Whistleblowing Policy

Policy Scope

Whistleblowing is the name given to the disclosure of information about a wrongdoing that the Company is responsible for.

You’re a Whistleblower if you’re a worker and you report certain types of wrongdoing, either because you know or you suspect it. This will usually be something you’ve seen at work. You must genuinely and reasonably believe that the wrongdoing you disclose is in the public interest. This means it must affect others, for example the general public.

As a Whistleblower you are protected by law – you should not be treated unfairly or lose your job because you ‘blow the whistle’. By making a qualifying disclosure, you are protected by The Public Interest Disclosure Act 1998.

You can raise your concern at any time about an incident that happened in the past, is happening now, or you believe will happen in the near future.

Qualifying Disclosures

Certain information is protected by law as “qualifying disclosures”.

You are protected by law if you report any of the following:

• A criminal offence, for example fraud

• Someone’s health and safety is in danger

• Risk or actual damage to the environment

• A miscarriage of justice

• The company is breaking the law, for example does not have the right insurance

• You believe someone is covering up wrongdoing

These acts can be in the past, present or future, so that, for example, a disclosure qualifies if it relates to environmental damage that has happened, is happening, or is likely to happen.

The Company will take any concerns that you may raise relating to the above matters very seriously and we encourage you to use the procedure below to raise any concerns.

Should the concern not meet the requirement to be a qualifying disclosure, you should raise this under the Company’s grievance policy. It will be confirmed by a Company Director if this is the case.

Personal grievances (for example bullying, harassment, discrimination) are not covered by whistleblowing law, unless your particular case is in the public interest.

Procedure

Reporting a Concern

In the first instance you should report any concerns you may have to a Company Director. All concerns will be treated in the utmost confidence. You must say straight away if you do not want anyone else to know it was you who raised the concern.

You may be asked to confirm any verbal concerns in writing or to confirm a written record of a verbal report.

Concerns can also be directed to the appropriate organisation or regulatory body with authority for our business area.

Investigation Meeting

Following submission of a disclosure made under this policy, an investigation meeting will be held with the person who has made the report to listen to their concerns, gather information (including whether they have any supporting evidence or can identify any witnesses) and decide if any action is needed. This meeting will be held within 7 working days following receipt of the disclosure.

After this meeting, the investigating Director will conduct a full investigation into the concerns raised. The investigation will aim to gather all relevant information including relevant documentary evidence or witness statements.

This investigation will be completed within 4 weeks following receipt of the disclosure. If this is not possible, the investigating Director will speak to the employee in advance of the completion deadline to agree an extended period of investigation.

Once the investigation is complete, the investigation Director will write to the employee confirming the outcome.

Appeals

If the employee is not satisfied with the explanation or outcome, they may raise the matter with the appropriate official organisation or regulatory body. Alternatively, employees may raise a formal complaint under the Company’s grievance policy.

Formal action

Should formal action be required as a result of any disclosure made under this policy, this action will be carried out in accordance with the applicable internal policy. Any potential sanctions imposed will be fair and reasonable in line with the relevant policy.

Protection against detrimental treatment

All employees who raise matters of concern under this policy are protected against detrimental treatment, up to and including dismissal, because they have made a disclosure.

Bullying, harassment or any other detrimental treatment afforded to a colleague who has made a qualifying disclosure is unacceptable. Anyone found to have acted in such a manner will be subject to disciplinary action.

Last Updated: January 2020