Operational Policies

1. Tabung.SG is an online platform for the community to make easy, cashless donations to Mosques and Muslim Organizations.

2. Tabung.SG Co. Ltd. is incorporated as a Public Company Limited by Guarantee with ACRA with UEN number 202105249M. The names and biodata of the members and directors of Tabung.SG are listed below in Annex A.

3. Tabung.SG is not registered as a charity as it does not solicit donations to run its own charitable programmes. It is a commercial entity that provides a service to Mosques and Muslim Organizations. However, it does endeavor to operate on a non-profit basis, i.e. it only charges fees to the extent sufficient to cover its expenses.

4. As a trusted platform, Tabung.SG operates on accountability and transparency. We comply with applicable statutes and regulations, including the Charities Act (Cap. 37) (“Charities Act”), the Charities (Fund-raising Appeals for Local and Foreign Charitable Purposes) Regulations 2012 (“Fund-raising Regulations”), and we endeavor to subscribe to the best practices in the Code of Practice for Charitable Online Fund-Raising Appeals (the “Code of Practice”). A table setting out Tabung.SG's compliance with the Code of Practice is set out below in Annex B.

WE WORK WITH MOSQUES AND MUSLIM CHARITABLE ORGANIZATIONS

5. Tabung.SG lists the following entities on its platform as Recipients:

6. We verify the UEN Number and entity details provided by these entities. Tabung.SG will publish these details on our platform to be available for verification by the general public.

7. Prior to being listed on the platform, Recipient charities will enter into a written agreement with Tabung.SG in compliance with Regulation 14 of the Fund-raising Regulations. These agreements must be signed by authorized signatories and will include terms relating to:

• The scope of service that Tabung.SG provides each Recipient charity, i.e. to facilitate fund-raising via an online platform;
• The responsibilities on Tabung.SG and each Recipient charity, including a warranty to provide accurate information and a declaration that the donations are used for charitable and legitimate purposes;
• The timeframe within which proceeds will be distributed to the Recipient charity;
• The rights of the Recipient charity to request for information pursuant to specified audit rights, in compliance with Regulation 15 of the Fund-raising Regulations;
• Applicable fee arrangements, if any, and the percentage of proceeds forwarded to the Recipient charity.

8. Tabung.SG reserves the right to reject requests to be listed as a Recipient on our platform, and may remove existing Recipients on our platform, on the following (non-exhaustive) grounds:

• If the Recipient is not a registered entity and/or is a shell or false entity;
• If Tabung.SG has reasonable grounds to suspect that the Recipient will use the received donations to support terrorist activities or organizations. See Sections 3 to 5 of the Terrorism (Suppression of Financing) Act (Cap. 325, Revised Edition 2003);
• If Tabung.SG has reasonable grounds to suspect that the Donor(s) and the Recipient(s) are connected in a donation transaction made to facilitate criminal conduct or the transfer of property related to criminal conduct. See, in general, the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act (Cap. 65A Revised Edition 2000);
• If the Recipient provides an unsubstantiated bank account to receive the donation funds, e.g. an unconnected foreign bank account or a bank account appearing to belong to an individual;
• If Tabung.SG receives notice from the authorities to reject the Recipient;
• We do not accept as Recipients any overseas charities or organizations soliciting donations for foreign purposes or beneficiaries without the required permits; and
• We do not accept as Recipients any local or foreign person or individual.

INCOMING DONATIONS

9. We may require a Donor to provide some personal data, especially if they wish to use our recurring monthly donation feature. The collection, use, transfer and management of the personal data will be subject to our published Personal Data Protection Policy.

10. Anyone who uses the Tabung.SG website and/or makes a donation via the Tabung.SG platform agrees to comply with the published Terms of Use.

11. Tabung.SG relies on existing inherent checks carried out by our payment gateways to validate funds transfers for each donation.

RECURRING DONATIONS

12. Donors may use the Tabung.SG website to make recurring monthly or weekly donations to an intended Recipient by selecting the applicable options on the Tabung.SG website. Donors may log in to make changes to this recurring arrangement and may amend the recurring donation sum, suspending the recurring donation for a period or terminating the recurring donation. Tabung.SG will execute the recurring donation automatically for as long as the recurring donation instructions are not suspended or terminated.

REFUND POLICY

13. All Donations are non-refundable.

14. In exceptional circumstances, Tabung.SG may consider requests for refunds provided that: 

• The Donation exceeds S$200;
• The Donor submits a notice in writing to Tabung.SG within 7 days from the date the donation was received by Tabung.SG; and
• Such notice in writing includes the Donor’s name, contact, reason for the refund and appropriate transfer details required to affect the transfer.

15. Tabung.SG reserves the right to reject a Donor’s request for a refund if there are reasonable grounds to determine the Donation and/or refund is or is related to a suspicious transaction.

16. If a refund is authorized by Tabung.SG, Tabung.SG reserves the right to deduct from any authorized refund an amount equivalent to incurred payment gateway transaction costs (incurred in the original donation and in effecting the refund) as well as a reasonable administrative fee.

INTERNAL CONTROLS AGAINST MONEY-LAUNDERING, TERRORISM AND FRAUD

17. To prevent abuse of the Tabung.SG platform, we implement robust verification procedures and safeguards that are as reasonably practicable as possible and in line with common practice in Singapore. We describe these procedures and safeguards in the following paragraphs.

18. To allow sufficient time to review incoming donation transactions, Tabung.SG will hold all incoming donation funds for up to 2 weeks before forwarding undisputed donations to the intended Mosque or Muslim Charitable Organizations.

19. Tabung.SG will flag the following transactions as potentially suspicious transactions:

• Any single donation transaction, or multiple donation transactions tracked to originate from a single source within a period of 7 days, that exceeds S$5,000.
• If Tabung.SG discovers any donations from politically exposed persons or corporate entities related to such persons.
• Any donation transactions that are flagged as suspicious by our payment gateways.
• Any donation transactions discovered to originate from high-risk jurisdictions and/or embargoed countries.
• Any requests for refunds of donations received by Tabung.SG that exceeds S$1,000 or multiple requests for refund linked to a single account or user.

20. In the event of a suspicious transaction, Tabung.SG will carry out the following procedure.

• We will prepare an internal report consolidating all available information related to the donation.
• Tabung.SG will file a Suspicious Transaction Report with the Singapore Police Force.
• The intended Mosque or Muslim Organization will be notified of the suspicious transaction. The funds related to the donation will be segregated and will not be forwarded to the Mosque or Muslim Organization until or unless the matter is fully resolved, and such transfer is allowed by the authorities.

21. Tabung.SG reserves the right to provide all information relevant to the suspicious transaction to the authorities.

INTERNAL CONTROLS FOR THE TRANSFER OF DONATIONS TO INTENDED MOSQUES AND MUSLIM CHARITABLE ORGANIZATIONS

22. Tabung.SG lists as many Recipients as we can on our website for the convenience and choice of our users. Users can select the Donation Recipient that they wish to donate to and the amount they wish to donate. All such donations received, excluding costs and fees, will be forwarded to the selected Recipient and not to any other Recipient.

23. Donations made via PayNow QR Codes will be directly transferred to the Recipient. Tabung.SG does not act as an intermediary in such transfers. For direct donations through the Tabung.SG platform, all donations are processed by the payment vendor, which charges and deducts a payment fee. The donation amount, less the payment fee, will be transferred to the Tabung.SG bank account within 7 days. Tabung.SG consolidates all such donations over a further 7-day period and transfers the gross donation amount to the Recipient at the end of the period, along with a record setting out the number of donors, the donation amount, the payment fees incurred and the total amount transferred to the Recipient. 

24. For accountability and transparency, Tabung.SG implements the following control measures and safeguards to make sure all donation funds that it receives are properly transferred to intended Recipients:

• Consolidation, verification and transfer of donation funds to Recipients will be conducted by at least 2 officers of Tabung.SG every 14 days;
• The officers will carry out internal SOPs and generate bank and transaction reports to verify, identify and resolve any discrepancies before transferring the received donation funds to the intended Recipients. At no point can one officer carry out all the required transactions without another officer’s approval.
• A monthly statement of account is issued to the Recipient setting out the total donation sum received by Tabung.SG and transferred to the Recipient.

25. The Recipients on our platform have audit rights set out in their respective written agreements with Tabung.SG entitling them to request for the following information over a specified period to verify that all received donation funds are transferred to intended Recipients:

• The total number of donors over the specified period; and
• A breakdown of each individual donation over the specified period and the corresponding total donation sum.

26. Tabung.SG is working to support tax deductible donations to IPCs. For such donations to IPCs, a tax deductible receipt must be issued by the IPC. Please bear with us while we work to make this function available soon.

FEES

27. Tabung.SG does not charge any admin or service fees on the Donor for each donation. However, each Donation will be subject to payment processing fees charged automatically by our payment gateways, which are up to 3.1% + $0.50 of the donation amount depending on the mode of transaction chosen by the Donor. Recurring donations will incur an additional 0.5% fee of the donation amount per transaction.

28. Tabung.SG is working hard with our payment solution providers to reduce the payment processing fees so that more of the donation can be transferred to the Recipient. As the volume of donations increases over time, we will do our best to negotiate with our payment vendors for lower processing fees and we will work towards reducing our service fees.

29. Tabung.SG will not be charging the Recipients any services fees and will be absorbing all incurred costs and expenses over the next 12 months, ending April 2022. After this period, Tabung.SG and the Recipients will mutually agree on any applicable service fees. Any such service fees will be paid separately by the Recipients and will not be deducted from the donations amounts. All fees paid to or income earned by Tabung.SG are applied solely towards the costs and expenses of running Tabung.SG platform and no portion shall be paid or transferred directly or indirectly by way of dividends or bonus or by way of profit to its members.

30. In the event of a winding up or dissolution of Tabung.SG, any property left after satisfaction of all debts will not be distributed to its members but to another suitable charitable organization.

Effective Date: 1 April 2021

Last Updated: 21 April 2021

 

ANNEX A: TABUNG.SG TEAM

Members and Directors:

• Ahmad Firdaus Daud
• Ridzwan Jasni
• Muhammad Mohsin
• Zayed Talib
• Noor Azhar Mohamed

Directors:

• Muhammad Noralfian
• Sazzali Sabandi
• Mohammad Noor Farhan Mohd Rasam
• Nadia Ja'afar
• Nadiah Mohamed Shah

 

ANNEX B: THE CODE OF PRACTICE FOR CHARITABLE ONLINE FUND-RAISING APPEALS

The Code advocates the following best practices:

(a) that subscribers to the Code will put in place systems, processes and procedures to ensure that user information is kept safe and secure and that it remains accessible in the event that the subscriber ceases to operate;

(b) that subscribers will ensure transparency on funds raised and that the public can freely access the following information on the subscribers’ crowdfunding platforms:

• regular updates of funds collected by virtue of any charitable fund-raising appeal conducted on the crowdfunding platforms while the appeal is ongoing;
• the total funds collected after a charitable fund-raising appeal has ended;
• maintain proper records of donations received;
• information of past, present and ongoing charitable fund-raising appeals;
• that subscribers will ensure that the Terms and Conditions applicable to a charitable fund-raising appeal are published on the crowdfunding platform for public access, with clear explanations on:
• how the donation process works;
• the duties and responsibilities of the subscribers;
• the due diligence that has been undertaken by the subscribers; and
• the nature and amount of fees and charges which apply;

(c) that subscribers require the persons conducting charitable fund-raising appeals (hereinafter referred to as “fund-raisers”) using the subscribers’ crowdfunding platforms to complete a declaration of compliance with the requirements under the Charities Act of Singapore relating to charitable fund-raising appeals, in such terms as may be proposed by the COC’s Office in consultation with the subscribers;

(d) that subscribers put in place systems and processes for early fraud and mismanagement detection and to ensure legitimacy of appeals, such as:

• development and application of a verification process of personal identification of fund-raisers and beneficiaries via submission of documents to substantiate the appeal;
• development and application of policies and procedures for detection of more sophisticated attempts at fraud; and
• regular reviews and testing of policies and procedures and prompt fixing of flaws as they become known;

(e) that subscribers make available on their crowdfunding platforms the descriptions of the general risks related to donations made via such platforms;

(f) that subscribers evaluate risks associated with Money Laundering and Terrorist Financing (with reference to the guidance issued by the COC’s Office in May 2015 titled “Protecting Your Charity Against Money Laundering and Terrorist Financing”, as amended from time to time) and have in place adequate systems, processes and procedures to address such risks; and

(g) that subscribers liaise closely with the COC’s Office and co-operate on the conduct of periodic audits and reviews of the subscribers’ systems and processes to ensure they are in accordance with the Code.

The Code of Practice for Charitable Online Fund-Raising Appeals	TABUNG.SG Compliance
Adherence to the Code of Practice	Clause 2.1.3 of the Agreement that Tabung.sg enters with Recipients sets out as follows: In addition to the obligation set out in the Agreement above, Tabung.SG shall … operate a platform and provide a commercial fund-raising service for the Recipient in accordance with the terms of this Agreement and Tabung.SG Operational Policies. Clause 4 of the Tabung.SG Operational Policies state that Tabung.SG will … “endeavour to subscribe to the best practices in the Code of Practice for Charitable Online Fund-Raising Appeals”.
The Code advocates the following best practices: (a)       that subscribers to the Code will put in place systems, processes and procedures to ensure that user information is kept safe and secure and that it remains accessible in the event that the subscriber ceases to operate;	Tabung.SG uses the Shopify platform, which is used by 500,000 businesses in 175 countries, to implement a system and processes to keep user information safe and secure. All user information in the Shopify platform will remain accessible even if Tabung.SG ceases to operate.
(b)        that subscribers will ensure transparency on funds raised and that the public can freely access the following information on the subscribers’ crowdfunding platforms: regular updates of funds collected by virtue of any charitable fund-raising appeal conducted on the crowdfunding platforms while the appeal is ongoing; the total funds collected after a charitable fund-raising appeal has ended; maintain proper records of donations received; information of past, present and ongoing charitable fund-raising appeals; that subscribers will ensure that the Terms and Conditions applicable to a charitable fund-raising appeal are published on the crowdfunding platform for public access, with clear explanations on: how the donation process works; the duties and responsibilities of the subscribers; the due diligence that has been undertaken by the subscribers; and the nature and amount of fees and charges which apply;	The Code applies to platforms that run time-limited campaign-related fund-raising appeals which will have a target amount while the appeal is ongoing. Tabung.SG facilitates fund-raising for the charities and Mosques on an ongoing basis. There is no finite, time-limited ongoing fund-raising appeal. Thus, best practice (B)(1) and (B)(2) are not applicable. In compliance with (B)(3), Tabung.SG maintains proper records of donations received. Mosques and charities receive a record of donations whenever Tabung.SG transfers the donations to the Mosques and charities after every 14-day period. Mosques and charities also have the right to request Tabung.SG for a detailed breakdown of such information from time to time. These obligations are set out in the Agreement that Tabung.SG has with its Recipients and the Tabung.SG Operational Policies. (B)(4) is not applicable for the reasons stated above. Nonetheless, Tabung.SG provides information on the recipient Mosque or charity on each donation page. In compliance with (B)(5), Tabung.SG publishes its Terms of Use, Tabung.SG Operational Policies and an FAQ on the Tabung.SG website and includes/references these terms on every donation page.
(c)        that subscribers require the persons conducting charitable fund-raising appeals (hereinafter referred to as “fund-raisers”) using the subscribers’ crowdfunding platforms to complete a declaration of compliance with the requirements under the Charities Act of Singapore relating to charitable fund-raising appeals, in such terms as may be proposed by the COC’s Office in consultation with the subscribers;	For charities, we will request that they complete such a declaration of compliance with the COC office. For mosques, we will wait for MUIS’ confirmation that they have carried out such a declaration of compliance.
(d)      that subscribers put in place systems and processes for early fraud and mismanagement detection and to ensure legitimacy of appeals, such as: development and application of a verification process of personal identification of fund-raisers and beneficiaries via submission of documents to substantiate the appeal; development and application of policies and procedures for detection of more sophisticated attempts at fraud; and regular reviews and testing of policies and procedures and prompt fixing of flaws as they become known;	Our Tabung.SG Operational Policies set out the systems and processes that we have implemented to detect early fraud and mismanagement. Specifically, we will verify the identity of the Mosque and charity prior to listing on Tabung.SG. We will verify that the information provided by the Mosque or charity are accurate before listing on Tabung.SG. Tabung.SG reserves the right to reject unverified entities or entities that have provided unsubstantiated information from being listed on Tabung.SG. We will endeavour to carry out internal audits on our processes to review and test our policies. See Clauses 5 to 8 of the Tabung.SG Operational Policies.
(e)       that subscribers make available on their crowdfunding platforms the descriptions of the general risks related to donations made via such platforms;	As opposed to fundraising platforms that conduct fund-raising appeals on behalf of individuals, causes or campaigns, there is less risk involved with Tabung.SG as it only lists verified Mosques and registered charities. Nevertheless, the Tabung.SG Operational Policies provide information on the donation process, i.e. the flow of monies from the donor to the recipient Mosque or charity, and the checks and policies that Tabung.SG implements, so that donors can be aware of any potential risks relating to their donations. See clauses 22 to 30 of the Tabung.SG Operational Policies.
(f)        that subscribers evaluate risks associated with Money Laundering and Terrorist Financing (with reference to the guidance issued by the COC’s Office in May 2015 titled “Protecting Your Charity Against Money Laundering and Terrorist Financing”, as amended from time to time) and have in place adequate systems, processes and procedures to address such risks; and	The Tabung.SG team has evaluated risks associated with the May 2015 COC document titled “Protecting Your Charity Against Money Laundering and Terrorist Financing” and had drafted the Tabung.SG Operational Policies to address those risks. See Clauses 17 to 21 of the Tabung.SG Operational Policies.
(g)       that subscribers liaise closely with the COC’s Office and co-operate on the conduct of periodic audits and reviews of the subscribers’ systems and processes to ensure they are in accordance with the Code.	Tabung.SG has, through its advisors, liaised with the COC Office. It will contact the COC office to invite periodic audits and reviews of its systems and processes to ensure that they are in accordance with the Code.