Whistleblowing Policy

 

1       INTRODUCTION

We are committed to conducting our businesses with honesty and integrity and we expect all staff to maintain high standards. Any suspected wrongdoing should be reported as soon as possible.

Whistleblowing is the reporting of suspected wrongdoing or dangers in relation to our activities. his includes bribery, facilitation of tax evasion, fraud or other criminal activity, miscarriages of justice, health and safety risks, damage to the environment and any breach of legal or professional obligations.

2       REFERENCE DOCUMENTS

None

3       POLICY

3.1      Qualifying Disclosures

Certain disclosures are prescribed by law as “qualifying disclosures”. A “qualifying disclosure” means a disclosure of information that the employee genuinely and reasonably believes is in the public interest and shows that the relevant company or Group has committed a “relevant failure” by: –

 

  1. a) committing a criminal offence;
  2. b) failing to comply with a legal obligation;
  3. c) a miscarriage of justice;
  4. d) endangering the health and safety of an individual;
  5. e) environmental damage; or
  6. f) concealing any information relating to the above

 

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 relevant company and Group will take any concerns that you may raise relating to the above matters very seriously.

We encourage you to use the procedure if you are concerned about any wrong doing at work. However, if the procedure has been invoked for malicious reasons or in pursuit of a personal grudge, then you will be liable to immediate termination of employment or such lesser disciplinary sanction as may be appropriate in the circumstances.

3.2      The Procedure

In the first instance you should report any concerns you may have to your Line Manager or if you prefer not to raise it with your Line Manager for any reason, you should contact the Chief Executive Officer who will treat the matter with complete confidence. If you are not satisfied with the explanation or reason given to you, you should raise the matter with the appropriate official organisation or regulatory body.

If you do not report your concerns to your Line Manager or the Chief Executive Officer, you should take them direct to the appropriate organisation or body.

A meeting will be arranged with you as soon as possible to discuss your concern. You may bring a colleague or union representative to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.

When an individual makes a disclosure which has sufficient substance or merit warranting further action, the Centre will take action it deems appropriate (including action under any other applicable Centre policy or procedure). Possible actions could include internal investigation, or referral to relevant external bodies such as the police, OFSTED, Disclosure & Barring Service, Health and Safety Executive or the Information Commissioner’s Office.

3.3      Treatment of Others

We aim to encourage openness and will support whistleblowers 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. If you believe that you have suffered any such treatment, you should inform the Chief Executive Officer immediately. 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. However, if we conclude that a whistleblower has made false allegations maliciously, the whistleblower may be subject to disciplinary action.

3.4      Confidentiality

We hope that staff will feel able to voice whistleblowing concerns openly under this policy.

Completely anonymous disclosures are difficult to investigate. If you want to raise your concern confidentially, we will make every effort to keep your identity secret and only reveal it where necessary to those involved in investigating your concern.

3.5      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. We strongly encourage you to seek advice before reporting a concern to anyone external.

 

KIP-0013 Revision 2
Last updated 18th December 2023