[BCM] [MINDS] [E3] [BIA] [T1] [CBF] [7] Governance, Compliance, and Regulatory Reporting

Sub-CBF Code

Sub-CBF

Description of Process / Activity

Examples (in MINDS context)

7.1

Board Governance & Strategic Oversight

Ensures effective oversight by the Board and senior management through meetings, decision-making, and strategic direction, including crisis governance during disruptions.

Maintain the ability to convene Board or Executive decision-making (physical or virtual) to address statutory, financial, and crisis-related matters within required timeframes.

7.2

Policy Development & Review

Development, approval, periodic review, and communication of organisational policies to ensure alignment with laws, regulations, and best practices.

Sustain access to current, approved policies and enable urgent policy updates or approvals required for regulatory or operational continuity.

7.3

Regulatory Compliance Management

Monitors compliance with applicable regulations, licensing conditions, funding requirements, and statutory obligations relevant to social service organisations.

Continue compliance monitoring and escalation for critical regulatory obligations to prevent breaches, penalties, or suspension of services.

7.4

Risk Management & Internal Controls

Identification, assessment, and mitigation of organisational risks, including operational, financial, reputational, and safeguarding risks.

Maintain core risk monitoring and key internal controls necessary to manage high-impact risks and support safe continuation of services.

7.5

Internal Audit & Assurance

Conducts internal audits and assurance activities to evaluate governance effectiveness, compliance, and internal controls.

Defer non-critical audit activities if required, while preserving access to audit records and supporting urgent assurance or regulatory requests.

7.6

External Reporting & Filings

Preparation and submission of statutory, regulatory, financial, and funder reports to authorities and stakeholders.

Ensure timely submission of mandatory reports and filings, prioritising those with legal, funding, or reputational implications.

7.7

Stakeholder Accountability & Transparency Communications

Communication with regulators, funders, donors, members, and the public regarding governance, compliance status, and organisational accountability.

Maintain accurate and timely communications on critical governance or compliance matters to preserve trust and meet accountability expectations.

7.8

Ethics & Whistleblowing Management

Management of ethics frameworks, whistleblowing channels, investigations, and protection of whistleblowers.

Ensure whistleblowing channels remain accessible and critical cases are received, assessed, and escalated without undue delay.

Sub-CBF Code

Sub-CBF

Impact Area

Financial Impact – Monetary Loss (Estimated)

Financial Impact – Calculation of Monetary Loss (State Formula for Calculations)

Impact on MBCO – Affect MBCO

Impact on MBCO – Impact

Remarks – Description

7.1

Board Governance & Strategic Oversight

Strategic decisions, crisis response, Board approvals

High – potential delayed decisions could result in service disruption, estimated loss: SGD 50,000/day

Monetary Loss = (Number of disrupted operational days × average daily operational cost for strategic decisions)

Yes

Delayed or missed Board decisions can prevent critical approvals, affecting organisational continuity

Ensures Board meetings, emergency committees, and escalation channels are maintained during disruptions.

7.2

Policy Development & Review

Internal compliance, staff adherence to policies

Medium – operational inconsistencies or regulatory breaches: SGD 10,000/day

Monetary Loss = (Number of days policy updates delayed × average cost of compliance-related corrections per day)

Yes

Delayed policy updates can lead to non-compliance and operational inefficiencies

Policies must be accessible and reviewed to reflect regulatory changes, ensuring staff guidance is current.

7.3

Regulatory Compliance Management

Legal and statutory adherence, funding compliance

High – fines, penalties, or loss of funding: SGD 100,000/event

Monetary Loss = (Regulatory fines + funding penalties + legal fees) per non-compliance event

Yes

Non-compliance can directly breach MBCO, jeopardising minimum service continuity

Continuous monitoring, reporting, and escalation to mitigate breaches; critical for maintaining licensing and funding.

7.4

Risk Management & Internal Controls

Organisational and operational risk mitigation

Medium – loss from incidents due to weak controls: SGD 20,000/day

Monetary Loss = (Number of incidents × estimated cost per incident)

Yes

Failure to manage risks can escalate operational disruption and affect continuity

Critical risk registers and controls must be maintained even during disruptions to prevent cascading failures.

7.5

Internal Audit & Assurance

Assurance of compliance, governance effectiveness

Low – delayed audits can result in undetected non-compliance: SGD 5,000/day

Monetary Loss = (Number of audit days deferred × estimated cost of non-detection)

Partial

Delay may reduce confidence in controls but core functions continue

Audit activities may be temporarily deferred, provided urgent compliance issues are addressed.

7.6

External Reporting & Filings

Statutory filings, funder and regulatory submissions

High – regulatory penalties or funding suspension: SGD 50,000 per missed filing

Monetary Loss = (Regulatory fines + potential funding withheld) per missed filing

Yes

Missed reporting directly breaches MBCO, risking legal and operational continuity

Prioritise mandatory filings; establish temporary measures if systems or staff are disrupted.

7.7

Stakeholder Accountability & Transparency Communications

Donor, regulator, and public communications

Medium – reputational damage impacting donations: SGD 15,000/day

Monetary Loss = (Estimated lost donations or funding × number of days communication delayed)

Partial

Delays affect confidence but core service delivery may continue

Communication channels must be maintained to ensure trust and accountability.

7.8

Ethics & Whistleblowing Management

Investigation of ethical breaches, protection of whistleblowers

Medium – potential fines, reputational loss: SGD 10,000/case

Monetary Loss = (Number of unaddressed cases × estimated impact cost per case)

Yes

Failure to maintain whistleblowing management can compromise MBCO related to regulatory and ethical compliance

Ensure whistleblowing mechanisms remain accessible and critical reports are acted upon promptly.