Explainer: What potential offences might have been committed over the inflation of SPH circulation numbers?

However, the version of the SPH audit and risk committee report released to the public has been redacted to remove the names of the personnel allegedly involved and also what offences, specifically, might have been disclosed by the investigation.

First, the inflation of circulation numbers by counting bulk copies that had been returned, unsold or undelivered. Bulk copies refer to news publications sold or distributed at a discounted rate or for free in large numbers However, according to the report, “the NIE Fund was used to pay for NIE bulk copies used to shore up the circulation numbers in annual reports, cushion the fall in print circulation numbers and to meet key performance indicator targets in respect of circulation numbers for the circulation division”.

The report states that the X barter deal dates back to 2013. Two persons are mentioned, though both names are redacted. One was in charge of deciding whether to renew the deal, and the other in charge of approving the decision. This seems unlikely in this case, based on the available evidence, as the ARC report concluded: “The persons who were involved in the overstatement of circulation numbers were from the circulation division. There has been no evidence sighted to suggest that the board or its senior management were involved in this.”

In this case, the thrust of the alleged wrongdoing is deception. It is not clear from the ARC report whether the target of the deception was the company, the public, or some other entity. Second, it could be falsification of accounts, also an offence under the Penal Code. The gist is that the source of the document may be genuine, but the information contained in it is false.

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