good faith to participate in the facilitation or commission of any prohibited practice, or who in good faith reports suspicion or knowledge of prohibited practices to the appropriate channels

Unethical behavior – an action that falls outside of what is considered morally right or proper for a person, profession or an industry

Whistle blower – is a person who reports a first-hand knowledge and/or verifiable information on acts that are deemed illegal, unethical, or fraudulent

Section IV: Statement of Policies and Guidelines
1. Coverage. Concerns about misconduct under, but not limited to, the following circumstances may be reported:

a. Violation of PBSP’s Codes of Conduct and Ethics;
b. Unethical or illegal conduct;
c. Fraudulent reporting or accounting practice;
d. Conduct that poses a serious risk to public safety, health, or the environment;
e. Misuse or misappropriation of the organization’s assets;
f. Conflict of interest situation;
g. Any action damaging the organization’s reputation;
h. Any criminal act punishable by law; and
i. Other conduct similar or related to the foregoing.

2. Confidentiality. The confidentiality of the whistle blower shall be maintained except when laws require identification for investigation and due process. The Internal Auditor (IA) and/or the Executive Director (ED) will treat the information as strictly confidential. Details and results of the initial screening and investigation shall be kept confidential and shall only be discussed with the management and those from the Legal Services, Human Resource, and law enforcement when the need arises. This is important in order to avoid the risk of damaging the suspected persons’ reputation (but subsequently found innocent of the alleged fraud) and to protect the institution from potential liability.

3. Anti-Harassment. PBSP recognizes that the decision to report a suspicion can be a difficult one to make because of the fear of reprisal from those responsible for the malpractice. Thus, the organization will not tolerate harassment or victimization and will take the necessary steps to protect those who raise an issue in good faith.

4. Anonymous Allegations. Anonymous allegations are discouraged. Issues expressed anonymously will be considered at the discretion of the IA and/or ED. In exercising this discretion, the following factors will be considered:

• Seriousness of the issues raised
• The credibility of the allegation and the supporting facts
• The likelihood of confirming the allegation from attributable sources

5. False Allegations. If an allegation is made in good faith, but found untrue, no action will be taken against the complainant. If, however, individuals make malicious or vexatious allegations, disciplinary action will be considered against an individual making the allegation.

6. Reporting. Reports can be made directly to report@pbsp.org.ph as it is the primary reporting channel for whistle blowers. Access to this reporting channel is restricted to the organization’s IA and ED ONLY.

7. Alternative Reporting Channels. Whistle blowers may also submit reports through the following channels. Likewise, access to these reporting channels is restricted to the intended receiver of the reports:

Internal Auditor
Mobile Phone: 0919 0648 709
Email: IntAudit@pbsp.org.ph
Mail: The Internal Auditor
        PBSP Building, Magallanes corner Real Streets, Intramuros, Manila

Executive Director
Email: ExecDir@pbsp.org.ph
Mail: The Executive Director
        PBSP Building, Magallanes corner Real Streets, Intramuros, Manila

8. Details to be Reported. Details to be included in reporting are the following:

a. The type of alleged wrongdoing;
b. Where and when the events occurred;
c. Who are involved;
d. How the alleged wrongdoing was committed.

9. Procedures for Reports Received. All reports must be acknowledged within 48 hours from receipt of the complaint.

• Initial screening handled by the IA and/or ED shall be made to determine the appropriate action and whether it should require a formal investigation.
• The subsequent process of formal investigation shall be handled by the appropriate unit or authority.
• For investigations involving PBSP personnel, proceedings shall adhere to the organization’s Code of Discipline.
• It is important to reiterate that the IA and/or ED will not disclose the identity of the person making a report of the irregularities unless that person has consented to such disclosure. All reasonable steps must be taken to ensure that pertinent issues are sufficiently examined.
• Internal Audit and the Executive Office shall regularly update the Audit Committee on the receipt of such complaints, actions taken and results.

Section V: Effectivity
This policy shall take effect on March 1, 2020.