Whistleblowing

The Company has developed this Whistleblowing Policy to demonstrate its commitment to open and accountable management. This policy is designed to allow staff to disclose information that they believe shows malpractice, unethical conduct or illegal practices in the workplace, without being penalised in any way. This includes protecting staff from any detriment or discrimination if they do report (i.e. 'blow the whistle on') improper or illegal conduct within the organisation.

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases staff should not find it necessary to alert anyone externally. However, the law recognises that in some circumstances it may be appropriate for staff to report their concerns to an external body such as a regulator. It will very rarely if ever be appropriate to alert the media. We strongly encourage any member of staff to seek advice before reporting a concern to anyone external. The independent whistleblowing charity, Public Concern at Work, operates a confidential helpline. It also has a list of prescribed regulators for reporting certain types of concern. Its contact details are at the end of this policy, along with the contact details of the Charity Commission for England and Wales which also has a dedicated whistleblowing support line. Should you have any questions or require clarification regarding our whistleblowing policy, feel free to speak to the Administrator for this policy.

All organisations face the risk of things going wrong or of unknowingly harbouring malpractice. The Company takes malpractice very seriously. We encourage open communication from our employees. We want them to feel secure about raising your concerns. All staff have statutory protection if they raise concerns regarding Modern Slavery in the right way. This policy is designed to give staff that opportunity and protection.

It does not matter if you are mistaken. You do not have to prove anything about the allegation you are making but you must reasonably believe the information you have tends to show some malpractice. This policy applies to employees, contractors and other workers within the Company, including agency workers and those who work from home.

There is a difference between whistleblowing and raising a grievance:

• Whistleblowing is where you have a concern about a danger or illegality that has a public interest aspect to it (e.g. because it threatens clients, third parties or the public).
• A grievance or complaint generally relates to your own employment position and does not have an additional public interest dimension.

This policy is not the procedure for general grievances. If you have a complaint about your own personal circumstances you should use the normal grievance procedure.

The sort of concerns covered by this policy are:

• That a criminal offence has been, is being or is likely to be committed;
• That someone within our supply chain is being subjected to a form of modern slavery;
• Danger to the health and safety of any individual;
• Damage to the environment;
• Deliberate concealment of any of the above;

The Company is committed to this policy. If you use this policy to raise a concern, we give you our assurance that you will not suffer any form of retribution or detrimental treatment. We will treat your concern seriously and act according to this whistleblowing policy. If you ask for a matter to be treated in confidence we will respect your request and only make disclosures to third parties, partners, or other staff with your consent. This assurance applies regardless of whether the subject matter of your concern, report or disclosure relates to this company, a client or third party.

If you are concerned about any form of malpractice covered by this policy, you should normally first raise the issue with the Administrator. Concerns can be raised orally or in writing. When raising the concern, you may choose to either include your identity or remain anonymous. You may wish to discuss your concern with a colleague before you formally raise it under this policy. However, remember that once you have raised your concern (alone or with your colleague), in the interests of everyone involved, this is a confidential process.

After an employee has raised a concern, we will record that concern in our central Whistleblowing Report Register which is maintained by the Administrator. We will then decide how to respond in a responsible and appropriate manner under this policy. This will usually involve making internal enquiries first, but it may be necessary to carry out an investigation at a later stage. This may be formal or informal, depending on the nature of the concern raised. We will endeavour to complete investigations within a reasonable time. We will keep you informed of the progress of the investigation carried out and when it is completed. Please note that we will not be able to inform you of any matters that would infringe the duty of confidentiality owed to others.

The purpose of this policy is to give staff the opportunity and protection they need to raise concerns internally. We expect that in almost all cases, raising concerns internally would be the most appropriate action for you to take.

If, for whatever reason, you feel you cannot raise your concerns internally and you reasonably believe the information and any allegations are substantially true, you can consider raising the matter with a reputable regulator. A list of all the bodies currently listed as regulators for the purpose of raising your concerns and the areas they are responsible for is available from the Department for Business Innovation and Skills.

If you have good reasons for not using the internal or regulatory disclosure procedures described above, you may consider making a wider disclosure, e.g. by reporting the matter to the police or to the media.

Caution: whistle-blowers who make wider disclosures of this type will only be protected in certain circumstances (such as from dismissal or suffering detrimental treatment). The Company recommends that employees take independent legal advice before following this course of action. When making external disclosures, you should be aware of your obligation to keep the affairs of a supplier confidential unless:

• Disclosure is required or permitted by law; or
• The supplier consents.

The whistle-blower should only divulge relevant information regarding a potential breach of The Act to the appropriate staff member. Defaming a supplier without undergoing the correct procedure could needlessly defame a supplier.

Those using the procedure outlined in this policy to raise a concern are assured that they will not suffer any form of retribution or detrimental treatment. Any person who victimises a bona fide whistle-blower will be liable to disciplinary action. However, to ensure the protection of all our employees, those who maliciously make a false allegation will be liable to disciplinary action.

If you have any questions about the application of this policy, please contact the Administrator or any independent concern e.g. Public Concern at Work which is a leading independent charity whose main objectives are to promote compliance with the law and good practice in the public, private and voluntary sectors. It is a source of further information and advice at www.pcaw.co.uk. Public Concern at Work provides a free helpline, offering confidential advice on 020 7404 6609.

Reports can be made through the following channels: