Whistleblowing Policy

The Company is committed to conducting its business with honesty and integrity, and expects everyone who works for it to maintain the same standards. All organisations face the risk of things going wrong, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential to prevent such situations occurring and to address them when they do.

The aims of this policy are to encourage individuals to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected; to provide guidance on how to raise those concerns; and to reassure individuals that they can raise genuine concerns without fear of reprisal, even if they turn out to be mistaken.

This policy applies to all individuals working for the Company or on the Company’s behalf in any capacity, including employees, directors, officers, agency workers, volunteers, interns, agents, contractors, consultants and business partners. It does not form part of any employee’s contract of employment and the Company may amend it at any time.

What is whistleblowing?

Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:

• criminal activity, including fraud, bribery and corruption;
• failure to comply with any legal or professional obligation or regulatory requirement;
• miscarriages of justice;
• danger to health and safety;
• damage to the environment;
• modern slavery or human trafficking, in the Company’s business or supply chains;
• breaches of data protection law or misuse of personal data, including customer data;
• sexual harassment;
• negligence or serious misconduct; and
• the deliberate concealment of any of the above.

A whistleblower is a person who raises a genuine concern relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or danger affecting any of the Company’s activities, you should report it under this policy.

This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases you should use the Grievance Procedure or the Anti-Harassment and Bullying Policy, as appropriate. If you are uncertain whether something is within the scope of this policy, you should seek advice from the Whistleblowing Officer.

Raising a concern

The Company hopes that in many cases you will be able to raise any concerns with your line manager. You may tell them in person or put the matter in writing if you prefer. They may be able to agree a way of resolving your concern quickly and effectively.

However, where the matter is more serious, where you feel that your line manager has not addressed your concern, or where you prefer not to raise it with them for any reason, you should contact the Whistleblowing Officer, who is a director of the Company. If your concern relates to the Whistleblowing Officer, you should raise it with another director.

The Company will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague or trade union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation. The Company will take down a written summary of your concern and provide you with a copy after the meeting, and will aim to give you an indication of how it proposes to deal with the matter.

You do not need to have firm evidence before raising a concern, but you should have a reasonable belief that the information you are disclosing shows one or more of the kinds of wrongdoing listed above. You should not investigate the matter yourself.

Confidentiality

The Company hopes that staff will feel able to voice whistleblowing concerns openly under this policy. However, if you want to raise your concern confidentially, the Company will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, the Company will discuss this with you first.

The Company does not encourage staff to make disclosures anonymously. Proper investigation may be more difficult or impossible if the Company cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible. Whistleblowers who are concerned about possible reprisals if their identity is revealed should come forward to the Whistleblowing Officer and appropriate measures can then be taken to preserve confidentiality.

Investigation and outcome

Once you have raised a concern, the Company will carry out an initial assessment to determine the scope of any investigation. The Company will inform you of the outcome of its assessment. You may be required to attend additional meetings in order to provide further information.

In some cases the Company may appoint an investigator or team of investigators, including staff with relevant experience of investigations or specialist knowledge of the subject matter. The investigator may make recommendations for change to enable the Company to minimise the risk of future wrongdoing.

The Company will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent it from giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.

If the Company concludes that a whistleblower has knowingly made false allegations, or has made them maliciously or for personal gain, the whistleblower will be subject to disciplinary action.

If you are not satisfied

While the Company cannot always guarantee the outcome you are seeking, it will try to deal with your concern fairly and in an appropriate way. By using this policy you can help it to achieve this.

If you are not happy with the way in which your concern has been handled, you can raise it with another director. Alternatively, you may contact the Chair of the Board.

External disclosures

The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.

The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. A list of the prescribed people and bodies to whom qualifying disclosures may be made is published by the UK Government. It will very rarely, if ever, be appropriate to alert the media. The Company strongly encourages you to seek advice before reporting a concern to anyone external.

Protect, the independent whistleblowing charity, operates a confidential advice line on 020 3117 2520 and can provide advice on the various options available to you and on how to raise a concern about malpractice at work. You can also contact the Government’s Modern Slavery Helpline on 0800 0121 700 for concerns about modern slavery.

Whistleblowing concerns usually relate to the conduct of Company staff, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. The law allows you to raise a concern with a third party where you reasonably believe it relates mainly to their actions or something that is legally their responsibility. However, the Company encourages you to report such concerns internally first.

Protection and support for whistleblowers

It is understandable that whistleblowers are sometimes worried about possible repercussions. The Company aims to encourage openness and will support staff who raise genuine concerns under this policy, even if they turn out to be mistaken.

Whistleblowers must not suffer any detrimental treatment as a result of raising a genuine concern. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the Whistleblowing Officer immediately. If the matter is not remedied you should raise it formally using the Grievance Procedure.

You must not threaten or retaliate against whistleblowers in any way. If you are involved in such conduct you will be subject to disciplinary action. In some cases the whistleblower could have a right to sue you personally for compensation in an employment tribunal.

No confidentiality agreement, settlement agreement or contractual term prevents you from making a protected disclosure, and the Company will not seek to rely on any such term to stop you doing so.

Responsibility for this policy

The Board has overall responsibility for this policy and for reviewing the effectiveness of actions taken in response to concerns raised under it. The Whistleblowing Officer has day-to-day operational responsibility for this policy and must ensure that all managers and other staff who may deal with concerns or investigations under it receive regular and appropriate training.

All staff are responsible for the success of this policy and should ensure that they use it to disclose any suspected danger or wrongdoing. Staff are invited to comment on this policy and suggest ways in which it might be improved. This policy is reviewed at least annually.

Personal data collected in connection with a concern raised under this policy will be processed in accordance with the Company’s data protection obligations and retained only for as long as necessary.