WHISTLEBLOWING
Last Revision Date: October 2018
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1. OVERVIEW
This policy outlines what you should do if you suspect something happening at work is putting you or others in danger or is illegal or unethical.
This policy applies to all employees, contractors, consultants, officers, interns, casual and agency workers. This policy is non-contractual.
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2. WHAT IS WHISTLEBLOWING?
Our aim is to maintain the highest standards of integrity in everything we do. However, all organisations can occasionally be affected by conduct that is dangerous, against the law or breaches ethical or professional codes.
Should you have any such concerns, we encourage you to report them immediately — this is called ‘whistleblowing’. You can be assured that we will take your concerns seriously, they will be thoroughly investigated, and you can be confident there will be no reprisals.
The types of concerns you may want to raise with us by whistleblowing might include:
any activity you suspect is criminal
any activity you suspect puts health and safety at risk
any activity you suspect may damage the environment
any activity you suspect breaches our policy on bribery and corruption
any failure to comply with legal or regulatory obligations
any failure to meet professional requirements; and/or
any attempt to conceal one or more of these activities.
Speak to your Line Manager if you are not sure whether something you have become aware of is covered by this policy. Note that if your complaint is about the way people are behaving towards you, then you should refer to our policy on Bullying and Harassment, or to our Grievance Policy, for guidance on how to proceed.
3. HOW TO RAISE A CONCERN
In most cases, you should start by raising your concerns with your manager, either face-to-face or in writing. If you would prefer not to go to your manager, you should write to a Company Director. You should also do this if your concerns are of a very serious nature.
Your letter should say that you are raising your concerns under this policy and then explain what they are. Include all the key facts, dates, and the names of the people involved.
You will be invited to a meeting to discuss your concerns, and you are entitled to be accompanied at this and any subsequent meetings by a colleague or trade union representative. If you bring a companion, we ask that you both agree to keep your disclosures confidential before and after the meeting and during any investigation that may follow.
After the initial meeting, we will investigate your concerns and we may ask you to attend further meetings. To investigate properly, we may involve specialists with particular knowledge or experience of the issues you have raised.
You will be kept informed about how our investigations are progressing and how long they are likely to take. Sometimes, however, we may be unable to give you details about the investigation (or any action it leads to) as we need to protect confidentiality and comply with legal obligations. We understand this may be frustrating and give you concerns about whether we have actually done anything, and if this happens we will do our best to sit down with you and explain why we are acting in the way we are.
Your concerns will be addressed fairly, but we cannot guarantee the outcome of our investigations will be the one you want. If you are not satisfied with how we have conducted the investigations, you can take the matter to [one of our board directors] for further consideration.
Most concerns are raised with us in good faith, but occasionally someone makes a false allegation out of malice or because they believe they have something to gain. Anyone found doing this will face action under our Disciplinary Policy and is at risk of being dismissed for gross misconduct.
4. Confidentiality an Anonymity
There is a significant difference between wanting to keep your concerns confidential and making a disclosure anonymously. We actively discourage anonymous whistleblowing.
You are always encouraged to raise concerns openly, and if you prefer to do so in confidence, we will do all that we can to ensure your identity remains hidden. We may want to disclose your identity to people involved in the investigation but will always discuss this with you first.
You are protected from reprisals under this policy, but if you are still worried we encourage you to discuss this with us and we will explore how far we can go in keeping your concerns confidential.
Concerns raised anonymously are very difficult — and sometimes impossible — to investigate. We can’t properly establish whether your allegations are credible without being able to ask you for more details or for clarification, and this makes it hard to reach an informed decision. This is why we urge you not to report matters anonymously.
How we protect whistle-blowers
If you raise a concern in good faith under this policy, we will support you fully even if we find through our investigations that you made a mistake or that there has been no breach of policy, legal obligation etc. However, if you feel you have been treated detrimentally as a result of raising a concern, you must tell us at once. First inform your Line manager and, if the matter remains unresolved, you must follow the formal process in our Grievance Policy.
All whistle-blowers are afforded the same protection, so you must not threaten others who have raised concerns or carry out reprisals against them. You may face disciplinary action which could include dismissal for gross misconduct, if we find that you have. You may also face legal action from the whistle-blower in these circumstances.
Taking your concerns outside the Company
This policy outlines the process for raising, investigating, and resolving wrongdoing within the workplace. It is rarely necessary – or, from our point of view, desirable – for anyone outside the Company to become involved when a whistleblowing allegation is made.
In some exceptional circumstances, you may need to go to an external body such as a regulator.
This policy covers the actions of third parties such as suppliers, service providers, and clients, as well as our staff. Should you have concerns about a third party, you are encouraged to raise them with us before approaching anyone else. Your Line Manager will be able to assist you.
Alerting the media to a concern - particularly before or during an internal investigation is almost never justified or appropriate in any situation. We strongly discourage you from doing so and will treat any contact with the press as a serious disciplinary issue justifying
dismissal unless exceptional circumstances exist. We would normally expect you to have taken all reasonable steps to deal with the matter internally or with an external regulator, and to have taken full advice from a solicitor before being justified in approaching the press.
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