Whistle Blowing Policy

1. Introduction

The company recognizes that there may be matters of concern to employees that they wish to bring to the attention of management or the appropriate authorities, but they may be reluctant to do so due to fear of reprisal.

The company is committed to maintaining the highest standards of honesty, integrity, and good practice. If an employee reasonably suspects in good faith that the company, or any employee, agent, or associate of the company, has acted improperly or unlawfully, they can make a disclosure with confidence that it will be taken seriously, handled discreetly, and will not result in disciplinary proceedings, dismissal, or any other detrimental treatment.

2. What Is Whistle Blowing?

Whistle blowing is formally known as making a disclosure in the public interest. Issues that should be reported through the company’s whistle blowing policy include failures related to:

• Breaches of health and safety.

• Commission of a crime.

• Breach of a legal obligation.

• A miscarriage of justice.

• Damage to the environment.

• Attempts to conceal evidence related to the above issues.

Instances of bullying, discrimination, and harassment should generally be reported through the company’s Bullying and Harassment Policy, while complaints personal to the employee’s work should be handled through the company’s Grievance Policy.

Conduct that may lead to whistle blowing could be committed by the company itself, an employee, a third party working on behalf of the company, a client or customer, supplier, or a partner in a joint venture.

3. Who Should the Disclosure Be Made To?

When an employee needs to make a disclosure, it should be done as a matter of urgency so that the company can promptly investigate and handle the matter.

Employees are encouraged to make the disclosure in writing, providing specific details such as dates, locations, and names, along with a concise description of the issue. The company’s Public Interest Disclosure Form, available from the employee’s designated manager, can be used to make the disclosure.

I. Anonymous Disclosures
Employees are encouraged to provide their name when making a disclosure and allow their identity to be revealed during the investigation. However, employees may request confidentiality, and the company will not reveal the whistleblower’s identity without consent, unless required by law.

The company will strive to maintain confidentiality regarding both the disclosure and the whistleblower’s identity. Employees who make a disclosure will not face detrimental treatment, and the company will take steps to prevent any party, including other employees, from subjecting a whistleblower to unfavorable treatment.

II. Malicious Disclosures
The company encourages employees to make disclosures in good faith if they genuinely believe that a failure has occurred or may occur. Employees who make a disclosure in good faith, whether valid or not, will not face any detrimental treatment, including disciplinary action or dismissal.

However, if an investigation reveals that the disclosure was made maliciously or in bad faith, the company reserves the right to initiate disciplinary proceedings under the Company Disciplinary Policy.

III. Investigation of Disclosures
The manager who receives the disclosure will either conduct an investigation or refer the matter to another manager. A meeting may be held with the whistleblower to gather further information, and they may be accompanied by a trade union representative or colleague.

The investigating manager will carry out all necessary inquiries, including interviews with employees, reviewing evidence such as documents or CCTV, and consulting with relevant authorities. A report will be produced outlining the findings and recommending further action.

The manager may choose to disclose the report to the whistleblower, but this is at their discretion. The company will seek to keep the whistleblower informed about the progress and outcome of the investigation, while respecting legal obligations and business interests.

4. Protection of Whistle Blowers

Employees who make valid public interest disclosures will not face detrimental treatment by the company as a result of their disclosure. The company will also take steps to prevent any employee from subjecting a whistleblower to unfavorable treatment.

Employees should be aware that Employment Tribunal proceedings can be brought against them as individuals if they subject a whistleblower to detrimental treatment. The company may also initiate formal disciplinary proceedings under the company’s disciplinary policy in such cases.

5. Further Action

If an employee is dissatisfied with the progression or outcome of the investigation, they should initially raise their concerns informally with the investigating manager or their designated manager. If this does not resolve the matter, they are entitled to raise a formal grievance under the company’s Grievance Policy.