If an employee walked into your office tomorrow and said “I want to file a complaint about my manager,” would you know exactly what to do next? Not roughly — exactly. Who investigates? How fast? What gets documented? Who do you legally have to protect from retaliation?
Most business owners assume they’d “figure it out when it happens.” That’s a risky assumption — especially now.
Why this matters more in 2026 than it did a few years ago
Singapore’s Workplace Fairness Act (WFA) is coming. Parliament passed the first WFA Bill in January 2025 and the Workplace Fairness (Dispute Resolution) Bill in November 2025. MOM has confirmed the law is expected to take full effect by end-2027.
Here’s the part employers tend to miss: under the new dispute resolution framework, an employee who feels discriminated against must first raise the matter internally through your company’s grievance handling process before they can request mediation — and only after mediation fails can they escalate to the Employment Claims Tribunal (for claims up to $250,000) or the High Court (above that).
In other words: your internal grievance process is about to become the official first stop in a legal pathway. If you don’t have one — or have one that exists only on paper — you’re not ready.
What a proper investigation process actually looks like
TAFEP’s Tripartite Advisory on Managing Workplace Harassment and its Grievance Handling Handbook lay out what regulators consider a reasonable standard. A defensible process includes:
- Confidentiality — the identities of the complainant and the accused are protected as far as possible.
- A neutral investigator — someone with no reporting relationship or personal stake in the outcome, trained to handle the case fairly.
- A clear timeline — communicated to both parties at the start, not improvised as you go.
- Evidence-based findings — conclusions based on what was actually gathered, not assumptions.
- Progress updates — both the complainant and the accused are told what’s happening, even if the answer is “still investigating.”
- Corrective action — if substantiated, follow through with real consequences and policy fixes, not just a quiet word.
- An appeal channel — so a disputed outcome doesn’t dead-end into resentment or, eventually, a tribunal claim.
Employers are also legally responsible for harassment carried out by their employees if it occurs at the workplace, and harassment can separately trigger the Protection from Harassment Act (POHA) — so weak handling isn’t just an HR risk, it can become a legal one.
A question worth asking yourself
If a complaint landed today, could you produce — in writing — your grievance procedure, your designated investigator, and your timeline commitment? If the honest answer is “no, we’d wing it,” you’re not alone. Most SMEs in Singapore are in the same position. But “most SMEs” won’t be a defence once the WFA is in force.
What you can do now, before 2027
- Put your grievance handling policy in writing — not buried in an employee handbook nobody reads, but as a standalone, communicated procedure.
- Identify and train whoever will act as your neutral investigator (this is often where smaller companies get stuck — there may not be anyone “neutral enough” internally).
- Review your policy against the Tripartite Guidelines on Fair Employment Practices, which the WFA builds on.
- Don’t wait for a real complaint to be your first test run.
A workplace investigation handled badly doesn’t just risk losing the case — it tells your whole team how seriously you take their safety and dignity at work. Getting it right, before the law forces your hand, is the difference between damage control and genuine credibility.
— Written by The HRGenie team. This article is for general information and does not constitute legal advice.
