1.1 Scope
1.1.1 This Code of Practice aims to provide clarity on and strengthen ownership of companies’ Chief Executives’and Board of Directors’ (henceforth termed as “Company Directors”) workplace safety and health (WSH) roles and duties. Company Directors include the Chief Executive or equivalent officer involved in executive decisions as well as activities on policy and decision-making related to the business affairs of the company, which are capable of affecting the company as a whole or a substantial part of it. This is regardless of their title and whether he or she is a member of the entity’s Board of Directors.
1.2 Purpose
1.2.1 Company Directors set the safety culture of their organisations. Their influence and control over their workplace resources and priorities ultimately drive WSH practices at workplaces.
1.2.2 The Workplace Safety and Health Act (WSH Act) section 48(1) already holds all Company Directors liable in ensuring their workers’ safety and health. Under section 48(1)(b) of the WSH Act, they are also responsible for proving that they had exercised due diligence to prevent workplace incidents. This Code of Practice outlines the desired outcomes in organisational systems and culture that Company Directors should seek to achieve in order to comply with section 48(1) of the WSH Act, and lists examples of reasonably practicable steps that Company Directors can take to realise the desired organisational WSH systems and culture.
1.2.3 There are three key points to note about this Code of Practice:
1.2.3.1 Fulfilment of WSH Act obligations
By adopting the principles and measures in the Code of Practice, the Company Directors would be better placed to be considered to have taken reasonably practicable measures to uphold their workers’ safety and health. Compliance with the Code of Practice could be used as a mitigating factor for the Court’s consideration in the event of an organisation’s WSH Act offence. Compliance with the Code of Practice means fulfilling the four principles listed in the Code of Practice. An organisation can fulfil the Code of Practice’s principles by effectively implementing the specific measures suggested in the Code of Practice; more measures implemented will likely result in fulfilling each principle to a greater extent. However, compliance with the Code of Practice, in and of itself, does not equate to due diligence. The Court will assess the degree of diligence that the Company Directors have exercised, having regard to the nature of their functions and to all the circumstances related to the commission of the offence.
1.2.3.2 Relevance to all organisations
The Code of Practice is relevant for all Company Directors, regardless of industry and organisation size.Under the WSH Act, all Company Directors must demonstrate that they have exercised a reasonable degree of due diligence to prevent WSH lapses in their organisations. As such, they should adopt and adapt the recommended practices that best suit the nature of work in their sector and organisation.
1.2.3.3 Calibration of measures in the Code of Practice
Company Directors should calibrate the measures cited in the Code of Practice based on the relevance to their organisations, including industry type and nature of exposure to risks and hazards. There is no one-size-fits-all solution that meets the different needs of every organisation, and the measures listed within the Code of Practice are not intended to be exhaustive. An organisation can still comply with the Code of Practice by implementing other measures in place of those listed here if it can demonstrate how these other measures can also fulfil the four principles.
1.2.4 Workers and managers are also encouraged to know and understand what is expected of the Company Directors who lead their organisations.
2. Principles and Measures
2.1 General
2.1.1 This section describes how the Company Directors can demonstrate leadership in improving WSH performance and management, based on the following principles and measures
2.2 Principle 1: Ensure WSH is integrated into business decisions and have clarity of roles and responsibilities of Chief Executive and individual members of the Board of Directors in leading WSH
2.2.1 Company Directors should set the WSH standards for the organisation. They should identify the individual Company Director(s) to be accountable for the relevant Code of Practice measures or any other WSH related measures the Board adopts, given the diverse range of measures and differing responsibilities and expertise among the Company Directors. In particular, the specific roles of the relevant individual Company Director(s) should be spelt out clearly (e.g. Chief Executive vis-à-vis the individual members of the Board of Directors, and executive directors vis-à-vis non-executive directors).
2.2.2 Measure 1: Assign and document WSH roles and responsibilities of individual Company Director(s). Appointed Company Director(s) should provide WSH oversight, and their roles and responsibilities should be clearly specified and documented. Company Directors should ensure that this document is readily available organisation-wide (e.g. via emails and townhalls), to provide clarity on the WSH duties of individual Company Director(s).
2.2.3 Measure 2: Establish the WSH policy, standards and strategic goals for the organisation. Company Directors or the relevant individual Company Director(s) should set highly effective WSH standards to ensure the safety and health of all their workers and develop strategies and initiatives to achieve these standards. In particular, WSH considerations should be classified as important and non-negotiable decisions.
2.3 Principle 2: Continuously build a strong WSH culture, set the tone and demonstrate visible leadership in embodying and communicating highly effective WSH standards
2.3.1 Company Directors should communicate and demonstrate that WSH is a priority at their workplace. Communication and actions should signal a visible and active commitment from the Company Directors. This includes publishing the organisation’s WSH commitment, reviewing and tracking WSH targets and performance, allocating sufficient resources for WSH, promoting WSH proactively, and having the necessary knowledge on WSH.
2.3.2 Measure 3: Publish the organisation’s WSH commitment, and review, endorse and track the organisation’s WSH targets and performance regularly.
Company Directors should publish their organisation’s WSH commitment annually via their sustainability report, organisation’s website and/or other means. Minimally, this information should be made available within their organisation and to their workers. They should also review, endorse and track their organisation’s WSH targets and performance regularly, such as via performance indicators.
2.3.3 Measure 4: Set WSH as a regular agenda item in management/board meetings. Company Directors should seek to be briefed on and have discussions around WSH-related topics such as:
• WSH Developments – developments on WSH legislation and within the industry, including new and emerging risks and innovative solutions.
• WSH Performance – WSH targets, statistics, industry benchmarks, contractor performance, near-misses and lessons learnt, lost time and cost incurred due to safety lapses, and WSH complaints lodged.
• WSH Resources – WSH personnel, budget, training, technology.
• WSH Measures – key WSH risk register and mitigation measures, workers’ health and well-being, WSH communications and engagement activities.
Company Directors should also incorporate WSH considerations into business and procurement decisions made at management/board meetings.
2.3.4 Measure 5: Ensure sufficient resource allocation to WSH.
Company Directors should allocate sufficient resources to the following WSH areas as relevant to the needs of the company:
• Conduct regular risk assessments;
• Redesign processes to address upstream risks;
• Set reasonable timeframes for project completion to prevent rushing;
• Identify WSH personnel, worker or union leader to champion good WSH practices on the ground;
• Adopt WSH technology and industrial best practices to detect and prevent workplace incidents;
• Provide relevant WSH training and refresher courses;
• Provide safe equipment and tools to ensure safe work procedures;
• Promote WSH and mental well-being initiatives through events and programmes; and
• Hire/leverage professional advice to address or advise on WSH issues.
2.3.5 Measure 6: Facilitate direct reporting of WSH issues to the Company Director(s).
Company Directors should consider (depending on the size of the organisation and number of work sites):
• Implementing a direct reporting line between the Company Director(s) and WSH personnel (e.g. WSH
Officer, WSH Coordinator);
• Setting up a WSH Committee with representation from management, workers and/or union leaders; and
• Working with appointed WSH personnel and/or union leaders (if any) to remind workers to follow safe work procedures.
2.3.6 Measure 7: Acquire WSH knowledge.
Company Directors should consider attending external and/or in-house trainings and learning journeys to keep abreast of the latest WSH resources, developments and industrial best practices locally and internationally:
• External trainings can include bizSAFE and learning journeys to organisations with progressive WSH practices;
• Where resources are available, in-house WSH professionals could conduct WSH trainings for Company
Director(s) to equip them with knowledge on risk management, systems, and processes, as well as possible technologies to improve WSH;
• Subscribe to the WSH Bulletin to keep abreast of latest developments and WSH Alerts to improve WSH practices and prevent similar WSH incidents; and
• Attend WSH conferences and seminars organised by sector agencies, trade associations, tripartite partners, WSH Council etc.
2.3.7 Measure 8: Conduct engagements to understand processes, workers’ concerns and communicate the need to prioritise WSH.
Company Directors should consider:
• Personally conducting regular workplace walkabouts, together with union leaders (if any), and invite workers, including WSH personnel, to share concerns related to WSH, where timely measures are taken subsequently to address these concerns; and
• Conducting regular reviews to better understand workers’ state of well-being (e.g. via townhalls, pulse surveys, iWorkHealth).
2.3.8 Measure 9: Set and demand effective WSH standards and performance from vendors and partners.
Company Directors should include WSH requirements and WSH track records in their organisation’s tender and procurement decisions (e.g. attainment of bizSAFE or international WSH standards certification; good WSH performance track records based on CheckSAFE on MOM’s website).
As an Occupier or Principal, organisations have duties under the WSH Act to ensure the safety and health of their contractors, subcontractors and outsourced personnel when at work. Company Directors, as leaders of the organisations, must also exercise due diligence to prevent any work incidents.
2.4 Principle 3: Ensure that WSH management systems are highly effective and reviewed regularly
2.4.1 Company Directors should ensure that WSH management systems and processes are highly effective and reviewed regularly, so that WSH is upheld and consistently integrated in business decisions. These systems and processes should ensure that risks are regularly monitored, reported, and reviewed. Proactive monitoring and reviews ensure that outdated and unsafe practices are removed, and new and emerging risks are identified, understood and managed. Implementation of proper change management is also critical to ensure sustained improvement in workplace safety. Company Directors should consider using a reward and disciplinary framework to incentivise positive WSH actions and behaviours, and make WSH part of the performance appraisal of every worker.
2.4.2 Measure 10: Ensure effectiveness of WSH management systems and maintain oversight of compliance with safe work procedures.
Company Directors should:
• Institutionalise WSH audits to review robustness of WSH management systems;
• Institutionalise effective Management of Change programmes to ensure sustained improvement in workplace safety and review potential consequences of unintended changes;
• Work with appointed WSH personnel or union leaders (if any) to remind workers to follow safe work procedures; and
• Develop structures/processes to share audit findings and corresponding action plans to mitigate WSH risks and hazards.
2.4.3 Measure 11: Ensure suitable, adequate and timely risk assessment.
Company Directors should ensure that risk assessments are developed and customised to the organisation’s situation, and that WSH risks are updated, and corresponding control measures implemented. The list of WSH risks and control measures should be checked as often as required, such as through weekly coordination meetings and daily toolbox briefings, and reviewed as soon as reasonably practicable when the situation calls for it.
Examples of such situations include but are not limited to:
• After a WSH incident or near-miss;
• When new information of a hazard is known;
• Before deploying new equipment;
• Before introducing a new work process;
• Other external factors such as climate change and inclement weather (e.g. heat stress, heavy rain, haze); or
• When there are changes to the WSH legislation, Code of Practices and guidelines.
2.4.4 Measure 12: Recognise and reward workers’ efforts toward achieving good WSH performance Incentives help reinforce positive actions and behaviours, and strengthen the workplace safety culture.
Company Directors can consider rewarding workers for good WSH behaviours and outcomes (e.g. their proactiveness in reporting of or intervening in unsafe workplace practices, behaviours or situations, their involvement in implementing WSH improvement initiatives) and make WSH part of the performance appraisal of every worker.
2.4.5 Measure 13: Endorse immediate remedial/disciplinary actions to address workers’ repeated noncompliance with safe work procedures.
Conversely, disciplinary actions should be meted out in a timely manner, in response to workers’ repeated non-compliance despite the organisation’s attempt to actively remind and educate workers on safe work procedures (e.g. not following safe work procedures, not wearing personal protective equipment). Disciplinary actions should be balanced with the incentive schemes already implemented in the workplace.
2.5 Principle 4: Empower workers to actively engage in WSH
2.5.1 Company Directors should ensure that their workers are given the necessary voice and platforms to raise any WSH concerns at work. Workers should be equipped with the necessary knowledge and skillsets to uphold and improve WSH. Every worker is a source of WSH intel and a resource to improve WSH. Union leaders can also play an important role to act as the point of contact to gather feedback, encourage
workers to speak up, or be the bridge between workers and their management to strengthen workplace WSH practices.
Company Directors should ensure feedback channels are available from all levels within their organization and build an open reporting culture as part of a collaborative approach to improve WSH. This reporting system should be one where workers feel safe to report WSH issues without fear of reprisal or job loss, even when highlighting inadequacies of their supervisor/senior management.
2.5.2 Measure 14: Ensure processes are in place for workers to receive information on WSH risks and safe work procedures in a timely manner.
Relevant information that should be shared with workers include:
• WSH incidents, hazards, risks and near misses in the organisation;
• Developments in regulatory requirements, WSH management practice and technical work safety procedures; and
• Emergency and crisis response.
Information can be shared via platforms such as:
• Daily toolbox briefings and weekly coordination meetings;
• Department/unit-level meetings and townhalls;
• WSH Committee meetings;
• Staff onboarding and training programmes; and
• Posters in workplaces, emails and short text messages.
2.5.3 Measure 15: Set up reporting systems, encourage proactive reporting and ensure proper follow-up
to address WSH issues.
A comprehensive system and process is necessary for workers to report any WSH incidents, where all reported WSH incidents are adequately investigated and concluded, such as through doing a root cause analysis and the necessary rectifications where required. Company Directors should set the right tone and provide a safe environment for workers to report unsafe practices and near misses, and to assure workers of the safeguards and protections in place (e.g. their identities are kept confidential, no penalties for speaking up).
Company Directors should ensure that these systems (e.g. hotline number or online channels for reporting) are available for both workers and members of the public to report various WSH issues including:
• WSH incidents (e.g. near-misses, hazards, incidents and lapses);
• Concerns/feedback on incident-prevention measures or safety improvements; and
• Company Directors should consider inviting workers to share any WSH concerns or suggestions such as via secured and anonymous platforms to protect the identities of workers, and ensure that workers are empowered to voice WSH concerns and to stop work if they see WSH red flags at work.
Company Directors should ensure proper follow-up of these reports and that appropriate actions were taken to address the issues reported.
2.5.4 Measure 16: Commit resources and protected time for workers to undergo WSH training and refresher courses.
Company Directors should consider:
• Allocating training funds;
• Ensuring protected time during working hours for WSH training, refresher courses, and WSH meetings; and
• Ensuring that managers identify suitable WSH trainings (e.g. in-house/on-the-job, or external training) and monitor the competency of workers under their supervision, especially if the worker is new to the organisation or the role.
When prioritising training support, Company Directors can also consider:
• Ensuring workers attend the relevant mandatory training;
• Ensuring adequate training to mitigate key WSH risks; and
• Integrating WSH in functional training.
2.5.5 Measure 17: Involve workers in the joint development and implementation of strategies/programmes to improve WSH.
• Company Directors should include WSH considerations in all work planning or strategising sessions.
• Company directors should consider involving their contractors/vendors’ WSH teams as well.
• For unionised companies, Company Directors should consider partnering union leaders to jointly develop WSH improvement strategies and action plans.
