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MOM’s AfA-SHEL and the Enhanced Top Executive WSH Programme: What It Means for Singapore Company Officers

On 23 July 2026, the Ministry of Manpower (“MOM”) launched an open call for the Alliance for Action on Safety and Health for Employment Longevity (“AfA-SHEL”) at the Workplace Safety and Health (“WSH”) Conference 2026. Jointly led by MOM, the National Trades Union Congress and the Singapore National Employers Federation, AfA-SHEL is not a new law. It is a tripartite, industry-led alliance that invites Singapore-registered organisations to co-develop practical solutions for injury prevention, return-to-work support and workplace adaptation, so that people can work safely for longer.

For company directors and officers, the more consequential development sits alongside it: from 1 September 2026, the existing Top Executive WSH Programme (“TEWP”), the mandatory training for chief executives and board directors under the Approved Code of Practice on Chief Executives’ and Board of Directors’ WSH Duties, is being enhanced with a stronger focus on executive accountability, governance and due diligence. Read together, the two signal where MOM’s attention is heading: beyond the shop floor and into the boardroom.

This article sets out what AfA-SHEL actually is, how the TEWP enhancement fits into the existing Workplace Safety and Health Act 2006 (“WSH Act”) framework, and what practical governance steps a Singapore company officer, not just those in construction, marine or manufacturing, should now be taking.

What AfA-SHEL Is (and Is Not)

AfA-SHEL was first announced by Minister of State for Manpower Mr Dinesh Vasu Dash during the Committee of Supply debate in March 2026, and formally launched at the WSH Conference on 23 July 2026. It is one of several “Alliances for Action” the Singapore government has used since 2020 to crowdsource industry solutions to structural problems, rather than legislate top-down.

The alliance is organised around three focus areas:

Singapore-registered organisations could submit proposals from 23 July to 31 August 2026, with around 30 selected to join a 14-month innovation programme starting in August 2026, receiving funding support and consultancy from an assigned account manager. In short, AfA-SHEL is an invitation to participate in shaping future WSH solutions, not a compliance deadline. Companies that are not directly involved in the alliance should nonetheless treat its launch as a signal: MOM is widening its WSH lens from high-risk industries to the broader economy, including office-based and service businesses that have historically regarded WSH as someone else’s problem.

The TEWP Enhancement: Where Officer Accountability Actually Bites

What the TEWP currently requires

The TEWP has been a legal requirement since 1 March 2024 for at least one top executive, meaning the chief executive officer or a board director responsible for WSH, of every company in the construction, manufacturing, marine and transport and storage sectors (and any company employing work pass holders in these sectors) to complete. The programme is built around the Approved Code of Practice on Chief Executives’ and Board of Directors’ WSH Duties, and is intended to ensure that the people setting a company’s direction understand their own WSH obligations, not merely delegate them to a safety officer several rungs down.

What changes from 1 September 2026

From 1 September 2026, the TEWP curriculum is being enhanced with a stronger emphasis on executive accountability, governance and due diligence. Practically, this means the training will push top executives harder on questions such as: what governance structures does the board have for WSH oversight, what management information reaches the board on incidents, near misses and risk assessments, and what evidence exists that the board actually exercised diligence, rather than simply signing off on a safety policy once a year.

This is a curriculum and expectation shift, not, as at the time of writing, a change to the statutory text of the WSH Act itself. Companies should treat it as MOM signalling how existing statutory duties will be interpreted and enforced going forward, rather than as a wholly new set of obligations. We have not been able to verify further granular detail of the enhanced syllabus from primary sources at time of writing, and companies should monitor MOM and Workplace Safety and Health Council announcements for the finalised content.

The Underlying Law: Officer Duties Under the WSH Act

The governance push behind AfA-SHEL and the TEWP enhancement did not arise in a vacuum. It builds on duties that already exist in the WSH Act, and which apply well beyond the four sectors currently subject to mandatory TEWP attendance.

Under the WSH Act, general duties are imposed on multiple categories of persons at a workplace, including employers, who must, so far as is reasonably practicable, ensure the safety and health of their employees and others affected by their undertaking, occupiers of workplaces, principals engaging contractors, and self-employed persons. Critically, a person can hold more than one of these capacities at once, and a duty imposed on one person is not diminished merely because it is also imposed on another.

Where the reasonably practicable standard is in issue, the WSH Act places the onus on the accused, not the prosecution, to prove that no more could reasonably have been done. This reverse-onus feature is one reason WSH compliance cannot be treated as a paperwork exercise: if an incident occurs, the company, and potentially its officers, must be able to demonstrate what was actually done, not merely assert that a policy existed.

Most directly relevant to company officers is the provision on offences by bodies corporate under section 48 of the WSH Act. Where an offence under the WSH Act is committed by a body corporate, an officer, which includes a director, chief executive, manager, secretary or any person purporting to act in such a capacity, is also guilty of the offence and liable to be proceeded against and punished accordingly, unless that officer proves both that the offence was committed without his or her consent or connivance, and that he or she had exercised all such diligence to prevent the commission of the offence as he or she ought to have exercised, having regard to the nature of his or her functions and all the circumstances. This due diligence defence is the statutory hook that the TEWP enhancement is aimed squarely at: an officer who cannot show active, documented diligence has no shelter simply because they were not personally on site when an incident occurred.

General penalties under the WSH Act for offences without an expressly stated penalty can reach a fine of up to $200,000 or up to two years’ imprisonment, or both, for a natural person, and up to $500,000 for a body corporate, with enhanced penalties for repeat offenders whose earlier conviction involved a death. These figures underline why the due diligence defence in the officer liability provision is not a technicality: it is often the difference between an officer being exposed to personal liability and not.

Practical Due-Diligence Checklist for Company Officers

Whether or not a company falls within the four sectors currently subject to mandatory TEWP attendance, the direction of travel is clear: boards and top executives are expected to actively govern WSH, not simply delegate and forget. The following checklist reflects what “exercising all such diligence” is likely to look like in practice.

Area What officers should be able to show
Board oversight WSH is a standing board or top-management agenda item, not an annual afterthought, with minutes recording discussion of incidents, near misses and risk trends.
Risk assessments Risk assessments are current, reviewed after any incident or process change, and actually referred to by the people doing the work, not filed and forgotten.
Training records Evidence that the responsible top executive has completed the TEWP, where applicable, and that relevant staff have had WSH induction and refresher training.
Incident reporting A working channel for near misses and incidents to reach management promptly, with a documented trail of follow-up action, not just the fact of reporting.
Contractor and principal duties Where the company engages contractors, evidence that contractor competence and safety measures were checked before and during engagement, not assumed.
Non-high-risk workplaces Office, retail and service businesses should not assume WSH duties are irrelevant; slips, falls, ergonomic and mental health related risks fall within the general duty of care too.
Documentation retention Records, notices and reports required to be kept under the WSH Act are retained for the prescribed period and can be produced promptly if an inspector asks.

None of this is exotic corporate governance. It mirrors, in substance, the kind of oversight a board is already expected to exercise under its general fiduciary duties and statutory duties under the Companies Act. Directors who treat WSH oversight as an extension of the same duty of care they already owe the company will find the TEWP enhancement far less of a shock than those who have historically left it entirely to operations staff.

Why This Matters Even for Low-Risk Businesses

It is tempting for a services, professional or corporate secretarial firm to assume that WSH governance is a construction-sector problem. That assumption is precisely what AfA-SHEL’s first focus area, injury prevention for the general workforce beyond high-risk workplaces, is designed to challenge. Slips and falls in an office, poorly designed workstations, and the health effects of long, sedentary hours are all within scope of an employer’s general duty under the WSH Act. An officer who is found not to have exercised due diligence does not get a lighter standard merely because the underlying industry is considered lower risk; the statutory test in section 48 of the WSH Act applies equally to all officers of all body corporates.

There is also a personal liability dimension worth keeping in view alongside WSH exposure. Officers who are already conscious of their broader exposure to personal liability as a company director should treat WSH governance as one more strand of the same risk management exercise, rather than a separate silo. The same board minutes, the same documented decision-making, and the same habit of asking what evidence would we produce if challenged, serves both purposes.

Companies restructuring their board, whether because a director is stepping down, being removed, or a resignation is in progress, should also factor WSH responsibility hand-over into that process. Guidance on how a director leaves office and the grounds for director disqualification is a useful reminder that governance failures, including safety governance failures, can have consequences that outlast the individual’s tenure if oversight gaps are not properly transitioned to the incoming officer.

What Company Officers Should Do Now

Ahead of the 1 September 2026 TEWP enhancement taking full effect, and independent of whether a company chooses to participate in AfA-SHEL, officers should consider the following immediate steps: confirm whether the company falls within the sectors where TEWP attendance is mandatory and, if so, ensure the responsible top executive is booked onto an approved provider’s programme; review whether WSH is a genuine, minuted board agenda item rather than a slide shown once a year; and commission a light-touch internal review of risk assessments, incident logs and contractor due-diligence records, so that, if ever tested, the company and its officers can point to real evidence of diligence rather than good intentions.

For companies outside the traditionally high-risk sectors, the sensible move is to treat the TEWP enhancement as a cue to voluntarily upgrade internal WSH governance now, ahead of any future extension of mandatory training to a wider range of industries. Regulatory direction in Singapore has historically moved from sector-specific pilots toward broader application, and WSH governance expectations look set to follow that pattern.

Conclusion

AfA-SHEL and the enhanced Top Executive WSH Programme both point in the same direction: Singapore’s workplace safety and health regime is placing more weight on what company officers can demonstrate they actually did, not merely what policies exist on paper. The underlying statutory framework, including the due diligence defence in section 48 of the WSH Act, has been in place for years. What is changing is the level of scrutiny applied to how genuinely that defence has been earned.

If your company needs help reviewing board governance practices, updating director responsibilities, or understanding how WSH obligations interact with your wider corporate secretarial and compliance obligations, Raffles Corporate Services can help you build a practical, evidence based governance framework. Visit Raffles Corporate Services to find out how we support Singapore company officers in staying ahead of evolving regulatory expectations.

The Editorial Team, Raffles Corporate Services

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