We are committed to conducting our business with honesty and integrity and we expect you to maintain our high standards. Any suspected wrongdoing should be reported as soon as possible.
The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. We encourage you to raise any concerns that you may have about the conduct of your colleagues or the way in which the business is being run.
Under certain circumstances, you have legal protection if you make disclosures about an organisation for whom you work i.e. you are a ‘whistle-blower’.
This policy sets out how you can raise any concerns that you have and how those concerns will be dealt with.
The law provides protection for employees who raise legitimate concerns about specified matters. These are called "qualifying disclosures". A qualifying disclosure is one made in the public interest by a worker who has a reasonable belief that one of the following things is being, has been, or is likely to be committed:
- a criminal offence;
- a miscarriage of justice;
- an act creating risk to health and safety;
- an act causing damage to the environment;
- a breach of any other legal obligation; or
- concealment of any of the above;
It is not necessary for you to have proof - a reasonable belief is sufficient. Please do not take matters into your own hands. You have no responsibility for investigating the matter - it is our responsibility to ensure that an investigation takes place.
If you make such a protected disclosure, you have the right not to be dismissed, subjected to any other detriment, or victimised, because you have made a disclosure.
We encourage you to raise any concerns under this procedure in the first instance. If you are unsure whether or not to raise a concern, you should discuss the matter with your manager.
The law on whistleblowing recognises that, in some circumstances, it may be appropriate for you to report your concerns to an external body, such as a regulator. We encourage you to seek advice before doing this and an organisation called Protect operate a free, confidential whistleblowing advice service. Their website is https://protect-advice.org.uk/ and the advice line number is 020 3117 2520.
If you have a concern about malpractice, we hope that you will feel able to raise it first with your line manager or a Director and this can be done orally or in writing. It will help if you state the facts of the matter clearly and you can also outline how you would like it to be investigated. If you have a direct or personal interest in the matter you should also tell us at this stage and please remember to give details of how you can be contacted.
Please note that:
- You must believe the disclosure of information is in the public interest.
- You must believe it to be substantially true.
- You must not act maliciously or make false allegations.
- You must not seek any personal gain.
Once you have reported your concern, the Company will look into it to assess initially what action should be taken. You may be asked how you think the matter might best be resolved. If your concern falls more appropriately within other policies we will tell you.
We will institute the appropriate enquiries and/or investigations. We will:
- tell you who is handling the matter and how you can contact them;
- say whether your further assistance may be requested;
- and, if you request, you will be written to, with a summary of your concern and an outline of how the Company proposes to handle it.
Please remember that we cannot guarantee that we will respond to all matters in the way that you might wish, the matter will be handled fairly and properly. By using this policy, you will help us to achieve this.
While the purpose of this policy is to enable us to investigate possible malpractice and take appropriate steps to deal with it, we will give you as much feedback as we properly can. If requested, we will confirm our response to you in writing. Please note, however, that we may not be able to tell you the precise action we take where this would infringe a duty of confidentiality owed by us to someone else.
If you are not satisfied with the outcome, please seek advice from Protect to enable you to make an informed decision about whether it is appropriate to raise the matter with the appropriate organisation or body, e.g., the Police, the Environment Agency, or Health and Safety Executive.
All concerns will be treated in confidence and every effort will be made not to reveal your identity if you so wish. At the appropriate time, however, you may need to come forward as a witness.
We do encourage you, however, to put your name to your concern whenever possible.
Protection and support for whistle-blowers
We aim to encourage openness and will support whistle-blowers who raise genuine concerns under this policy, even if they turn out to be mistaken.
Whistle-blowers must not suffer any detrimental treatment as a result of raising a genuine concern. If you believe that you have suffered any such treatment, you should inform your manager immediately.
You must not threaten or retaliate against whistle-blowers in any way. If you are involved in such conduct, you may be subject to disciplinary action.
However, if we conclude that a whistle-blower has made false allegations maliciously or with a view to personal gain, the whistle-blower may be subject to disciplinary action.